V E S 001512.pd f 
Preliminary Permitting Action for Veolia in Sauget 

David Ogulei to: Reed, Michael 

Cc: "Bakowski, Ed" 

n . 

11/28/2012 03:20 P M 

FYI - George Czerniak shared this information with Laurel earlier today. I'm forwarding this to you 

to ensure that you also get this timely. 

-David 

We will be sending the enclosed documents to Veoha tomorrow for a two week review prior to putting 

the permitting actions on notice. I wanted to give you a heads up as well as extend Illinois EPA the 

opportunity to provide input to us during this two week preliminary review period . 

EPA has made a preliminary determination to deny the feedrate limits requested by Veolia, and to 

incorporate into a revised Title V permit feedrate limits that EPA considers to be supported by the 

available performance test data and federal regulations. EPA will propose periodic monitoring 

requirements to ensure compliance with EPA's proposed feedrate limits. 

David Ogulei is the permit writer. Please share any comments on the preliminary draft permit and 

other materials directly with him by December 14, 2012. 

Veolia SOB_November 2012.pdf Veolia Sig Mod_November 2012.pdf 

Veolia Fact Sheet ll-27-12.pdf Veolia NOID_November 2012.pdf 

David Ogulei 

U.S. Environmental Protection Agency 

Region 5 | Air & Radiation Division I A-18J 

77 West Jackson Blvd. I Chicago, Illinois 60604 

Phone: (312) 353-0987 | Fax: (312) 692-2080 

Ogulei.David@epa.gov 

VES 001512 
United States Environmental Protection Agency 

Region 5 

Air Programs Branch 

Air & Radiation Division 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

AIR POLLUTION CONTRO L 

TITLE V PERMIT T O OPERATE 

Permit No.: V-IL-1716300103-08-01 Expires: October 12, 2013 

PERMI T REVISIO N HISTOR Y 

Initial Permit Date: September 12. 2008 

Effective Date: October 12,2008 

Significant Modification: xx, 2013 

' Effective Date: xx, 2013 

In accordance with the provisions of Title V of the Clean Air Ac t and 40 C.F.R, Part 71 and 

applicable rules and regulations, 

Veolia Environmental Services 

is authorized to operate air emission units and to conduct other air pollutant emitting activities in 

accordance with the permit conditions listed in this permit. 

This source is authorized to operate in the following location: 

7 Mobile Avenue, Sauget, Illinois, St. Clair County, 62201 

Terms and conditions not otherwise defined in this permit have the meaning assigned to them in 

the referenced regulations. Al l terms and conditions of the permit are enforceable by EP A and 

citizens under the Clean Air Act. 

Once effective, this permit supersedes any other pennit issued to the source pursuant to Title V 

ofthe Clean Air Act ami 40 C.F.R. Part 7 L 

George Czerniak, Acting Director 

A i r and Radiation Division 

U.S. EP A - Region 5 

Date 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12, 2013 

Page: 2 of 134 

TABL E OF CONTENTS 

1J). SOURC E IDENTIFICATIO N AM ) UNIT-SPECIFIC INFORMATIO N 5 

(A) .. 5 

( Bl 5 

2.0. UNIT-SPECIFIC OPERATIN G REQUIREMENT S . ...... 

............ 7 

2.1. 

II ............7 

(C) 

i, . i - i' 

* • ;• -Si : ,! • !• . . 

C A ! 1 . i , . i ' » I " . . 1 

7 

1 1 

1 1 

24 

. . 56 

2.2 .......... 72 

Emission Limitations and Standards............ 72 

CB) inapplicabl e Regulations.............. 73 

TO Work Practice and Operational Requirements .......... 73 

I'D) Monitorin" and Testing.... 75 

( B ,. 79 

2.3 .......... 811 

( A ) Emission Limitations and Standards 80 

(IT Nonapplicable Regulations... .......... 80 

(CO Work Practice and Operational Requirements .......... 80 

(Di .......... 80 

CE) Reeordkeepjng and Reportin» ............ 8! 

2.4 .......... 82 

Standards 

onal Requirements 

.......... 82 

83 

84 

. . nm......................................... 

84 

.......... 85 

2.5 .......... 87 

Emission Limitations and Standards 87 

( Bi 89 

( O Work Practice and Operational Requirements 8

{

) 

I'D) 89 

(E) Recordkeeping and Reporting......... ..........91 

2.6 : s T- L " „ __ 

M.onitonng ano testing 

'- -

VES 001514 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 3 of 134 

2.7 Boiier,.,...,,.^ 96 

(A) Emission Lirnitatioiis and Standards 96 

(B) Nonapplicable Regulations ..„. 97 

((') Work Practice and Operational Requirements 97 

(D) Moiiitoriiag and Testing 97 

( E| Recordkeeping and Reporting. .....,...„.., „ 98 

2.8 Fugitive Emissions • 99 

£A) Emission Limitations and Standards 99 

Llil_Jll2MlMEJ2^ 

(0) Work. Practice and Operational Requirements 100 

(Dt JVtomtor^^ 

(E) Recordkeeping and Reporting 111 

2 9 , _______ _ i _J_J _ - _t _ 

W . l ' _ . _c . O _' _ . " 

'9 ' " O - ' i . -i • *-i _ _ _ ...... 1 L3 

2 _ ^ _ W ._i'7 ' O/^'w . ________ ; j. 113 

__ '_ a L 2J1" _ 2W _ 113 

f Ii) JteieraJ PartJ 1 Renortjng^..^.^............,.. . 

...... lira 

07)} Facility-wide Applicable Requirements.. 1 1.0 

4 " „ _- „ "72 ' 7 --WTM 20 _ ______ ^ ______ ____ _ ...... 12,4 

i

:

 ' _ " _ " _ " " - - - ~^j24_ 

...... 122. 

^,.±2 6 

(09 Compliance Certifications L1L.. 1 ' ,. 127 

_____ . Tl e—nO l _r _ _ _ ^ _„ 

^,,,,.I28: 

i' l-f t "s 11 h m i s s i n n c 97 X 

VES 001515 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12, 2013 

Page: 4 of 134 

Abbreviations and Acronyms 

AST M American Society for Testing and Materials 

C A A Clean Air Act [42 U.S.C. Section 7401 et seq.] 

C E M Continuous Emission Monitor 

C FR Code of Federal Regulations 

C M S Continuous Monitoring System 

C O Carbon Monoxide 

C O M Continuous Opacity Monitor 

D OC Documentation of Compliance 

D R E Destruction and removal efficiency 

E P A United States Environmental Protection Agency, Region 5 

E SV Emergency Safety Vent 

E U Emission Unit 

Facility Veolia Environmental Services 

gal gallon 

g grams 

H A P Hazardous Air Pollutant 

hr hour 

I A C Illinois Administrative Code 

IEP A Illinois Environmental Protection Agency 

kg kilogram 

kpa kilo pascals 

lb pound 

L V M Low Volatile Metals (Arsenic. Chromium and Beryllium) 

MAC T Maximum Achievable Control Technology 

M g megagram 

MMBt u million British Thermal Units 

NESHA P National Emission Standards for Hazardous Air Pollutants 

N O C Notification of Compliance 

N O x Nitrogen Oxides 

NSPS New Source Performance Standard 

N S R New Source Review 

Operator Veolia Environmental Services 

Permittee Veolia Environmental Services 

P M Particulate Matter 

PMio Particulate matter less than 10 microns in diameter 

ppm parts per million 

POH C principle organic hazardous constituent 

P SD Prevention of Significant Deterioration 

Psi Pounds per square inch 

P T E Potential to Emit 

S 0 2 Sulfur Dioxide 

S V M Semivolatile Metals (Lead and Cadmium) 

V O C Volatile Organic Compounds 

VHA P Volatile Hazardous Ai r Pollutant 

VES 001516 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 5 of 134 

1.0. SOURCE IDENTIFICATION AND UNIT-SPECIFIC INFORMATION 

1. General Source Information 

Parent Company: 

Facility: 

County: 

SIC Code: 

Veolia ES, Technical Solutions, L.L. C 

700 E. Butterfield Road 

Lombard, Illinois 60148 

Veolia ES, Technical Solutions, L.L. C 

7 Mobile Avenue 

Sauget, Illinois 62201 

St. Clair 

4953 

A F S Plant Identification Number: 1716300103 

Description of Process: _Veolia ES, Technical Services L.L.C . is a treatment, storage and 

disposal facility, which accepts offsite waste for further disposal through incineration. 

Containers and bulk shipments of hazardous and solid wastes are received, analyzed and 

transferred to temporary storage facilities, and processed and incinerated in one of three 

combustion units. 

2. Source Emission Points 

The emissions units located at the facility at the time of permit issuance are: 

Emission 

Unit Description 

Manufacturer 

/Model 

Date of 

Construc-tion 

Emission Control 

Equipment 

Hazardous 

Waste 

Combustors 

Incineration Unit #2 

(Incinerator) with a 

Maximum Heat 

Capacity 16 

mmBtu/hr 

Trade Waste 

Incineration, TWI2000, Series 2 

9/1986 Joy-Niro Spray 

Dryer Absorber 

(SDA-2), Pulse Flo 

Fabric Filter (BH-2) 

VES 001517 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 6 of 134 

Emission 

Unit Description 

Manufacturer 

/Model 

Date of 

Construc-tion 

Emission Control 

Equipment 

Incineration Unit #3 

(Incinerator) with a 

Maximum Heat 

Capacity 16 

mmBtu/hr 

Trade Waste 

Incineration, TWI2000, Series 2 

9/1986 Joy-Niro Spray 

Dryer Absorber 

(SDA-3), Pulse Flo 

Fabric Filter (BH-3) 

Incineration Unit #4 

(Rotary Kiln) -with a 

Maximum Heat 

Capacity 50 

mmBtu/hr 

International Waste 

Energy, PY*RO X 

6/1988 Tempering 

Chamber, Activated 

Carbon Injection, 

Spray Dryer 

Absorber, Fabric 

Filter 

Material 

Processing 

Areas 

Waste Processing 

Units (Area 1 and 

Area 2) 

Lab Pack Repack 

Unit 

1988 

1988 

None 

Dram Crusher Empty drums are 

crushed 

1984 None 

Storage Tanks 

for Liquid 

Wastes and #2 

fuel oil 

Tanks #2, #4, #6, #8, 

#10, #20, #30, #40, 

#50, #60, #300, 

#302, #304, #306, 

#308, #310, #312, 

#314, and #390 

Modern Welding 1988 Carbon Canisters 

Bulk Feed 

Building 

Temporary storage 

of bulk solid wastes 

in pits prior to being 

fed to incineration 

unit #4 

1988 Cyclone, Airtol 

Baghouse (BF BldgBH-1), Carbon 

Adsorption Unit 

Gasoline 

Storage Tanks 

Design capacity -

564 gallons, 

equipped with 

submerged loading 

pipe 

1992 None 

Boiler Natural Gas-Fired 

Boiler with a 

Maximum Heat 

Capacity 10.6 

mmBtu/hr 

Cleaver Brooks, 250 11/1995 None 

Fugitive Pumps, Valves, N / A None 

VES 001518 
I Veolia Environmental Services Page: 7 of 134 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Emission 

Unit Description 

Manufacturer 

/Model 

Date of 

Construction 

Emission Control 

Equipment 

Emissions Open-End Lines and 

Compressors 

2.0. UNIT-SPECIFIC OPERATING REQUIREMENT S 

2.1. Hazardous Waste Combustors, Units 2,3 and 4 

(A) Emission Limitations and Standards 140 C.F.R. § 71.6(a)(1)] 

The Permittee shall comply with the following requirements for each individual incinerator 

unless specified otherwise: 

1. Visible Eemission Limitation. 

(a) The Permittee shall not cause or allow the emission of smoke or other particulate 

matter, with an opacity greater than 30 percent, into the atmosphere from any emission 

source, except as allowed by 35 IAC 212.123(b) and 212.124. [35 IA C 212.123(a)] 

(b) The Permittee shall not cause or allow the emission of fugitive particulate matter from 

any process, including any material handling or storage activity, that is visible by an 

observer looking generally overhead at a point beyond the property line of the source 

unless the wind speed is greater than 40.2 kilometers per hour (25 miles per hour.) [35 

I AC 212.301 and 212.314] 

2. Sulfur Dioxide Limitation. 

Total sulfur dioxide emissions from the facility shall not exceed 7.7 tons per year for 

units 2 and 3 and 50.76 tons per year for unit 4. [Construction permits 87100024 and 

88010001] 

3. Carbon Monoxide Limitation. 

(a) The Permittee shall not allow emissions of carbon monoxide in excess of 100 parts 

per million by volume, over an hourly rolling average (monitored continuously with a 

continuous emissions monitoring system), dry basis and corrected to 7 percent oxygen. 

The Permittee must also document that, during the destruction and removal efficiency 

(DRE) test runs or their equivalent as provided by §63.1206(b)(7), hydrocarbons do not 

exceed 10 parts per million by volume during those runs, over an hourly rolling average 

(monitored continuously with a continuous emissions monitoring system), dry basis, 

corrected to 7 percent oxygen, and reported as propane. [40 C.F.R. 63.1203(a)(5)] 

VES 001519 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 8 of 134 

(b) The Permittee shall not allow emissions of carbon monoxide emissions from the 

incinerator in excess of 500 ppm corrected to 50% excess air. _[35 IA C 216.141, 

Construction permits 83120053, 87100024, and 88010001] 

(c) The Permittee shall not allow emissions of carbon monoxide emissions from the 

facility in excess of 6.6 tons per year for units 2 and 3 and 13.86 tons per year for unit 4. 

[Construction permits 87100024 and 88010001] 

4. Particulate Matter Limitation. 

(a) The Permittee shall not cause or allow the emission of particulate matter into the 

atmosphere from any incinerator burning more than 0.907 megagram per hour (Mg/hr; 

2,000 pound per hour (lb/hr)) but less than 27.2 Mg/hr (60,000 lb/hr) of refuse to exceed 

183 milligrams per standard cubic meter (mg/scm; 0.08 grain per standard cubic foot 

(gr/scf)) of effluent gases corrected to 12 percent carbon dioxide^ [35 IA C 212.181(b)]. 

(b) Prior to October 14, 2008, the Permittee shall not allow emissions of particulate 

matter from the facility in excess of 34 milligrams per dry standard cubic meter 

(mg/dscm) corrected to 7 percent oxygen. _[40 C.F.R. § 63.1203(a)(7)] 

(c) On and after October 14, 2008, the Permittee shall not allow emissions of particulate 

matter from the facility in excess of 0.013 grain per standard cubic foot (gr/scf), corrected 

to 7 percent oxygen._ [40 C.F.R. § 63.1219(a)(7)] 

(d) The Permittee shall not allow emissions of total suspended solid emissions from the 

facility in excess of 15.0 tons per year for units 2 and 3 and 16.92 tons per year for unit 4. 

[Construction permits 87100024 and 88010001] 

5. Volatile Organic Compounds Limitation. 

(a) The Permittee shall not cause or allow the discharge of more than 3.6 kg/hr (8 lbs/hr) 

of organic material into the atmosphere from any emission unit, except that, if no odor 

nuisance exists, this limitation shall apply only to photochemically reactive material. 

Alternatively, Permittee may use a control device to reduce such emissions either to 10 

ppm equivalent methane (molecular weight 16) or less, or to convert 85 percent of the 

hydrocarbons to carbon dioxide and water. _[35 IAC 219.301, 219.302] 

(b) Organic material emissions from the facility shall not exceed 0.9 tons per year for 

units 2 and 3 and 3.1 tons per year for unit 4. .[Construction permits 87100024 and 

88010001] 

6. Nitrogen Oxide Limitation. 

Nitrogen Oxide emissions from the facility shall not exceed 4.0 tons per year for units 2 

and 3 and 61.6 tons per year for unit 4. .[Construction permits 87100024 and 88010001] 

VES 001520 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 9 of 134 

7. Hazardous Air Pollutant Limitations. 

(a) JPrior to October 14, 2008, the Permittee shall not allow from the facility emissions of 

(i) -dioxins and furans emissions in excess of 0.20 ng TEQ/dscm corrected to 7 

percent oxygen; 

(ii) mercury in excess of 130 micrograms per dry standard cubic meter (ug/dscm) 

corrected to 7 percent oxygen; or 

(iii) lead and cadmium in excess of 240 ug/dscm, combined emissions, corrected to 

7 percent oxygen; 

(iv) __ combined emissions of arsenic, beryllium, and chromium in excess of 

97 ug/dscm, corrected to 7 percent oxygen. 

[40 C.F.R. 3 63.1203(a)1 

(b) On and after October 14, 2008 [40 C.F.R. § 63.1219(a)]: 

(i) The Permittee shall not allow emissions of dioxin and furans from the facility in 

excess of 0.20 ng TEQ/dscm, corrected to 7 percent oxygen; 

-(ii) The Permittee shall not allow emissions of mercury from the facility in excess 

of 130 ug/dscm, corrected to 7 percent oxygen; 

(iii) The Permittee shall not allow emissions of cadmium and lead from the facility 

in excess of 230 ug/dscm, combined emissions, corrected to 7 percent oxygen; 

(iv) The Permittee shall not allow emissions of arsenic, beryllium, and chromium 

from the facility in excess of 92 ug/dscm, combined emissions, corrected to 

7 percent oxygen.i 

[40 C.F.R. 3 63.1.210:0] 

(c) The Permittee shall design, install, operate, and maintain a treatment process that 

destroys benzene in the waste stream by incinerating the waste in a combustion unit that 

achieves a destruction efficiency of 99 percent or greater for benzene. [40 C.F.R. 

§ 61.348(a)(l)(iii)]. 

(d) Al l joints or seams between the pipe sections of any transfer system that consists o f 

continuous hard-piping shall be permanently or semi-permanently sealed (e.g., a welded 

joint between two sections of metal pipe or a bolted and gasketed flange). [40 C.F.R. 

§ 63.689(c)(2)]. 

VES 001521 
) Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 10 of 134 

8. Hydrogen Chloride Limitations. 

(a) Prior to October 14, 2008 ,40 C.F.R. § 63.1203(a)]:. 

JPthe Permittee shall not allow hydrochloric acid and chlorine gas emissions from the 

facility in excess of 77 parts per million by volume, combined emissions, expressed as 

hydrochloric acid equivalents, dry basis and corrected to 7 percent oxygen. [40 C.F.R. 

3 63.1203(a)! 

(b) On and after October 14, 2008-t404i4OJ* ^ 

T-_the Permittee shall not allow hydrogen chloride and chlorine gas (total chlorine) 

emissions from the facility in excess of 32 parts per million by volume, combined 

emissions, expressed as a chloride (CF) equivalent, dry basis and corrected to 7 percent 

oxygen. (4(3 C.F.R. 3 63. i2j9(a|l 

(c) The Permittee shall not allow hydrogen chloride emissions from incinerators 2 and 3 

in excess of 4.0 pounds per hour or the control devices shall demonstrate a minimum HCI 

removal efficiency of 99%. .[Construction permits 83120053 and 87100024] 

9. Destruction and removal efficiency *!->RFt standard: 

(a) Each hazardous waste combustor (HWC) must achieve a DRE of 99.99% for each 

principle organic hazardous constituent (POHC) designated under section 9(c)(ii) ofthe 

permit, below. The Permittee shall calculate the DR E for each POH C using the 

following equation: 

D R E = [1-(WOUT/WIN)] X 100% 

Where: 

WIN = mass feedrate of one POH C in a waste feedstream; and 

WOUT = mass emission rate of the same POH C present in exhaust emissions prior 

to release to the atmosphere. .[40 C.F.R. §§ 63.1203(c) and 63.1219(c)] 

The Permittee must perform intermediate calculations using at least three significant 

figures, but may round the resultant emission levels to two significant figures to 

document compliance. .[40 C.F.R. § 63.1203(d)] 

(b) For dioxin-listed hazardous wastes F020, F021, F022, F023, F026, or F027 (see 40 

C.F.R. § 261.31), each affected HW C must achieve a DR E of 99.9999% for each 

principle organic hazardous constituent (POHC) designated under section 9(c)(ii), below. 

The Permittee must demonstrate this DR E performance on POHCs that are more difficult 

to incinerate than tetra-, penta-, and hexachlorodibenzo-p-dioxins and dibenzofurans. The 

Permittee must use the equation in section 9(a), above, to calculate DR E for each POHC. 

VES 001522 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 11 of 134 

In addition, the Permittee must notify the Administrator of its intent to incinerate 

hazardous wastes F020, F021, F022, F023, F026, or F027. [40 C.F.R. §§ 63.1203(c)(2) 

and 63.1219(c)(1)] 

(c) Principal organic hazardous constituents <R< H4< 

(i) The Permittee must treat the POHCs in the waste feed that Permittee specifies 

under section 9(c)(ii), below, to the extent required by 4{K9F.R.1£63.1203 and 

1219(c)(1). 

(ii) The Permittee must specify one or more POHCs that are representative of the 

most difficult to destroy organic compounds in the hazardous waste feedstream. 

The Permittee must base this specification on the degree of difficulty of 

incineration of the organic constituents in the waste and on their concentration 

or mass in the waste feed, considering the results of waste analyses or other data 

and information. [40 C.F.R. §§ 63.1203(c)(3)(ii) and 63.1219(c)(3)(ii)] 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

1. Units 2, 3, and 4 are not subject to 40 C.F.R. Part 64, Compliance Assurance Monitoring 

(CAM ) for Major Stationary Sources because they are required to comply with a post1990 MAC T standard. [40 C.F.R. § 64.2(a)] 

2. Units 2, 3, and 4 are not subject to 35 IAC Part 229 of the Illinois State Implementation 

Plan (SIP), "Hospital Medical Infectious Waste Incinerators," because the Permittee is 

prohibited from accepting or processing hospital medical infectious waste at the facility. 

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)] 

1. The Pennittee shall not bum hospital medical infectious waste, municipal waste, or 

beryllium! NF.SH AP containing waste. J42 U.S.C. § 7661 c(a)] 

2. The Permittee must operate Units 2, 3, and 4 under these operating parameters limits 

(OPL's) to demonstrate compliance with Subpart EEE . 

Operating Parameters Unit #2 Unit #3 Unit #4 AWFC O 

Minimum primary combustion 

chamber temperature (40 C.F.R. 

i63.1209G)(l),(k)(2)) 

1,712°F 1,734°F 1,509°F Minimum 

hourly rolling 

average 

Minimum secondary combustion 

chamber temperature (40 C.F.R. 

163.1209(j)(l),(k)(2)) 

1,848°F 1,850°F 1,889°F Minimum 

hourly rolling 

average 

Maximum flue gas flowrate or 

production rate (40 C.F.R. 5j 

63.1209(j)(2)), (k)(3), (m)(2), 

(n)(5), (c)(2)) 

13,266 acf/min 13,111 acf/min 43,400 

acf/min 

hourly rolling 

averages 

VES 001523 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 12 of 134 

Operating Parameters Unit #2 Unit #3 Unit #4 AWFC O 

Maximum hazardous waste 

pumblable feedrate rate for each 

combustion chamber (40 C.F.R. 

i63.1209(j)(3),(k)(4)) 

3,003 lbs/hr 4,160 lbs/hr 3,312 lbs/hr 

for PC C and 

1,787 lbs/hr 

for SCC 

hourly rolling 

averages 

Maximum hazardous waste total 

feedrate rate for each combustion 

chamber (40 (2F.R. 3 

63.1209(j)(3),(k)(4)) 

4,149 lbs/hr 5,344 lbs/hr 17,907 

lbs/hr for 

P C C and 

1,787 lbs/hr 

for SCC 

hourly rolling 

average basis 

Operation of waste firing system 

for each location where waste is 

fed to the incinerator (40 C.F.R, 

163.12090X4)) 

Minimum 

waste 

atomization 

pressure for 

low BT U 

waste - 15 psi 

Minimum 

waste 

atomization 

pressure for 

low BT U 

waste -1 5 psi 

Minimum 

waste 

atomization 

pressure for 

low BT U 

waste -1 5 

psi 

Instantaneous 

Maximum temperature of the gas 

at the inlet (40 C.F.R. § 

63.1209(k)(l)),(n)(l)) 

420°F 420°F 435°F hourly rolling 

average 

Minimum carbon injection rate 

(40 C.F.R. 8. 63.1209(k)(6)(i)) 

N / A N / A 6 lbs/hr hourly rolling 

average 

Minimum carrier fluid (gas or 

liquid) flowrate or pressure drop 

(40 C.F.R. 4s63.1209(k)(6)(ii)) 

N / A N / A minimum 

high 

pressure: 

4 psig 

Minimum carrier fluid (gas or 

liquid) flowrate or pressure drop 

(40 C.F.R. 4s63.1209(k)(6)(ii)) 

N / A N / A 

Maximum 

low 

pressure: 

1 inch H 2 0 

hourly rolling 

average 

The brand (i.e., manufacturer) 

and type of carbon used during 

the comprehensive performance 

test (41) C.F.R. § 

63.1209(k)(6)(iii)) 

N / A N / A NORIT 

Americas 

Inc. 

DARCO® 

F G L 

Total feedrate of mercury (40 

C.F.R. § 63.1209(l)(l)(i)) 

0.0017 lbs/hr 0.0018 lbs/hr 0.021 lbs/hr 12-hour rolling 

average 

Total feedrate of mercury (40 

C.F.R. § 63.1209(l)(l)(i)) 

12-hour rolling 

average 

Maximum ash federate (40 

C.F.R. $ 63.1209(m)(3)) 

913.4 lbs/hr 7,559 

lbs/hr 

12-hour rolling 

average 

Total feedrate of semivolatile 

metals (40 C.F.R. 3 

63.1209(n)(2)(ii)) 

91 lbs/hr 82 lbs/hr 64 lbs'hr 12-hour rolling 

average limits 

Total feedrate of low volatile 

metals (40 C.F.R. $. 

63.1209(n)(2)(ii)) 

84 Ibs/hr 77 lbs/hr 77 lbs/hr 12-hour rolling 

average limits 

Feedrate limits for low volatile 84 lbs/hr 77 lbs/hr 77 lbs/hr 12-hour rolling 

VES 001524 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 13 of 134 

Operating Parameters Unit #2 Unit #3 Unit #4 AWFC O 

metals in pumpable feedstreams 

(4() C.F.R. $ 63.1209(n)(2)(vii)) 

average limits 

Feedrate of total chlorine and 

chloride in all feedstreams (40 

C.F.R. § 63.1209(n)(4), (o)(l)) 

250 Ibs/hr 247 lbs/hr 274 lbs/hr 12-hour rolling 

average 

Minimum sorbent feedrate 

(63.1209 (o)(4)(i)) 

Minimum carrier fluid flowrate 

or nozzle pressure drop for the 

spray dry adsorber (40 C.F.R. 5 

63.1209 (o)(4)(ii)) 

The brand (i.e., manufacturer) 

and type of sorbent used during 

the comprehensive performance 

test (40 C.F.R. tj 63.1209 

(o)(4)(iii)(A)) 

Mississippi 

Lime 

Company 

Hydrated Lime 

Code MR200 

Mississippi 

Lime 

Company 

Hydrated Lime 

Code MR200 

Mississippi 

Lime 

Company 

Hydrated 

Lime Code 

MR200 

Maximum combustion chamber 

pressure (40 C.F.R. § 

63.1209(p)) 

-0.01 inch H 2 0 -0.01 inchH 2 0 -0.01 inch 

H 2 0 

5 seconds for 

units 2 and 3 

and 

instantaneous 

for unit 4 

3. Compliance with standards^ [40 C.F.R. § 63.1206(b)(1)] 

The emission standards and operating requirements -*H FM-rF derived from Subpart EE E 

apply at all times except: 

(a) During periods of startup, shutdown, and malfunction; and 

(b) When hazardous waste is not in the combustion chamber (i.e., the hazardous waste 

feed to the combustor has been cut off for a period of time not less than the hazardous 

waste residence time) and the Permittee has documented in the operating record 

compliance with all otherwise-applicable requirements and standards promulgated under 

authority of sections 112 (e.g., 40 C.F.R. Ppart 63, -subparts LLL , DDDDD , and 

NNNNN ) or 129 of the Clean Air Ac t in lieu of the emission standards under 40 C.F.R. 

§§ 63.1203, 63.1204, 63.1205, 63.1215, 63.1216, 63.1217, 63.1218, 63.1219, 63.1220, 

and 63.1221; the monitoring and compliance standards of 40 C.F.R. §§ 63.1206 through 

63.1209, except the modes of operation requirements of § 63.1209(q); and the 

notification, reporting, and recordkeeping requirements of §§ 63.1210 through 63.1212. 

4. (a) If the Pennittee plans to change (as denned in 40 C.F.R. § 63.1206(b)(5)(iii)) the 

design, operation, or maintenance practices of the source in a manner that may adversely 

affect compliance with any emission standard that is not monitored with a CEMS , the 

Permittee must not burn hazardous waste for more than a total of 720 hours (renewable at 

VES 001525 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 14 of 134 

the discretion of the Administrator) and only for the purposes of pretesting or 

comprehensive performance testing. Pretesting is defined at 40 C.F.R. § 63.1207(h)(2)(i) 

and (ii). However, the Permittee may petition the Administrator to obtain written 

approval to bum hazardous waste in the interim prior to submitting a Notification of 

Compliance (NOC) for purposes other than testing or pretesting. The Permittee must 

specify operating requirements, including limits on operating parameter that the 

Permittee determines will ensure compliance with the emission standards of this subpart 

based on available information. The Administrator will review, modify as necessary, and 

approve if warranted the interim operating requirements.. [40 C.F.R. 

§ 63.1206(b)(5)(i)(C)] 

(b) Notification, .[40 C.F.R. § 1206(b)(5)] 

¥««-Thc Permittee must notify the Administrator at least 60 days prior to any change 

described in section 2.1(B)(4)(a), above, unless you document circumstances that dictate 

that such prior notice is not reasonably feasible. The notification must include: 

(i) A description of the changes and which emission standards may be affected; and 

(ii) A comprehensive performance test schedule and test plan under the requirements 

of § 63.1207(f) that will document compliance with the affected emission 

standard(s); 

5. General Operating Requirements, .[40 C.F.R. 63.1206(c)(1)] 

(a) The Permittee must operate only under the operating requirements specified in the 

Documentation of Compliance (DOC) under 40 C.F.R. § 63.1211(c) or the Mt^tOTreaOtw 

ofComrtlianceNOC under 40 C.F.R. §§ 63.12070) and 63.1210(d), except: 

(i) During perfonnance tests under approved test plans according to 40 C.F.R. § 

63.1207(e), (f), and (g), and 

(ii) Under the conditions of section 2.1(C)(3)(i) or (ii), above. 

(b) Documentation of Compliance^ [40 C.F.R. § 1211(c)] 

By October 14, 2008, the Permittee must develop and include in the operating record a 

t9eetttws^ The 79fWttf^ti ^ must 

identify the applicable emission standards under 40 C.F.R. part-Part 63, Ssubpart EEE , 

and the hmits on the operating parameters that will ensure compliance with those 

emission standards. 

(c) Failure to comply with the operating requirements is failure to ensure compliance 

with the emission standards of 40 C.F.R. Ppart 63, Subpart EEE . 

VES 001526 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 15 of 134 

6. Startup, Shutdown, and Malfunction Plan,. [40 C.F.R. §§ 63.6(e)(3), 63.1206(c)(2)] 

(a) The Permittee is subject to the startup, shutdown, and malfunction plan requirements 

of 40 C.F.R. § 63.6(e)(3). [40 C.F.R. § 63.1206(c)(2)(i)] 

(i) The Permittee must develop a written startup, shutdown, and malfunction plan 

that describes, in detail, procedures for operating and maintaining the source 

during periods of startup, shutdown, and malfunction; and a program of corrective 

action for malfunctioning process, air pollution control, and monitoring 

equipment used to comply with the relevant standard. _The startup, shutdown, and 

malfunction plan does not need to address any scenario that would not cause the 

source to exceed an applicable emission limitation in the relevant standard. _The 

purpose of the startup, shutdown, and malfunction plan is to: 

(A) .Ensure that, at all times, the Permittee operates and maintains each affected 

source, including associated air pollution control and monitoring equipment, in a 

manner which satisfies the general duty to minimize emissions established by 40 

C.F.R. § 63.6(e)(l)(i); 

(B) .Ensure that the Permittee is prepared to correct malfunctions as soon as 

practicable after their occurrence in order to minimize excess emissions of 

hazardous air pollutants; and 

(C) .Reduce the reporting burden associated with periods of startup, shutdown, 

and malfunction (including corrective action taken to restore malfunctioning 

process and air pollution control equipment to its normal or usual manner of 

operation). .[40 C.F.R. § 63.6(e)(3)] 

(ii) The Permittee must maintain at the affected source a current startup, shutdown, 

and malfunction plan and must make the plan available upon request for 

inspection and copying by the Administrator. _In addition, if the startup, 

shutdown, and malfunction plan is subsequently revised as provided in 40 C.F.R. 

§ 63.6(e)(3)(viii), the Permittee must maintain at the affected source each 

previous (i.e., superseded) version of the startup, shutdown, and malfunction plan, 

and must make each previous version available for inspection and copying by the 

Administrator for a period of 5 years after revision of the plan. .If at any time after 

adoption of a startup, shutdown, and malfunction plan an affected source ceases 

operation or is otherwise no longer subject to the provisions of this part, the 

Permittee must retain a copy ofthe most recent plan for 5 years from the date the 

source ceases operation or is no longer subject to 40 C.F.R. Ppart 63, and must 

make the plan available upon request for inspection and copying by the 

Administrator. .Upon receipt of a written request from the Administrator that the 

Permittee submit a copy of any startup, shutdown and malfunction plan (or 

portion thereof) which the Permittee maintains at the affected source or which is 

in the possession of the Permittee, the Permittee must promptly submit a copy of 

the requested plan (or a portion thereof) to the Administrator. .The Permittee may 

VES 001527 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 16 of 134 

elect to submit the required copy of any startup, shutdown, and malfunction plan 

to the Administrator in an electronic format. _The Permittee may claim that any 

portion of such a startup, shutdown, and malfunction plan is confidential business 

information entitled to protection from disclosure under section 114(c) of the Ac t 

or 40 C.F.R. § 2.301. If the Permittee makes a CBI claim, it must clearly 

designate in the submission the material which it claims as confidential. 

(iii) _To satisfy the requirements of 40 C.F.R. § 63.6 to develop a startup, shutdown, 

and malfunction plan, the Pennittee may use the affected source's standard 

operating procedures (SOP) manual, an Occupational Safety and Health 

Administration (OSHA, or other plan, provided the alternative plans meet all the 

requirements of 40 C.F.R. 63.6 and the Permittee makes the alternative plans 

available for inspection when requested by the Administrator. 

(iv) The Permittee must revise the startup, shutdown and malfunction plan if required 

by the Administrator to do so based on the results of a determination made under 

63.6(e)(l)(i), or if the Administrator finds that the plan: 

(A) Does not address a startup, shutdown, or malfunction event that has occurred; 

(B) Fails to provide for the operation ofthe source (including associated air 

pollution control and monitoring equipment) during a startup, shutdown, or 

malfunction event in a manner consistent with the general duty to minimize 

emissions established by 40 C.F.R. § 63.6(e)(1)(f); 

(C) Does not provide adequate procedures for conecting malfunctioning process 

and/or air pollution control and monitoring equipment as quickly as practicable; 

or 

(D) Includes an event that does not meet the definition of startup, shutdown, or 

malfunction listed in 40 C.F.R. § 63.2. 

(v) The Permittee may periodically revise the startup, shutdown, and malfunction 

plan for the affected source as necessary to satisfy the requirements of 40 C.F.R. 

Ppart 63 or to reflect changes in equipment or procedures at the affected source. 

The Permittee may make such revisions to the startup, shutdown, and malfunction 

plan without prior approval by the Administrator or the permitting authority. 

However, the Permittee must report each revision to the startup, shutdown, and 

malfunction plan in the semiannual report required by §63.10(d)(5). _If the 

startup, shutdown, and malfunction plan fails to address or inadequately addresses 

an event that meets the characteristics of a malfunction but was not included in 

the startup, shutdown, and malfunction plan at the time the Pennittee developed 

the plan, the Permittee must revise the startup, shutdown, and malfunction plan 

within 45 days after the event to include detailed procedures for operating and 

maintaining the source during similar malfunction events, and a program of 

corrective action for similar malfunctions of process or air pollution control and 

VES 001528 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 17 of 134 

monitoring equipment. _In the event that the Permittee makes any revision to the 

startup, shutdown, and malfunction plan which alters the scope ofthe activities at 

the source which are deemed to be a startup, shutdown, or malfunction, or 

otherwise modifies the applicability of any emission limit, work practice 

requirement, or other requirement in a standard established under 40 C.F.R. pPart 

63, the revised plan shall not take effect until after the Permittee has provided a 

written notice describing the revision to the Administrator. 

(vi) Any revisions made to the startup, shutdown, and malfunction plan in accordance 

with the procedures established by this part shall not be deemed to constitute 

revisions to this permit, and the elements of the startup, shutdown, and 

malfunction plan shall not be considered an applicable requirement as defined in 

40 C.F.R. £§ 70.2 and 40 C.F.R. § 71.2. .[40 C.F.R. § 63.6(e)(3)(ix)] 

(vii) The procedures specified in the startup, shutdown, and malfunction plan do not 

fall within the permit shield provided in section 4.0(U) of this permit. 

(b)_ The Permittee is subjectto the following provisions of 40 C.F.R. § 63.1206(c)(2) 

and (3): 

(i) The Permittee must identify in the startup, shutdown, and malfunction plan a 

projected oxygen correction factor, based on normal operations, to use during 

periods of startup and shutdown. [40 C.F.R. § 63.1206(c)(2)(iii)] 

(ii) The Permittee must record the startup, shutdown, and malfunction plan in the 

operating record. [40 C.F.R. § 63.1206(c)(2)(iv)] 

(iii) _Operating under the startup, shutdown, and malfunction plan [40 C.F.R. 

"§ 63.1206(c)(2)(v)(A)]: 

(A) Compliance with automatic waste feed cutoff (AWFCO ) requirements during 

malfunctions: 

(1) During malfunctions, the automatic waste feed cutoff requirements of 

section 2.1(C)(7) o f the permit continue to apply, except for section 

2.1(C)(7)(e). J f there is an exceedance of a 40 C.F.R. Part 63, Subpart 

EEE , emission standard monitored by a CEM S or COMs S or operating 

limit specified under 40 C.F.R. § 63.1209, the automatic waste feed cutoff 

system must immediately and automatically cutoff the hazardous waste 

feed, except as provided by section 2.1(C)(7)(f) ofthe permit. J f the 

malfunction itself prevents immediate and automatic cutoff of the 

hazardous waste feed, the Pennittee must cease feeding hazardous waste 

as quickly as possible. 

(2) Although the automatic waste feed cutoff requirements continue to apply 

during a malfunction, an exceedance of an emission standard monitored 

VES 001529 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 18 of 134 

by a CEM S or COM S or operating limit specified under section 63.1209 

is not a violation of 40 C.F.R. Ppart 63, Ssubpart EE E if the source 

continues to operate in accordance with section 63.6(e)(1)]. _[40 C.F.R. 

§ 63.1206(c)(2)(v)(A)(2)] 

(3) Excessive exceedances during malfunctions. _For each set of 10 

exceedances of an emission standard or operating requirement while 

hazardous waste remains in the combustion chamber (i.e., when the 

hazardous waste residence time has not transpired since the hazardous 

waste feed was cutoff) during a 60-day block period, the Permittee must: 

• Within 45 days of the 10th exceedance, complete an investigation of 

the cause of each exceedance and evaluation of approaches to 

minimize the frequency, duration, and severity o f each exceedance, 

and revise the startup, shutdown, and malfunction plan as warranted 

by the evaluation to minimize the frequency, duration, and severity of 

each exceedance; and 

• Record the results of the investigation and evaluation in the operating 

record, and include a summary of the investigation and evaluation, 

and any changes to the startup, shutdown, and malfunction plan, in 

the excess emissions report required under section 2.1(D) ofthe 

permit and 40 C.F.R. § 63.10(e)(3). [40 C.F.R. 

§ 63.1206(c)(2)(v)(A)] 

(B) Compliance with AWFC O requirements when burning hazardous waste 

during startup and shutdown [40 C.F.R. § 1206(c)(2)(v)(B)]: 

(1) .If the Permittee feeds hazardous waste during startup or shutdown, the 

Permittee must include waste feed restrictions (e.g., type and quantity), 

and other appropriate operating conditions and limits in the startup, 

shutdown, and malfunction plan. [40 C.F.R. § 63.1206(c)(2)(v)(B)(l)] 

(2) _The Permittee must interlock the operating limits established under section 

2.1(C)(6)(iii)(B)(l), above, with the automatic waste feed cutoff system 

required under section 2.1 (C)(7), except for section 2.1(C)(7)(e). 

[40 C.F.R. § 63.1206(c)(2)(v)(B)(2)] 

(3) _When feeding hazardous waste during startup or shutdown, the automatic 

waste feed cutoff system must immediately and automatically cutoff the 

hazardous waste feed if the Permittee exceeds the operating limits 

established under section 2.1(C)(6)(b)(iii)(B)(l) of this permit, except as 

provided by section 2.1(C)(7). [40 C.F.R. § 63.1206(c)(2)(v)(B)(3)] 

(4) Although the automatic waste feed cutoff requirements of 40 C.F.R. 

§ 63.1206 (c)(2)(v)(B)(4) apply during startup and shutdown, an 

VES 001530 
[ Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 19 of 134 

exceedance of an emission standard or operating limit is not a violation of 

this sSubpart EE E if the Permittee operates in accordance with 40 C.F.R. § 

63.6(e)(1). [40 C.F.R. § 63.1206(c)(2)(v)(B)(4)] 

(c)_The Permittee shall not cause or allow the continued operation of an emission source 

during malfunction or breakdown o f the emission source or related air pollution control 

equipment if such operation would cause a violation of the standards or limitations set 

forth in Subchapter c: Emission Standards and Limitations for Stationary Sources. _The 

Permittee shall not cause or allow violation of the standards or limitations set forth in 

Subchapter c: Emission Standards and Limitations for Stationary Sources during startup. 

[35 IA C 201.149] 

7. Automatic waste feed cutoff (AWFCO) .[40 C.F.R. § 63.1206(c)(3)] 

(a) The Permittee must operate the hazardous waste combustor with a functioning 

AWFC O system that immediately and automatically cuts off the hazardous waste feed, 

except as provided by section 2.1(C)(7)(f): 

(i) When any ofthe following are exceeded: Operating parameter limits specified 

under section 2.1(D) of this permit and 40 C.F.R. § 63.1209; an emission standard 

monitored by a CEMS ; and the allowable combustion chamber pressure; 

(ii) When the span value of any CM S detector, except a CEMS , is met or exceeded; 

(iii) _Upon malfunction of a CM S monitoring an operating parameter limit specified 

under section 2.1(D) of this permit and 40 C.F.R. § 63.1209 or an emission level; 

or 

(iv) When any component ofthe AWFC O system fails. [40 C.F.R. § 63.1206(c)3)(i)] 

(b) Ducting of combustion gases. .During an AWFCO , the Permittee must continue to 

duct combustion gasses to the air pollution control system while hazardous waste remains 

in the combustion chamber (i.e., if the hazardous waste residence time has not transpired 

since the hazardous waste feed cutoff system was activated). [40 C.F.R. 

§ 63.1206(c)(3)(h)] 

(c) Restarting waste feed. .The Permittee must continue to monitor during the cutoff the 

operating parameters for which limits are established under section 2.1(D) o f this permit 

and 40 C.F.R. § 63.1209 and the emissions required under that section to be monitored by 

a CEMS , and must not restart the hazardous waste feed until the operating parameters 

and emission levels are within the specified limits. [40 C.F.R. § 63.1206(c)(3)(iii)] 

(d) Failure ofthe AWFC O system. J f the AWFC O system fails to automatically and 

immediately cut off the flow of hazardous waste upon exceedance of a parameter 

required to be interlocked with the AWFC O system under section 2.1(C)(7)(a), the 

Permittee has failed to comply with the AWFC O requirements of section 2.1(C)(7). J f 

VES 001531 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 20 of 134 

an equipment or other failure prevents immediate and automatic cutoff of the hazardous 

waste feed, however, the Permittee must cease feeding hazardous waste as quickly as 

possible. "{40 C.F.R. § 63.1206(c)(3)(iv)] 

(e) Corrective measures. If, after any AWFCO , there is an exceedance of an emission 

standard or operating requirement, irrespective of whether the exceedance occurred while 

hazardous waste remained in the combustion chamber (i.e., whether the hazardous waste 

residence time has transpired since the hazardous waste feed cutoff system was 

activated), the Permittee must investigate the cause of the AWFCO , take appropriate 

corrective measures to minimize future AWFCOs, and record the findings and corrective 

measures in the operating record. [40 C.F.R. § 63.1206(c)(3)(v)] 

(f) Ramping down waste feed. ^ J40 C.F.R. § 63.1206(c)(3)(viii)] 

(i) The Permittee may ramp down the waste feedrate of pumpable hazardous waste 

over a period not to exceed 1 minute, except as provided by section 

2.1(C)(7)(f)(ii) of this permit, below. If the Permittee elects to ramp down the 

waste feed, the Permittee must document ramp down procedures in the operating 

and maintenance plan. The procedures must specify that the ramp down begins 

immediately upon initiation of automatic waste feed cutoff and the procedures 

must prescribe a bona fide ramping down. If an emission standard or operating 

limit is exceeded during the ramp down, the Permittee hasw failed to comply 

with the emission standards or operating requirements of tbis-40 C.F.R. Part 63, 

sSubpart EHL 

(ii) If the automatic waste feed cutoff is triggered by an exceedance of any of the 

following operating limits, the Permittee may not ramp down the waste feed 

cutoff: Minimum combustion chamber temperature, maximum hazardous waste 

feedrate, or any hazardous waste firing system operating limits that may be 

established for its combustor. 

(g) —Complianc e with the requirements of the AWFC O in Subpart EE E will assure 

compliance with the requirements for a waste cutoff interlock system required by 

Construction pennit 83120053.^ [40 C.F.R. § 71.6(a)(3)(i)(A)] 

8. Emergency safety vent fiSV-openings. J40 C.F.R. § 63.1206(c)(4)] 

(a) Failure to meet standards. J f an emergency safety vent (ESV) opens when hazardous 

waste remains in the combustion chamber (i.e., when the hazardous waste residence time 

has not expired) during an event other than a malfunction as defined in the startup, 

shutdown, and malfunction plan such that combustion gases are not treated as during the 

most recent comprehensive perfonnance test (e.g., if the combustion gas by-passes any 

emission control device that was operating during the performance test), the Permittee 

must document in the operating record whether the source remained in compliance with 

the emission standards of Subpart EE E considering emissions during the ES V opening 

event. [40 C.F.R. § 63.1206(c)(4)(i)] 

VES 001532 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 21 of 134 

(b) ES V operating plan. [40 C.F.R. § 63.1206(c)(c)(4)(ii)] 

(i) The Pennittee must develop an ES V operating plan, comply with the operating 

plan, and keep the plan in the operating record. 

(ii) The ES V operating plan must provide detailed procedures for rapidly stopping the 

waste feed, shutting down the combustor, and, if feasible, maintaining 

temperature and negative pressure in the combustion chamber during the 

hazardous waste residence time. The plan must include calculations, information 

and data documenting the effectiveness of the plan's procedures for ensuring that 

combustion chamber temperature and negative pressure are maintained as is 

reasonably feasible. 

(c) Corrective measures. After any ES V opening that results in a failure to meet the 

emission standards as defined in section 2.1(C)(8)(a) of this permit, the Permittee must 

investigate the cause ofthe ES V opening, take appropriate conective measures to 

minimize such future ES V openings, and record the findings and corrective measures in 

the operating record. [40 C.F.R. § 63.1206(c)(4)(iii)] 

9. Combustion system leaks, J40 C.F.R. 63.1206(c)(5)] 

(a) Combustion system leaks of hazardous air pollutants must be controlled by 

maintaining the maximum combustion zone pressure lower than ambient pressure using 

an instantaneous monitor; [40 C.F.R. § 63.1206(c)(5)(i)(B)] and 

(b) The Permittee must specify in the performance test work plan and Hmfmihim-of 

ComplianceNOC the method that it will use to control combustion system leaks. 

Because the Permittee controls combustion system leaks by maintaining the combustion 

zone pressure lower than ambient pressure using an instantaneous monitor, tlie Pennittee 

must also specify in the performance test work plan and Notification of-ComplianceNQC 

the monitoring and recording frequency of the pressure monitor, and specify how the 

monitoring approach is integrated into the automatic waste feed cutoff system. 

[40 C.F.R. § 63.1206(c)(5)(h)] 

10. Operator training and certification, [40 C.F.R. § 63.1206(c)(6)] 

(a) The Permittee must establish training programs for all categories of personnel whose 

activities may reasonably be expected to directly affect emissions of hazardous air 

pollutants from the source. Such persons include, but are not limited to, chief facility 

operators, control room operators, continuous monitoring system operators, persons that 

sample and analyze feedstreams, persons that manage and charge feedstreams to the 

combustor, persons that operate emission control devices, and ash and waste handlers. 

Each training program shall be of a technical level commensurate with the person's job 

duties specified in the training manual. Each commensurate training program shall 

require an examination to be administered by the instructor at the end of the training 

VES 001533 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 22 of 134 

course. .Passing of this test shall be deemed the "certification" for personnel, except that, 

for control room operators, the training and certification program shall be as specified in 

section 2.1(C)(10)(c) through (e) of this permit. [40 C.F.R. § 63.1206(c)(6)(i)] 

(b) The Permittee must ensure that the source is operated and maintained at all times by 

persons who are trained and certified to perform these and any other duties that may 

affect emissions of hazardous air pollutants. . A certified control room operator must be 

on duty at the site at all times the source is in operation. [40 C.F.R. § 63.1206(c)(6)(ii)] 

(c) Hazardous waste incinerator control room operators must: 

(i) Be trained and certified under a site-specific, source-developed and implemented 

program that meets the requirements of section 2.1(C)(10)(d); or 

(ii) _Be trained under the requirements of, and certified under, one of the following 

American Society of Mechanical Engineers (ASME) standards: QHO-1-1994, 

QHO-1 a-1996, or QHO-1 -2004 (Standard for the Qualification and Certification 

of Hazardous Waste Incinerator Operators).. If the Permittee elects to use the 

ASM E program: 

(A) Control room operators must, prior to the compliance date, achieve 

provisional certification, and must submit an application to ASM E and be 

scheduled for the full certification exam. Within 1 year o f the compliance date, 

control room operators must achieve full certification; 

(B) New operators and operators of new sources must, before assuming their 

duties, achieve provisional certification, and must submit an application to 

ASME , and be scheduled for the full certification exam. Within 1 year of 

assuming their duties, these operators must achieve full certification; or 

(iii) _Be trained and certified under a State program. [40 C.F.R. § 63.1206(c)(6)(iii)] 

(d) Site-specific, source developed and implemented training programs for control room 

operators must include the following elements: 

(i) Training on the following subjects: 

(A) Environmental concerns, including types of emissions; 

(B) Basic combustion principles, including products of combustion; 

(C) Operation of the specific type of combustor used by the operator, including 

proper startup, waste firing, and shutdown procedures; 

(D) Combustion controls and continuous monitoring systems; 

VES 001534 
I Veolia Environmental Services Page: 23 of 134 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

(E) Operation of air pollution control equipment and factors affecting 

performance; 

(F) Inspection and maintenance of the combustor, continuous monitoring systems, 

and air pollution control devices; 

(G) Actions to correct malfunctions or conditions that may lead to malfunction; 

(H) Residue characteristics and handling procedures; and 

(I) Applicable fPederal, state, and local regulations, including Occupational 

Safety and Health Administration workplace standards; and 

(ii) _An examination designed and administered by the instructor; and 

(iii) Written material covering the training course topics that may serve as reference 

material following completion of the course. [40 C.F.R. § 63.1206(c)(6)(v)] 

(e) To maintain control room operator qualification under a site-specific, source 

developed and implemented training program as provided by section 10(d), control room 

operators must complete an annual review or refresher course covering, at a minimum, 

the following topics: 

(i) Update of regulations; 

(ii) _Combustor operation, including startup and shutdown procedures, waste firing, 

and residue handling; 

(iii) Jnspection and maintenance; 

(iv) Responses to malfunctions or conditions that may lead to malfunction; and 

(v) Operating problems encountered by the operator. [40 C.F.R. § 63.1206(c)(6)(vi)] 

(f) The Pennittee must record the operator training and certification program in the 

operating record. [40 C.F.R. § 63.1206(c)(6)(vii)] 

11. Operation and maintenance plan [40 C.F.R. § 63.1206(c)(7)] 

(a) The Permittee must prepare and at all times operate according to an operation and 

maintenance plan that describes in detail procedures for operation, inspection, 

maintenance, and conective measures for all components of the combustor, including 

associated pollution control equipment, that could affect emissions of regulated 

hazardous air pollutants. [40 C.F.R. § 63.1206(c)(7)(i)] 

VES 001535 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 24 of 134 

(b) The plan must prescribe how the source will operate and maintain the combustor in a 

manner consistent with good air pollution control practices for minimizing emissions at 

least to the levels achieved during the comprehensive performance test. [40 C.F.R. 

§ 63.1206(c)(7)(h)] 

(c) This plan ensures compliance with the operation and maintenance requirements of 40 

C.F.R. § 63.6(e) and minimizes emissions of pollutants, automatic waste feed cutoffs, and 

malfunctions. [40 C.F.R. § 63.1206(c)(7)(iii)] 

(d) The Permittee must record the plan i n the operating record. [40 C.F.R. 

§ 63.1206(c)(7)(iv)] 

12. Compliance with 40 C.F.R. Ppart 63, Subpart EE E will assume compliance with the 

requirements for a Waste Feed cutoff interlock system and Sensors from Construction 

permits 87100024, 88010001, and 83120053. .[40 C.F.R. § 71.6(a)(3)(i)(A)] 

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)] 

1. Continuous emissions monitoring systems (CEMS) and continuous opacity monitoring 

systems (COMS) [40 C.F.R. § 63.1209(a)]: 

(a) The Permittee must use either a carbon monoxide or hydrocarbon CEM S to 

demonstrate any-and monitor compliance with the carbon monoxide or hydrocarbon 

standard. The Permittee must also use an oxygen CEM S to continuously correct the 

carbon monoxide to 7 percent oxygen. 

(b) After such time as the EP A promulgates all performance specifications and 

operational requirements applicable to P M CEMS , the Permittee must install, calibrate, 

maintain, and operate a particulate matter CEM S to demonstrate and monitor compliance 

with the particulate matter standards under this permit. 

(c) Performance specifications. The Permittee must install, calibrate, maintain, and 

continuously operate the CEM S and COM S in compliance with the quality assurance 

procedures provided in the appendix to 40 C.F.R. part-Part 63, Subpart EE E and 

Performance Specifications 1 (opacity), 4B (carbon monoxide and oxygen), and 8A 

(hydrocarbons) in Appendix B to 40 C.F.R. Part 60. 

(d) Carbon monoxide readings exceeding the span should be recorded in accordance with 

the following requirements of 40 C.F.R. § 63.1209(a)(3): 

(i) Except as provided by 40 C.F.R. § 63.1209(a)(3)(ii), if a carbon monoxide CEM S 

detects a response that results in a 1-minute average at or above the 3,000 ppmv 

span level required by Performance Specification 4B in Aappendix B to 40 C.F.R. 

pPart 60, the Permittee must record the 1-minute average as 10,000 ppmv. .The 

Permittee must use the 1-minute 10,000 ppmv value for calculating the hourly 

rolling average carbon monoxide level. 

VES 001536 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 25 of 134 

(ii) _Carbon monoxide CEM S that use a span value of 10,000 ppmv when 1-minute 

carbon monoxide levels are equal to or exceed 3,000 ppmv are not subject to 40 

C.F.R. § 63.1209(a)(3)(i). Carbon monoxide CEM S that use a span value of 

10,000 are subject to the same CEM S performance and equipment specifications 

when operating in the range of 3,000 ppmv to 10,000 ppmv that are provided by 

Performance Specification 4B for other carbon monoxide CEMS , except: 

(A) Calibration drift must be less than 300 ppmv; and 

(B) Calibration error must be less than 500 ppmv. 

(e) Hydrocarbon readings exceeding the span. 

(i) _ Except as provided by 40 C.F.R. § 63.1209(a)(4)(ii), if a hydrocarbon 

CEM S detects a response that results in a 1-minute average at or above the 100 

ppmv span level required by Performance Specification 8 A in Aappendix B to 40 

C.F.R. Ppart 60, the Permittee must record the 1-minute average as 500 ppmv. 

The Permittee must use the 1-minute 500 ppmv value for calculating the hourly 

rolling average H C level. 

(ii) _-Hydrocarbon CEM S that use a span value of 500 ppmv when 1-minute 

hydrocarbon levels are equal to or exceed 100 ppmv are not subject to 40 C.F.R. 

§ 63.1209(a)(4)(f). .Hydrocarbon CEM S that use a span value of 500 ppmv are 

subject to the same CEM S performance and equipment specifications when 

operating in the range of 100 ppmv to 500 ppmv that are provided by 

Performance Specification 8A in Appendix B to 40 C.F.R. Part 60 for other 

hydrocarbon CEMS , except: 

(A) Tlie zero and high-level calibration gas must have a hydrocarbon level of 

between 0 and 100 ppmv, and between 250 and 450 ppmv, respectively; 

(B) The strip chart recorder, computer, or digital recorder must be capable of 

recording all readings within the CE M measurement range and must have a 

resolution of 2.5 ppmv; 

(C) The CEM S calibration must not differ by more than ±15 ppmv after each 24-

hour period of the seven day test at both zero and high levels; 

(D) The calibration error must be no greater than 25 ppmv; and 

(E) The zero level, mid-level, and high level calibration gas used to detennine 

calibration enor must have a hydrocarbon level of 0-200 ppmv, 150-200 ppmv, 

and 350^100 ppmv, respectively. 

VES 001537 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 26 of 134 

(f) Petitions to use CEM S for other standards. The Permittee may petition EP A to use 

CEM S for compliance monitoring for particulate matter, mercury, semi-volatile metals, 

low volatile metals, and hydrogen chloride and chlorine gas under 40 C.F.R. § 63.8(f), in 

lieu o f compliance with the corresponding operating parameter limits. 

(g) Calculation of rolling averages should be done in accordance with the following 

requirements of 40 C.F.R. § 63.1209(a)(6): 

(i) Calculation of rolling averages upon intermittent operations. .The Permittee must 

ignore periods of time when 1-minute values are not available for calculating the 

hourly rolling average. When 1-minute values become available again, the first 

1 -minute value is added to the previous 59 values to calculate the hourly rolling 

average. 

(ii) Calculation of rolling averages when the hazardous waste feed is cutoff. 

(A) Except as provided by 40 C.F.R. § 63.1209(a)(6)(iii)(B), the Permittee must 

continue monitoring carbon monoxide when the hazardous waste feed is cutoff if 

the source is operating. The Permittee must not resume feeding hazardous waste 

if the emission levels exceed the standard. 

(B) The Pennittee is not subject to the CEM S requirements of 40 C.F.R. Ppart 63, 

Ssubpart EE E during periods of time the Pennittee meets the requirements of 40 

C.F.R. § 63.1206(b)(1)(h) (compliance with emissions standards for 

nonhazardous waste burning sources when the Permittee is not burning hazardous 

waste). 

(h) Operating parameter limits for hydrocarbons. If the Permittee elects to comply with 

the carbon monoxide and hydrocarbon emission standard by continuously monitoring 

carbon monoxide with a CEMS , the Pennittee must demonstrate that hydrocarbon 

emissions during the comprehensive performance test do not exceed the hydrocarbon 

emissions standard. In addition, the limits the Permittee establishes on the destructionand removal efficiency (DRE) operating parameters required under 40 C.F.R. 

§ 63.1209(j) also must ensure that the Pennittee maintains compliance with the 

hydrocarbon emission standard. If the Permittee does not conduct the hydrocarbon 

demonstration and DR E tests concunently, the Permittee must establish separate 

operating parameter limits under 40 C.F.R. § 63.1209(f) based on each test, and the more 

restrictive of the operating parameter limits applies. 

mMulli-metalsCEMS . 140 C.F.R. § 71.6(a)(3)(i)(BY| 

The Pennittee shall install, calibrate, maintain and operate an x-rav fluorescence rnui 

metals ("EMS on Incineration Unit #3 within 1X0 davs after tl us pennit condition 

becomes effective, unless the Administrator determines that a time extension is warn 

based on the Permittee's documentation in writing of factors 1 beyond its control that 

he Permittee must also 

VES 001538 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 27 of 134 

to 7 percent oxygen. 

(pp JJhcjmuJtFrr^^ 

Method (OTM) 16, Perfomiance Specification Y Y (Specifications and 'Test 

Procedures for X-ray Fluorescence Based Multi-Metals Continuous Emission 

Monitoring Systems at Stationary Sources) and the on-going quality control and 

quality assurance procedures set forth in OTM 27), Procedure Jity Assurance 

Requirements for X-Ray-Fluorescence Based Multi-Metals Continuous Emission 

Monitoring Systems at Stationary Sources) and subsequent revisions, 

(ii) At a. niiniinu.no. the rotiltoroetals CEM S shall measure and report, the total 

concentrations (regardless of speciation) ofthe following metals in both their vapor 

and solid forms in the exhaust stream: arsenic, beryllium, cadmium, chromium., 

lead and mercury. If the Permittee installs a multi-metals CEM S that is incapable 

ol* measuring any ofthe specified metals, the Permittee must determine the default 

value for that metal's ernissions using the highest measured concentration of that. 

metal in any feedstream burned bv the Pennittee in the last live years and the lowest 

system removal efficiency with respect to that metal, as obtained during any 

comprehensive perfonnance test performed by the Permittee over that same period. 

The Permittee must assume that all wastes fed to the incinerator contain the affected 

metal at the default concentration. 

(iii) For a period of no less than twelve (I2> consecutive months, the Pennittee shall 

operate the multi-metals CEM S at all times except during periods of monitor 

downtime due to calibration, quality assurance checks or scheduled maintenance. 

OjpsefaiioipTO^ 

each successive 15-minute period. In order to calculate a valid one-hour block 

average, valid results must be available for at least three- ofthe four 15-minute 

(iv) During the period when the multi-mclals OEMS is installed and operating, the 

Permittee shall determine compliance with the applicable ernissions limits for 

Incineration Unit 03 using a 12-hour rolling average of OEM S data, calculated each 

IliTiMEJiSjIitLJFV 

iyj_ During periods when the multi-metals OHMS is malfunctioning, or during periods 

of monitor downtime due to calibration., quality assuran.ee checks or scheduled 

maintenance, the Permittee shall use data from feedstream analysis, performance 

tests and/or other CMSs, as provided in thus permit, to demonstrate compliance with 

the applicable emissions limits provided that the monitor downtime lasts at least 

three ofthe four 15-minute cycles in each hour needed to calculated a valid onehour block average. 

£vi j [4urij||gr jhe 

.j • j l _„ b i a- _

 1 !

- 0 

m -i •< • i- u . • i. a i . i i, i a. . . " m, ". . i .(,... . , i . 

VES 001539 
Veolia Environmental Services Page: 28 of 134 

PermitNo.: V4L-1716300103-08-01 

Expires: October 12,2013 

in condn f •_ ' )(2). 

A i iUn nrtA r«f I "> rru-.rU t, twmrw t Uiirit-i.» twhfft i th,» miilti tvwvtnlc CRy ? »»..»« 

peraieu. tlie Permittee mav pctilio 

...iL(lfaJJ2fW 

wutonng for mercury. L V M apdS 

(viii) If operation of the multi-metals CEM S during the 12-month period, in conjunction 

with feedstream analysts or other relevant data, reveals that any of the feedrate 

limits included in this permit must be made more stringent in order to assure 

compliance with the applicable emissions limits,.EPA will reopen this pennit, 

pursuant to 40 C.F.R. S 71.7(f). to either revise the affected feedrate limits or 

E'ilMFfsljHilTM 

Li. - . J ' -

 1 1

 _ 'I _ J 1 . ' L _!-'•-._ >

 s

 _ _ _!_ l ± i' _ 

_ '< 4 a p -r - p , , c i_ m I . _ 1_ <p 

"i. i's ' i , II i iii i - i ' . II _ v i 

nee.withj.he apphcable emissions limits, the rerrnitftee may petition 

arator to utilize the results of historical comprehensive perfonnance 

• 1 c >> I. ! I " Ja. . - .-..[... . _.. .s .. '• 0 

ruid. be assured at the higher teedratc limits regaroJess oi. thu 

_' • ; p •_ eg; _

 1 _i . _ _ J _•> _iiL„ P_. " • L_ 

iministrator to approve a petition for revised feedrate limits 

' pjai p rj ' ' p j ; ^n j_ . _j g 

section 2.1(E) oi this pennit. the Permittee she 

yi i " 

2. Jdhpe JJ!4gpur ja^ 

feedstream analyses conducted during the same period. 

3. Sample calculations, equations or other data used by Veolia to convert CEM S 

and feedrate data. 

4. ' * ' • )> r P ' • •• i. . ..... . I I , u n ; ,, 

i up _p_ "u ^ 2_~" Li . 12 

VES 001540 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 29 of 134 

2. Other continuous monitoring systems (CMS) [40 C.F.R. § 63.1209(b)]: 

(a) The Permittee must use CM S (e.g., thermocouples, pressure transducers, flow meters) 

to document compliance with the applicable operating parameter limits under § 63.1209. 

(b) Except as specified in 40 C.F.R. § 63.1209(b)(2)(i) and (ii), the Permittee must install 

and operate continuous monitoring systems other than CEM S in conformance with 40 

C.F.R. § 63.8(c)(3) that requires, at a minimum, to comply with the manufacturer's 

written specifications or recommendations for installation, operation, and calibration of 

the system: 

(i) Calibration of thermocouples and pyrometers. The calibration of thermocouples 

must be verified at a frequency and in a manner consistent with manufacturer 

specifications, but no less frequent than once per year. The Permittee must 

operate and maintain optical pyrometers in accordance with manufacturer 

specifications unless otherwise approved by the Administrator. The Permittee 

must calibrate optical pyrometers in accordance with the frequency and 

procedures recommended by the manufacturer, but no less frequent than once per 

year, unless otherwise approved by the Administrator. 

(ii) Accuracy and calibration of weight measurement devices for activated carbon 

injection systems. ..The Permittee operates a carbon injection system, the accuracy 

of the weight measurement device must be ± 1 percent ofthe weight being 

measured. The calibration ofthe device must be verified at least once each 

calendar quarter at a frequency of approximately 120 days. 

(c) A CM S must sample the regulated parameter without interruption, evaluate the 

detector response at least once each 15 seconds, and compute and record the average 

values at least every 60 seconds. 

(d) The span ofthe non-CEMS CM S detector must not be exceeded. TThe Pennittee must 

interlock the span limits into the automatic waste feed cutoff system required by 40 

C.F.R. § 63.1206(c)(3). 

(e) Calculation of rolling averages. 

(i) Calculation of rolling averages upon intennittent operations. The Permittee must 

ignore periods of time when 1-minute values are not available when calculating 

rolling averages. AVhen 1-minute values become available again, the first 

1-minute value is added to the previous 1-minute values to calculate rolling 

averages. 

VES 001541 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 30 of 134 

(ii) _Calculation of rolling averages when the hazardous waste feed is cutoff. 

(A) Except as provided by 40 C.F.R. § 63.1209 (b)(5)(iii)(B), the Pennittee must 

continue monitoring operating parameter limits with a CM S when the hazardous 

waste feed is cutoff if the source is operating. _The Permittee must not resume 

feeding hazardous waste if an operating parameter exceeds its limit. 

(B) The Permittee is not subject to the CM S requirements during periods of time 

the Permittee meets the requirements of 40 C.F.R. § 63.1206(b)(l)(ii) 

(compliance with emissions standards for nonhazardous waste burning sources 

when the Permittee is not burning hazardous waste). 

3. Bag leak detection system requirements^ [40 C.F.R. § 63.1206(c)(8)] 

The Pennittee must continuously operate a bag leak detection system under the following 

requirements: 

(a) A bag leak detection system that meets the specifications and requirements of 40 

C.F.R. § 63.1206(c)(8)(h), and the Permittee must comply with the conective measures 

and notification requirements of § 63.1206(c)(8)(iii) and (iv). 

(b) Bag leak detection system specification and requirements: 

(i) The bag leak detection system must be certified by the manufacturer to be capable 

of continuously detecting and recording particulate matter emissions at 

concentrations of 1.0 milligram per actual cubic meter unless the Permittee 

demonstrates, under 40 C.F.R. § 63.1209(g)(1), that a higher detection limit 

would routinely detect particulate matter loadings during normal operations; 

(ii) The bag leak detection system shall provide output of relative or absolute 

particulate matter loadings; 

(iii) The bag leak detection system shall be equipped with an alarm system that wil l 

sound an audible alarm when an increase in relative particulate loadings is 

detected over a preset level; 

(iv) The bag leak detection system shall be installed and operated in a manner 

consistent with available written guidance from the U.S. EP A or, in the absence of 

such written guidance, the manufacturer's written specifications and 

recommendations for installation, operation, and adjustment of the system; 

(v) The initial adjustment ofthe system shall, at a minimum, consist of establishing 

the baseline output by adjusting the sensitivity (range) and the averaging period of 

the device, and establishing the alarm set points and the alarm delay time; 

VES 001542 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 31 of 134 

(vi) Following initial adjustment, the Permittee must not adjust the sensitivity or 

range, averaging period, alarm set points, or alarm delay time, except as detailed 

in the operation and maintenance plan required under 40 C.F.R. § 63.1206(c)(7). 

The Pennittee must not increase the sensitivity by more than 100 percent or 

decrease the sensitivity by more than 50 percent over a 365-day period unless 

such adjustment follows a complete baghouse inspection which demonstrates the 

baghouse is in good operating condition; and 

(vii) _The bag leak detector shall be installed downstream ofthe baghouse and upstream 

of any wet acid gas scrubber. _Where multiple detectors are required, the system's 

instrumentation and alarm system may be shared among the detectors. 

(c) Bag leak detection system conective measures requirements. /The operating and 

maintenance plan required by 40 C.F.R. § 63.1206(c)(7) must include a conective 

measures plan that specifies the procedures the Permittee will follow in the case of a bag 

leak detection system alarm. The conective measures plan must include, at a minimum, 

the procedures used to detennine and record the time and cause of the alann as well as 

the conective measures taken to conect the control device malfunction or minimize 

emissions as specified below. _Failure to initiate the corrective measures required by this 

paragraph is failure to ensure compliance with the emission standards in Subpart EEE . 

(i) The Permittee must initiate the procedures used to determine the cause of the 

alann within 30 minutes of the time the alann first sounds; and 

(ii) The Permittee must alleviate the cause ofthe alarm by taking the necessary 

conective measure(s) which may include, but are not to be limited to, the 

following: 

(A) Inspecting the baghouse for air leaks, torn or broken filter elements, or any 

other malfunction that may cause an increase in emissions; 

(B) Sealing off defective bags or filter media; 

(C) Replacing defective bags or filter media, or otherwise repairing the control 

device; 

(D) Sealing off a defective baghouse compartment; 

(E) Cleaning the bag leak detection system probe, or otherwise repairing the bag 

leak detection system; or 

(F) Shutting down the combustor. 

4. Analysis of feedstreams [40 C.F.R. § 63.1209(c)]: 

VES 001543 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 32 of 134 

(a) General. Prior to feeding the material, the Permittee must obtain an analysis of each 

feedstream that is sufficient to document compliance with the applicable feedrate limits 

provided by 40 C.F.R. § 63.1209. 

(b) Feedstream analysis plan. The Permittee must develop and implement a feedstream 

analysis plan and record it in the operating record. The plan must specify at a minimum: 

(i) The parameters for which the Permittee will analyze each feedstream to ensure 

compliance with the operating parameter limits of this section; 

(ii) Whether the Permittee will obtain the analysis by performing sampling and 

analysis or by other methods, such as using analytical information obtained from 

others or using other published or documented data or information; 

(iii) How the Permittee will use the analysis to document compliance with applicable 

feedrate limits (e.g., if the Permittee blends hazardous wastes and obtains analyses 

of the wastes prior to blending but not ofthe blended, as-fired, waste, the plan 

must describe how the Permittee will determine the pertinent parameters o f the 

blended waste); 

(iv) The test methods which the Permittee will use to obtain the analyses; 

(v) The sampling method which the Pennittee will use to obtain a representative 

sample of each feedstream to be analyzed using sampling methods described in 

Appendix IX to 40 C.F.R. Ppart 266, or an equivalent method; and 

(vi) The frequency with which the Pennittee will review or repeat the initial analysis 

of the feedstream to ensure that the analysis is accurate and up to date. 

(c) Review and approval of analysis plan. The Pennittee must submit the feedstream 

analysis plan to the pennitting authority for review and approval, if requested. 

(d) Compliance with feedrate limits. 

(1) To comply with the applicable feedrate limits of this section, the Permittee must 

monitor and record feedrates as follows: 

(i) Determine and record the value of the parameter for each feedstream by sampling 

and analysis or other method; 

(ii) _Determine and record the mass or volume flowrate of each feedstream by a CMS . 

If the Pennittee detennines flowrate of a feedstream by volume, the Pennittee 

must detennine and record the density of the feedstream by sampling and analysis 

(unless the Permittee reports the constituent concentration in units of weight per 

unit volume (e.g., mg/l)); and 

VES 001544 
I Veolia Environmental Sen/ices Page: 33 of 134 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

(iii) Calculate and record the mass feedrate of the parameter per unit time. 

(2) Analysis procedures for mercury, LV M and SVM . 140 C.F.R. $ 63.1209; 40 C.F.R. $ 

iiMmimm 

Notwithstanding the requirement for a feedstream analysis plan, as specified in condition 

2.1(D)(4)(b), the Permittee shall implement, the following procedures Few mercury. SV M 

andJ-VMp, 

(1) Pre-acceptance screening procedure. 

The Permittee shall obtain, prior to the shipment of waste to the facility, a 

representative sample of the waste for mercury. LV M and SV M analysis by the 

Pennittee using appropriate quality assurance/quality control procedures and an 

appropriate test method that are consistent with the "Test Methods for Evaluating 

Solid Waste, Physical/Chemical Methods" (SW-846). I lie Permittee shall follow 

this pre-acceptance screening sampling and analysis procedure at least once per 

year for each waste stream using appropriate quality assurance/quality control 

procedures and, appropriate test methods that are consistent with SW-846. 

(7i) Wastc acceptance provedurc. 

Idie Pennittee shall conduct, representative sampling ofeach shipment of waste 

tor mercury. LVM . and SV M within 24 hours of receipt and, shall analyze such 

samples using appropnate quality assurance/quality control procedures and m 

appropriate test, methods that are consistent with SW-846. 

(iii) Batch sampling procedure. 

" _ : • JL U u . J ' c. _ t _ ^ _ . C _i " -

otherwise altered from its shipped stare, the Permittee shall sample and analyze 

j . . j_ . m. _ y ' _ 2L ^__ h si _ ' L. _a 

test methods that are consistent with SW-846. 

(iv) Fuel procedure. 

I lie permittee shall document trie concentration ol mercury, LVM . ant 

_ i _ p _ i ^_ I_ I • _ _ i' _- _4_ i_ d_ _i_ > 

•> • p i p 2l._ l _a f — ''— he

 1 ••^•'.a^. a_ ' 

P _ _ g _ i "! _; JL j ' _ i p 

• • < • • i • •• -t a ,- - , o , - •,!,! • 

VES 001545 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 34 of 134 

(v) Treatment of detection limits for metal feedrate calculations. 

The Permittee shall determine the concentrations of arsenic, beryllium, cadmium, 

chpwntya^ 

mercury, LV M and SV M for each waste or fuel fed to each incinerator unit. 

L If the applicable metal is detected at. or above the reporting limit for that metal., 

as defined in condition 2.1 f P')(4f(dy2")(v)(3) above. in any sampling analysis 

required by condition. 2.1('P)(4)(d)(2). the metal concentration shall be equal to 

lIleLgrpmee^ 

. at or above the reporting limit, as delined in condition 2.1 (PX4)(dX2)fv.M3) 

above. 

2^Jdfj3iej ^ 

metal, as defined in. condition 2.i(D>(4K.d¥2)(vK3) above, in any sampling 

analysis required by condition 2. l(P)(4)(d)(2), and there is acceptable 

knowledgejj^^ 

the metal concentration shall be equal to one-half ofthe reporting limit, as 

defined in condition 2.1(P)(4)(dK.2).(v)(3) above, from the sampling analyses 

required by condition 2.i(D)(4)(dX2). 

3. The reporting limit shall be determined as the lowest non-zero concentration of 

the applicable metal in a minimum 5-point linear calibration study multiplied 

by tlie appropriate extraction and dilution factors. 

4. The mass of LV M in each feedstream is the algebraic sum ofthe mass of 

!LMO.hefrjt23^ 

.lecdspgea^ 

feedstream. 

(vi) Exemptions to the analysis procedures in condition 2.1 (P)(4)(d)(2h 

The following wastes that the Pennittee determines do not contain mercury. LV M and 

SVM' , consistent with this condition 2. l(P)(4)(d)(2)(vi), shall be exempt from the 

analysis procedures set loitli in condition 2.l(P)(4)(d')(2): 

jU _u. „_•_. Ja.___u •» % mi . i ._> . L^ I ._>. e.i i-j_-<.._±_ i_. 

• L" J_ U Cd nl_' ipi i _ _ _.•'.-.< i _ •_

 1

 • _ V 

identification'). For packaged chemicals, the Permittee shall obtain a packing 1 

for each container from the generator specifying type and quantity ot chemical 

.a • m < it •!• 

2. Empty containers as defined in 33 IAC g 72.1.10.7(b); 

VES 001546 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 35 of 134 

4^773yprosf^ 

5. Controlled substances, as defined in 24 C.F.R. Part 1308. regulated bv the federal 

paoraipaiea^ 

6. Explosive, poison inhalation hazard (PIH), or odiferous material, such as 

mercaptan, which present sampling, and analytical safety hazards? and that are 

handled unopened until destroyed in the incinerator. 

7h._A.J_ , ,_^p _'_' _ p.' _ JJ _ _L:'_d_ i _ i jp p ;_ pp-p 

i n veil t o n e s^ pack ing lists, an d any ot h err?! evant d ata or information provid ed hv 

the generator to determine whether niereurv. LV M or SV M is present in any 

m s i i _ m p.j_.e '_ ' -')!_' i -_L g_ li _d ' ' . _Ll' _ •-•_!._ a hm 

p \ i j J j _ <_ ' _ _ _ _ j _ h _ -

such review are exempt from the analysis procedures set forth in 2.ltDi(4)(dM2). 

J . f lil_yn^_ m__ 'i _ __v_ _ __; i_ _n_ A ^ . - i^ i 

077742^1172^ 

i _ • _2 " p_ " _ i •>_ 

8. Any waste listed above for which there is insufficient infonnation. to allow the 

Permittee to make a reasonable determination that mercury. LV M and SVM ' are 

not present shall, not be exempt. 

fh _. . ,i . i. a u _t i. . u. _p.i| . a p , m . i _ ._ __' _ "• u_ . _ i _ 

_ p _ 1 '_'C _ J . l — pp Fiuas d f: _J' L 222 ' 

1 • 1 • . i , a 

j vi.) condition 1.1 (D)(4)(d)U) snalisu.per.seQe any contacting or Less stringent. 

, . _ , j_ _ 'j _ ,± j . p , p i _^ 1 

(e) Waiver of monitoring of constituents i n certain feedstreams. The Pennittee is not 

required to monitor levels of metals or chlorine in the following feedstreams to document 

compliance with the feedrate limits under this section provided that the Permittee 

documents in the comprehensive perfonnance test plan the expected levels ofthe 

constituent in the feedstream and account for those assumed feedrate levels in 

VES 001547 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 36 of 134 

documenting compliance with feedrate limits: natural gas, process air, and feedstreams 

from vapor recovery systems. 

(f) Performance evaluations [40 C.F.R. § 63.1209(d)]: 

(i) The requirements of 40 C.F.R. § 63.8(d) (quality control program) and (e) 

(performance evaluation of continuous monitoring systems) apply, except that the 

Permittee must conduct performance evaluations of components ofthe CM S 

under the frequency and procedures (for example, submittal of performance 

evaluation test plan for review and approval) applicable to performance tests as 

provided by 40 C.F.R. § 63.1207. 

(ii) The Permittee must comply with the quality assurance procedures for CEM S 

prescribed in the appendix to Subpart EEE . 

(g) Conduct of monitoring [40 C.F.R. § 63.1209(e)]: The provisions of 40 C.F.R. 

§ 63.8(b) apply. 

(h) Operation and maintenance of continuous monitoring systems [40 C.F.R. 

§ 63.1209(f)]: 

The Pennittee is subject to the provisions of 40 C.F.R. § 63.8(c)-apply, except: 

(i) Section 63.8(c)(3). .Instead of complying with 40 C.F.R. § 63.8(c)(3), the 

Permittee shall comply with 40 C.F.R. § 63.1211(c), which requires CMS s to be 

installed, calibrated, and operational on the compliance date, and 

(ii) Section 63.8(c)(4)(h). instead of complying with 40 C.F.R. § 63.8(c)(4)(h), the 

Permittee shall comply with the performance specifications for carbon monoxide, 

hydrocarbon and oxygen CEMS s in 40 C.F.R. Part 60, Ssubpart B, which requires 

detectors to measure the sample concentration at least once every 15 seconds for 

calculating an average emission rate once every 60. 

(i) Reduction of monitoring data, J40 C.F.R. § 63.1209(h)]: 

The following provisions of 40 C.F.R. § 63.8(g) apply: 

(i) The Pennittee must reduce the monitoring data for each CMS , as specified in 40 

C.F.R. § 63.8(g)(1) through (5). 

(ii) The Permittee shall reduce all data from each COM s to 6-minute averages 

calculated from 36 or more data points which are equally spaced over each 

6-minute period. .Data from CEM S for measurement other than opacity, unless 

otherwise specified in the relevant standard, shall be reduced to 1 -hour averages 

computed from four or more data points equally spaced over each 1-hour period, 

except during periods when calibration, quality assurance, or maintenance 

VES 001548 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 37 of 134 

activities pursuant to provisions of this part are being performed. During these 

periods, a valid hourly average shall consist o f at least two data points with each 

representing a 15-minute period. Alternatively, an arithmetic or integrated 1-hour 

average of CEM S data may be used. Time periods for averaging are defined in 40 

C.F.R. § 63.2. 

(iii) The data may be recorded in reduced or nonreduced form (e.g., ppm pollutant and 

percent O 2 or ng/J of pollutant). 

(iv) Al l emissions data shall be converted into units ofthe relevant standard for 

reporting purposes using the conversion procedures specified in that standard. 

After conversion into units of the relevant standard, the data may be rounded to 

the same number of significant digits as used in that standard to specify the 

emission limit (e.g., rounded to the nearest 1 percent opacity). 

(v) Monitoring data recorded during periods of unavoidable CM S breakdowns, outof-control periods, repairs, maintenance periods, calibration checks, and zero 

(low-level) and high-level adjustments must not be included in any data average 

computed under this part. For the Permittee complying with the requirements of 

63.10(b)(2)(vii)(A) or (B), data averages must include any data recorded during 

periods of monitor breakdown or malfunction. 

(j) When an operating parameter is applicable to multiple standards [40 C.F.R. 

§ 63.1209(f)]: 

40 C.F.R. § 63.1209(j) through (p) requires the Permittee to establish limits on operating 

parameters based on comprehensive perfonnance testing to ensure the Permittee 

maintains compliance with the emission standards. For several parameters, the Permittee 

must establish a limit for the parameter to ensure compliance with more than one 

emission standard. A n example is a limit on minimum combustion chamber temperature 

to ensure compliance with both the DR E standard of 40 C.F.R. § 63.1209(j) and the 

dioxin/furan standard of 40 C.F.R. § 63.1209(k). If the perfonnance tests for such 

standards are not performed simultaneously, the most stringent limit for a parameter 

derived from independent performance tests applies. 

(k) Destruction and Removal Efficiency [40 C.F.R. § 63.1209(j)]: To remain in 

compliance with the destraetion and removal effieietwy (DRE) standard, the Permittee 

must establish operating limits during the comprehensive performance test (or during a 

previous DR E test under provisions of 40 C.F.R. § 63.1206(b)(7)) for the following 

parameters, unless the limits are based on manufacturer specifications, and comply with 

those limits at all times that hazardous waste remains in the combustion chamber (i.e., the 

hazardous waste residence tune has not transpired since the hazardous waste feed cutoff 

system was activated): 

(i) Minimum combustion chamber temperature. 

VES 001549 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 38 of 134 

(A) The Permittee must measure the temperature of each combustion chamber at a 

location that best represents, as practicable, the bulk gas temperature in the 

combustion zone. The Permittee must document the temperature measurement 

location in the test plan the Pennittee submit under 40 C.F.R. § 63.1207(e). 

(B) The Permittee must establish a minimum hourly rolling average limit as the 

average of the test run averages. 

(ii) _Maximum flue gas flowrate or production rate^ 

(A) As an indicator of gas residence time in the control device, the Permittee must 

establish and comply with a limit on the maximum flue gas flowrate, the 

maximum production rate, or another parameter that the Permittee documents in 

the site-specific test plan as an appropriate sunogate for gas residence time, as the 

average of the maximum hourly rolling averages for each run. 

(B) The Permittee must comply with this limit on an hourly rolling average basis. 

(iii) .Maximum hazardous waste feedrate 

(A) The Permittee must establish limits on the maximum pumpable and total (i.e., 

pumpable and nonpumpable) hazardous waste feedrate for each location where 

hazardous waste is fed. 

(B) The Permittee must establish the limits as the average of the maximum hourly 

rolling averages for each run. 

(C) The Permittee must comply with the feedrate limit(s) on an hourly rolling 

average basis. 

(iv) Operation of waste firing system. The Pennittee must specify operating 

parameters and limits to ensure that good operation of each hazardous waste firing 

system is maintained. 

(1) Dioxins and furans [40 C.F.R. § 63.1209(k)]: The Permittee must comply with the 

dioxin and furans emission standard by establishing and complying with the following 

operating parameter limits. The Permittee must base the limits on operations during the 

comprehensive performance test, unless the limits are based on manufacturer 

specifications. 

(i) Gas temperature at the inlet to a dry particulate matter control device. 

Each combustor is equipped with a baghouse (fabric filter). Therefore, the 

Permittee must establish a limit on the maximum temperature of the gas at the 

inlet to the device on an hourly rolling average. The Permittee must establish the 

hourly rolling average limit as the average of the test run averages. 

VES 001550 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 39 of 134 

(ii) Minimum combustion chamber temperature^ 

(A) The Pennittee must measure the temperature of each combustion chamber at a 

location that best represents, as practicable, the bulk gas temperature in the 

combustion zone. The Permittee must document the temperature measurement 

location in the test plan under 40 C.F.R. § 63.1207(e) and (f); 

(B) The Permittee must establish a minimum hourly rolling average limit as the 

average of the test run averages. 

(iii) Maximum flue gas flow rate or production rate_ 

(A) As an indicator of gas residence time in the control device, the Permittee must 

establish and comply with a limit on the maximum flue gas flow rate, the 

maximum production rate, or another parameter that the Permittee documents in 

the site-specific test plan as an appropriate sunogate for gas residence time, as the 

average of the maximum hourly rolling averages for each run. 

(B) The Permittee must comply with this limit on an hourly rolling average basis. 

(iv) Maximum hazardous waste feedrate, 

(A) The Permittee must establish limits on the maximum pumpable and total 

(pumpable and nonpumpable) waste feedrate for each location where waste is fed. 

(B) The Permittee must establish the limits as the average of the maximum hourly 

rolling averages for each run. 

(C) The Permittee must comply with the feedrate limit(s) on an hourly rolling 

average basis. 

(v) Particulate matter operating limit 

Combustor #4 is equipped with an activated carbon injection system, therefore, 

the Pennittee must establish operating parameter limits on the particulate matter 

control device as specified by 40 C.F.R. § 63.1209(m)(l). 

(vi) Activated carbon injection parameter limits^ 

(A) Carbon feedrate. The Permittee must establish a limit on minimum carbon 

injection rate on an hourly rolling average calculated as the average of the test run 

averages for unit #4. If the carbon injection system injects carbon at more than 

one location, the Permittee must establish a carbon feedrate limit for each 

location. 

VES 001551 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 40 of 134 

(B) Carrier fluid. The Permittee must establish a limit on minimum carrier fluid 

(gas or liquid) flowrate or pressure drop as an hourly rolling average based on the 

manufacturer's specifications for unit #4. The Permittee must document the 

specifications in the test plan submitted under 40 C.F.R. § 63.1207(e) and (f). 

(C) Carbon specification 

(1) The Permittee must specify and use the brand (i.e., manufacturer) and type 

of carbon used during the comprehensive performance test until a 

subsequent comprehensive performance test is conducted, unless the 

Permittee documents in the site-specific performance test plan required 

under 40 C.F.R. § 63.1207(e) and (f) key parameters that affect adsorption 

and establish limits on those parameters based on the carbon used in the 

performance test. 

(2) The Permittee may substitute at any time a different brand or type of 

carbon provided that the replacement has equivalent or improved 

properties compared to the carbon used in the performance test and 

conforms to the key sorbent parameters identified under 40 C.F.R. 

§ 63.1209(k)(6)(iii)(A). The Permittee must include in the operating 

record documentation that the substitute carbon will provide the same 

level of control as the original carbon. 

(vii) Jnhibitor feedrate parameter limits. _If the Permittee feeds a dioxin/furan inhibitor 

into the combustion system, the Permittee must establish limits for the following 

parameters: 

(A) Minimum inhibitor feedrate. _The Permittee must establish a limit on 

minimum inhibitor feedrate on an hourly rolling average as the average ofthe test 

run averages. 

(B) Inhibitor specifications. 

(1) The Permittee must specify and use the brand (i.e., manufacturer) and type 

of inhibitor used during the comprehensive performance test until a 

subsequent comprehensive performance test is conducted, unless the 

Permittee documents in the site-specific performance test plan required 

under 40 C.F.R. § 63.1207(e) and (f) key parameters that affect the 

effectiveness of the inhibitor and establish limits on those parameters 

based on the inhibitor used in the performance test. 

(2) The Permittee may substitute at any time a different brand or type of 

inhibitor provided that the replacement has equivalent or improved 

properties compared to the inhibitor used in the performance test and 

conforms to the key parameters the Permittee identifies under 40 C.F.R. 

§ 63.1209(k)(9)(ii)(A). /The Permittee must include in the operating 

VES 001552 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 41 of 134 

record documentation that the substitute inhibitor wil l provide the same 

level of control as the original inhibitor. 

(m) Mercury [40 C.F.R. § 63.1209(1)]: The Permittee must comply with the mercury 

emission standard by establishing and complying with the following operating parameter 

limits. The Permittee must base the hmits on operations during the comprehensive 

performance test, unless the limits are based on manufacturer specifications. 

(i) Feedrate of mercury. When complying with the mercury emission standards 

under 40 C.F.R. §§ 63.1203, 63.1216 and 63.1219, the Permittee must establish a 

12-hour rolling average limit for the total feedrate of mercury in all feedstreams 

as the average of the test run averages. 

(ii) ..Extrapolation of feedrate levels. _In lieu of establishing mercury feedrate limits as 

specified in 40 C.F.R. § 63.1209(l)(l)(i), the Permittee may request as part ofthe 

performance test plan under 40 C.F.R. §§ 63.7(b) and (c) and 63.1207(e) and (f) 

approval to use the mercury feedrates and associated emission rates during the 

comprehensive performance test to extrapolate to higher allowable feedrate limits 

and emission rates. .The extrapolation methodology will be reviewed and 

approved, if warranted, by U.S. EPA . U.S. EPA's review will consider in 

particular whether: 

(A) Performance test metal feedrates are appropriate (i.e., whether feedrates are at 

least at normal levels; depending on the heterogeneity o f the waste, whether some 

level of spiking would be appropriate; and whether the physical form and species 

of spike material is appropriate); and 

(B) Whether the extrapolated feedrates the Permittee requests are warranted 

considering historical metal feedrate data. 

(iii) Activated carbon injection. Incinerator #4 is equipped with an activated carbon 

injection system, therefore, the Permittee must establish operating parameter 

limits prescribed by 40 C.F.R. § 63.1209(k)(5) and (k)(6). 

(n) Particulate matter [40 C.F.R. § 63.1209(m)]: The Permittee must comply with the 

particulate matter emission standard by establishing and complying with the following 

operating parameter limits. The Permittee must base the limits on operation during the 

comprehensive performance test, unless the limits are based on manufacturer 

specifications. 

(i) Control device operating parameter limits. 

The Permittee must ensure that the control device is properly operated and 

maintained as required by 40 C.F.R. § 63.1206(c)(7) and by monitoring the 

operation of the control device. 

VES 001553 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 42 of 134 

(A) During each comprehensive performance test conducted to demonstrate 

compliance with the particulate matter emissions standard, the Permittee must 

establish a range of operating values for the control device that is a representative 

and reliable indicator that the control device is operating within the same range of 

conditions as during the performance test. /Tthe Permittee must establish this 

range of operating values as follows: 

(1) The Permittee must select a set of operating parameters appropriate for the 

control device design that the Permittee determines to be a representative 

and reliable indicator ofthe control device performance. 

(2) The Permittee must measure and record values for each of the selected 

operating parameters during each test run of the performance test. _A value 

for each selected parameter must be recorded using a continuous monitor. 

(3) For each selected operating parameter measured i n accordance with the 

requirements of 40 C.F.R. § 63.1209(m)(l)(iv)(A)(l), the Pennittee must 

establish a minimum operating parameter limit or a maximum operating 

parameter limit, as appropriate for the parameter, to define the operating 

limits within which the control device can operate and still continuously 

achieve the same operating conditions as during the performance test. 

(4) The Pennittee must prepare written documentation to support the 

operating parameter limits established for the control device and must 

include this documentation in the performance test plan that the Permittee 

submits for review and approval. This documentation must include a 

description for each selected parameter and the operating range and 

monitoring frequency required to ensure the control device is being 

properly operated and maintained. 

(B) The Permittee must install, calibrate, operate, and maintain a monitoring 

device equipped with a recorder to measure the values for each operating 

parameter selected in accordance with the requirements of 40 C.F.R. 

§ 63.1209(m)(l)(iv)(A)(l). /The Permittee must install, calibrate, and maintain the 

monitoring equipment in accordance with the equipment manufacturer's 

specifications. /The recorder must record the detector responses at least every 

60 seconds, as required in the definition of continuous monitor. 

(C) The Pennittee must regularly inspect the data recorded by the operating 

parameter monitoring system at a sufficient frequency to ensure the control device 

is operating properly. _An excursion is determined to have occuned any time that 

the actual value of a selected operating parameter is less than the minimum 

operating limit (or, if applicable, greater than the maximum operating limit) 

established for the parameter in accordance with the requirements of 

§ 63.1209(m)(l)(iv)(A)(3). 

VES 001554 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 43 of 134 

(D) Operating parameters selected in accordance with 40 C.F.R. 

§ 63.1209(m)(l)(iv) may be based on manufacturer specifications provided the 

Permittee supports the use of manufacturer specifications in the performance test 

plan that the Permittee submits for review and approval. 

(ii) Maximum flue gas flowrate or production rate. 

(A) As an indicator of gas residence time in the control device, the Permittee must 

establish a limit on the maximum flue gas flowrate, the maximum production rate, 

or another parameter that the Permittee documents in the site-specific test plan as 

an appropriate surrogate for gas residence time, as the average of the maximum 

hourly rolling averages for each run. 

(B) The Permittee must comply with this limit on an hourly rolling average basis. 

(iii) -Maximum ash feedrate. 

The Permittee must establish a maximum ash feedrate limit as a 12-hour rolling 

average of the test run averages. /This requirement is waived, however, if the 

Permittee complies with particulate matter detection system requirements under 

40 C.F.R. §63.1206(c)(9). 

(o) Semi-volatile metals and low volatile metals [40 C.F.R. § 63.1209(n)]: Tlie Pennittee 

must comply with the semi-volatile metal (cadmium and lead: SVM ) and low volatile 

metal (arsenic, beryllium, and chromium; LVM ) emission standards by establishing and 

complying with the following operating parameter limits. The Permittee must base the 

limits on operations during the comprehensive performance test, unless the limits are 

based on manufacturer specifications. 

(i) Maximum inlet temperature to dry particulate matter air pollution control device. 

The Permittee must establish a limit on the maximum inlet temperature to the 

primary dry metals emissions control device (e.g., baghouse) on an hourly rolling 

average basis as the average of the test run averages. 

(ii) Maximum feedrate of semi-volatile and low volatile metals. 

(A) General. The Permittee must establish feedrate limits for semi volatile metals 

Hmh^mm<m44m4¥sy M and Lw^aaTLT ^ 

chromium)LVM as follows, except as provided by 40 C.F.R. § 63.1209(n)(2)(ii): 

(B) When complying with the emission standards under 40 C.F.R. §§ 63.1203 and 

63.1219, the Pennittee must establish 12-hour rolling average limits for the total 

feedrate of semivolatile SVM_and low volatile metalsLVM in all feedstreams as 

the average of the test run averages. 

VES 001555 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 44 of 134 

(C) LV M limits for pumpable wastes. The Permittee must establish separate 

feedrate limits for low volatile-inetolsLVM in pumpable feedstreams using the 

procedures prescribed above for total k>wvolatile roetalsLVM. .Dual feedrate 

limits for both pumpable and total feedstreams are not required, however, if the 

Pennittee the Permitteecstablish.es the total feedrate limit solely based on the 

feedrate of pumpable feedstreams. 

(iii) Control device operating parameter limits (OPLs). The Permittee must establish 

operating parameter limits on the particulate matter control device as specified by 

40 C.F.R. § 63.1209(m)(l); 

(iv) Maximum total chlorine and chloride feedrate. The Permittee must establish a 

12-hour rolling average limit for the feedrate of total chlorine and chloride in all 

feedstreams as the average of the test run averages. 

(v) Maximum flue gas flowrate or production rate. 

(A) As an indicator of gas residence time in the control device, the Permittee must 

establish a limit on the maximum flue gas flowrate, the maximum production rate, 

or another parameter that the Permittee documents in the site-specific test plan as 

an appropriate surrogate for gas residence time, as the average of the maximum 

hourly rolling averages for each run. 

(B) The Permittee must comply with this limit on an hourly rolling average basis. 

(p) Hydrogen chloride and chlorine gas [40 C.F.R. § 63.1209(o)]: The Permittee must 

comply with the hydrogen chloride and chlorine gas emission standard by establishing 

and complying with the following operating parameter limits. The Permittee must base 

the limits on operations during the comprehensive performance test, unless the limits are 

based on manufacturer specifications. 

(i) Feedrate of total chlorine and chloride. The Permittee must establish a 12-hour 

rolling average limit for the total feedrate of chlorine (organic and inorganic) in 

all feedstreams as the average of the test run averages. 

(ii) Maximum flue gas flowrate or production rate. 

(A) As an indicator of gas residence time in the control device, the Permittee must 

establish a limit on the maximum flue gas flowrate, the maximum production rate, 

or another parameter that the Perrnittee documents i n the site-specific test plan as 

an appropriate sunogate for gas residence time, as the average of the maximum 

hourly rolling averages for each run. 

(B) The Pennittee must comply with this limit on an hourly rolling average basis. 

VES 001556 
I Veolia Environmental Services 

Pennit No.; V-IL-1716300103-08-01 

| Expires: October 12,2013 

Page: 45 of 134 

(iii) Dry Scrubber. /The combustor is equipped with a dry scrubber, therefore, the 

Permittee must establish and comply with the following operating parameter 

limits: 

(A) Minimum sorbent feedrate. /The Permittee must establish a limit on minimum 

sorbent feedrate on an hourly rolling average as the average of the test run 

averages. 

(B) Minimum carrier fluid flowrate or nozzle pressure drop. /The Permittee must 

establish a limit on minimum carrier fluid (gas or liquid) flowrate or nozzle 

pressure drop based on manufacturer/^ specifications. 

(C) Sorbent specifications: 

(1) The Permittee must specify and use the brand (i.e., manufacturer) and type 

of sorbent used during the comprehensive performance test until a 

subsequent comprehensive performance test is conducted, unless the 

Permittee documents in the site-specific performance test plan required 

under 40 C.F.R. § 63.1207(e) and (f) key parameters that affect adsorption 

and establish limits on those parameters based on the sorbent used in the 

performance test. 

(2) The Pennittee may substitute at any time a different brand or type of 

sorbent provided that the replacement has equivalent or improved 

properties compared to the sorbent used in the perfonnance test and 

conforms to the key sorbent parameters the Permittee identifies under 40 

C.F.R. § 63.1209(o)(4)(iii)(A)._ The Permittee must record in the 

operating record documentation that the substitute sorbent will provide the 

same level of control as the original sorbent. 

(q) Maximum combustion chamber pressure [40 C.F.R. § 63.1209(p): /The Permittee 

must monitor the pressure instantaneously and the automatic waste feed cutoff system 

must be engaged when negative pressure is not maintained. 

(r) Operating under different modes of operation [40 C.F.R. § 63.1209(q): /The Permittee 

has not established different mode of operation. /Therefore, the source shall only operate 

under the terms and conditions identified in this permit. 

(s) Significant figures. /The emission limits provided in 40 C.F.R. §§ 63.1203 and 

63.1219(a) and (b) are presented with two significant figures. .Although the Permittee 

must perform intermediate calculations using at least three significant figures, the 

Pennittee may round the resultant emission levels to two significant figures to document 

compliance.. [40 C.F.R. §§ 63.1203(d) and 63.1219(d)] 

5. If the Permittee plans to change (as defmed in 40 C.F.R. § 63.1206(b)(5)(iii)) the design, 

operation, or maintenance practices of the source in a manner that may adversely affect 

VES 001557 
I Veolia Environmental Services 

Pennit No.; V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 46 of 134 

compliance with any emission standard that is not monitored with a CEMS , the Pennittee 

must conduct a comprehensive performance test under the requirements of 40 C.F.R. 

§ 63.1207(f)(1) and (g)(1) to document compliance with the affected emission standard(s) 

and establish operating parameter limits as required under 40 C.F.R. § 63.1209, and 

submit to the Administrator a Notification of ComplianceN(X' under 40 C.F.R. 

§§ 63.1207G) and 63.1211(c). _[40 C.F.R. § 63.1206(b)(5)(i)(B)] 

6. Compliance with the carbon monoxide and hydrocarbon emission standards. [40 C.F.R. 

§ 63.1206(b)(6)] .This paragraph applies to sowees-thatthe Pennittee if it elects to 

comply with the carbon monoxide and hydrocarbon emissions standards of Ssubpart EE E 

by documenting continuous compliance with the carbon monoxide standard using a 

continuous emissions monitoring system and documenting compliance with the 

hydrocarbon standard during the destruction and removal efficiency (DRE) performance 

test or its equivalent. 

(a) If during the acceptable DR E test the Permittee did not obtain hydrocarbon emissions 

data sufficient to document compliance with the hydrocarbon standard, the Permittee 

must either: 

(i) Perform, as part of the performance test, an "equivalent DR E test" to document 

compliance with the hydrocarbon standard. _An equivalent DR E test is comprised 

of a minimum of three runs each with a minimum duration of 1 hour during which 

the Pennittee operates the combustor as close as reasonably possible to the 

operating parameter limits that the Permittee established based on the initial DR E 

test. The Permittee must use the highest hourly rolling average hydrocarbon 

emission level achieved during the equivalent DR E test to document compliance 

with the hydrocarbon standard; or 

(ii) Perform a DR E test as part of the performance test. 

7. The provisions of 40 C.F.R. § 63.7 apply, except as noted below. [40 C.F.R. 

§ 63.1207(a)] 

8. Types of performance tests^ [40 C.F.R. § 63.1207(b)] 

(a) The Pennittee must conduct comprehensive perfonnance tests to demonstrate 

compliance with the emission standards provided by 40 C.F.R. Part 63, Subpart EEE , 

establish limits for the operating parameters provided by 40 C.F.R. § 63.1209, and 

demonstrate compliance with the performance specifications for continuous monitoring 

systems for each incinerator. 

(b) Confirmatory performance test. The Pennittee must conduct confirmatory 

performance tests on each incinerator to: 

(i) Demonstrate compliance with the dioxin/furan emission standard when the source 

operates under normal operating conditions; and 

VES 001558 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 47 of 134 

(ii) Conduct a performance evaluation of continuous monitoring systems required for 

compliance assurance with the dioxin/furan emission standard under 40 C.F.R. 

§ 63.1209(k). 

9. The Permittee must commence the initial comprehensive performance test to demonstrate 

compliance with the standards under 40 C.F.R. §§ 63.1219, 63.1220, and 63.1221 not 

later than 12 months after the compliance date. .[40 C.F.R. § 63.1207(c)(3)] 

10. Frequency of testing. Except as otherwise specified in 40 C.F.R. § 63.1207(d)(4), the 

Permittee must conduct testing periodically as prescribed in 40 C.F.R. § 63.1207(d)(1) 

through (d)(3). /The date of commencement of the initial comprehensive performance test 

is the basis for establishing the deadline to commence the initial confirmatory 

performance test and the next comprehensive performance test. The Pennittee may 

conduct performance testing at any time prior to the required date.. The deadline for 

commencing subsequent confirmatory and comprehensive performance testing is based 

on the date of commencement of the previous comprehensive perfonnance test. .Unless 

the Administrator grants a time extension under § 63. 1207(b)(3)(i), the Permittee must 

conduct testing as follows: 

(a) Comprehensive performance testing. .Except as otherwise specified in 40 C.F.R. 

§ 63.1207(d)(4), the Permittee must commence testing no later than 61 months after the 

date of commencing the previous comprehensive perfonnance test. 

(b) Confinnatory performance testing. _Except as otherwise specified in 40 C.F.R. 

§ 63.1207(d)(4), the Permittee must commence confirmatory performance testing no later 

than 31 months after the date o f commencing the previous comprehensive performance 

test. If the Permittee submit data in lieu of the initial performance test, the Permittee 

must commence the initial confirmatory performance test within 31 months ofthe date 6 

months after the compliance date. /To ensure that the confinnatory test is conducted 

approximately midway between comprehensive performance tests, the Administrator will 

not approve a test plan that schedules testing within 18 months of commencing the 

previous comprehensive performance test. 

(c) Duration of testing. .The Permittee must complete performance testing within 60 days 

after the date of commencement, unless the Administrator detennines that a time 

extension is wananted based on its documentation in writing of factors beyond its control 

that prevents the Permittee from meeting the 60-day deadline. 

11. Content of performance test plan [40 C.F.R. § 63.1207(f)]. .The provisions of 40 C.F.R. 

§§ 63.7(c)(2)(i)-(iii) and (v) regarding the content of the test plan apply.. In addition, the 

Pennittee must include the following infonnation in the test plan: 

(a) Content of comprehensive performance test plan. 

VES 001559 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 48 of 134 

(i) A n analysis of each feedstream, including hazardous waste, other fuels, and 

industrial furnace feedstocks, as fired, that includes: 

(A) Heating value, levels of ash (for hazardous waste incinerators only), levels of 

semivolatile metalsSVM. low volatile metnlsLVM. mercury, and total chlorine 

(organic and inorganic); and 

(B) Viscosity or description ofthe physical form ofthe feedstream; 

(ii) For organic hazardous air pollutants established by 42 U.S.C. 7412(b)(1), 

excluding caprolactam (CAS number 105602) as provided by 40 C.F.R. § 63.60: 

(A) Except as provided by 40 C.F.R. § 63.1207(f)( l)(ii)(D), an identification of 

such organic hazardous air pollutants that are present in each hazardous waste 

feedstream. The Permittee need not analyze for organic hazardous air pollutants 

that would reasonably not be expected to be found i n the feedstream. /The 

Pennittee must identify any constituents the Pennittee excludes from analysis and 

explain the basis for excluding them. /The Permittee must conduct the feedstream 

analysis according to 40 C.F.R. § 63.1208(b)(8); 

(B) A n approximate quantification of such identified organic hazardous air 

pollutants in the hazardous waste feedstreams, within the precision produced by 

analytical procedures of 40 C.F.R. § 63.1208(b)(8); and 

(C) A description of blending procedures, if applicable, prior to firing the 

hazardous waste feedstream, including a detailed analysis of the materials prior to 

blending, and blending ratios. 

(D) The Administrator may approve on a case-by-case basis a hazardous waste 

feedstream analysis for organic hazardous air pollutants in lieu of the analysis 

required under 40 C.F.R. § 63.1207(f)(l)(ii)(A) if the reduced analysis is 

sufficient to ensure that the POHCs used to demonstrate compliance with the 

applicable DR E standards of this subpart continue to be representative of the most 

difficult to destroy organic compounds in its hazardous waste feedstreams; 

(iii) A detailed engineering description of the hazardous waste combustor, including: 

(A) Manufacturer's name and model number of the hazardous waste combustor; 

(B) Type of hazardous waste combustor; 

(C) Maximum design capacity in appropriate units; 

(D) Description of the feed system for each feedstream; 

(E) Capacity of each feed system; 

VES 001560 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 49 of 134 

(F) Description of automatic hazardous waste feed cutoff system(s); 

(G) Description of the design, operation, and maintenance practices for any air 

pollution control system; and 

(H) Description of the design, operation, and maintenance practices of any stack 

gas monitoring and pollution control monitoring systems; 

(iv) A detailed description of sampling and monitoring procedures including sampling 

and monitoring locations in the system, the equipment to be used, sampling and 

monitoring frequency, and planned analytical procedures for sample analysis; 

(v) A detailed test schedule for each hazardous waste for which the performance test 

is planned, including date(s), duration, quantity of hazardous waste to be burned, 

and other relevant factors; 

(vi) A detailed test protocol, including, for each hazardous waste identified, the ranges 

of hazardous waste feedrate for each feed system, and, as appropriate, the 

feedrates of other fuels and feedstocks, and any other relevant parameters that 

may affect the ability ofthe hazardous waste combustor to meet the emission 

standards; 

(vii) _A description of, and planned operating conditions for, any emission control 

equipment that will be used; 

(viii) Procedures for rapidly stopping the hazardous waste feed and controlling 

emissions in the event of an equipment malfunction; 

(ix) A. determination of the hazardous waste residence time as required by 40 C.F.R. 

"§ 63.1206(b)(ll); 

(x) If the Permittee is requesting to extrapolate metal feedrate limits from 

comprehensive performance test levels under 40 C.F.R. §•§ 63.1209(l)(l)(v) or 

63.1209(n)(2)(vii): 

(A) A description of the extrapolation methodology and rationale for how the 

approach ensures compliance with the emission standards; 

(B) Documentation of the historical range of normal (i.e., other than during 

compliance testing) metals feedrates for each feedstream; 

(C) Documentation that the level of spiking recommended during the performance 

test will mask sampling and analysis imprecision and inaccuracy to the extent that 

the extrapolated feedrate limits adequately assure compliance with the emission 

standards; 

VES 001561 
Veolia Enviromnental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 50 of 134 

(xi) If the Permittee does not continuously monitor regulated constituents in natural 

gas, process air feedstreams, and feedstreams from vapor recovery systems under 

40 C.F.R. § 63.1209(c)(5), the Permittee must include documentation ofthe 

expected levels of regulated constituents in those feedstreams; 

(xii) Documentation justifying the duration of system conditioning required to ensure 

the combustor has achieved steady-state operations under performance test 

operating conditions, as provided by 40 C.F.R. § 63.1207(g)(l)(iii); 

(xiii) The Permittee must submit an application to request alternative monitoring under 

40 C.F.R. § 63.1209(g)(1) not later than with the comprehensive performance test 

plan, as required by § 63.1209(g)(l)(iii)(A). 

(xiv) The Permittee must document the temperature location measurement in the 

comprehensive performance test plan, as required by 40 C.F.R. 

§§ 63.1209(j)(l)(i) and 63.1209(k)(2)(i). 

(xv) .Because unit 4 is equipped with activated carbon injection, the Permittee must 

document in the comprehensive performance test plan for unit 4: 

(A) The manufacturer specifications for minimum carrier fluid flowrate or 

pressure drop, as required by 40 C.F.R. § 63.1209(k)(6)(ii); and 

(B) Key parameters that affect carbon adsorption, and the operating limits the 

Permittee establishes for those parameters based on the carbon used during the 

performance test, if the Permittee elects not to specify and use the brand and type 

of carbon used during the comprehensive performance test, as required by 40 

C.F.R. § 63.1209(k)(6)(iii). 

(xvi) If its source is equipped with a particulate matter control device other than a wet 

scrubber, the Permittee must include in the comprehensive performance test plan: 

(A) Documentation to support the operating parameter limits the Permittee 

establishes for the control device, as required by 40 C.F.R. 

§ 63.1209(m)(l)(iv)(A)(4); and 

(B) Support for the use of manufacturer specifications if the Permittee 

recommends such specifications in lieu of basing operating limits on performance 

test operating levels, as required by § 63.1209(m)(l)(iv)(D). 

(xvii) Jf its source is equipped with a dry scrubber to control hydrogen chloride and 

chlorine gas, the Permittee must document in the comprehensive performance test 

plan key parameters that affect adsorption, and the limits the Permittee establishes 

for those parameters based on the sorbent used during the performance test, if the 

Permittee elects not to specify and use the brand and type of sorbent used during 

VES 001562 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 51 of 134 

the comprehensive performance test, as required by 40 C.F.R. 

§63.1209(o)(4)(iii)(A);and 

(xviii) .For purposes of calculating semivolatile metalSVM. low volatile rnetaltVM. 

mercury, and total chlorine (organic and inorganic), and ash feedrate limits, a 

description of how the Permittee will handle performance test feedstream 

analytical results that determine these constituents are not present at detectable 

levels. 

(xix) Such other information as the Administrator reasonably finds necessary to 

determine whether to approve the performance test plan. 

(b) Content of confirmatory test plan. 

(i) A description ofthe Permittee's normal hydrocarbon or carbon monoxide 

operating levels, as specified in 40 C.F.R. § 63.1207(g)(2)(i), and an explanation 

of how these nonnal levels were determined; 

(ii) _ A description of the Permittee's normal applicable operating parameter levels, as 

specified in 40 C.F.R. § 63.1207(g)(2)(h), and an explanation of how these 

normal levels were determined; 

(iii) A description of the Permittee's nonnal chlorine operating levels, as specified in 

40 C.F.R. § 63.1207(g)(2)(iii), and an explanation of how these normal levels 

were determined; 

(iv) A description of the Permittee's normal cleaning cycle of the particulate matter 

control device for unit 4, as specified in 40 C.F.R. § 63.1207(g)(2)(iv), and an 

explanation of how these normal levels were determined; 

(v) A detailed description of sampling and monitoring procedures including sampling 

and monitoring locations in the system, the equipment to be used, sampling and 

monitoring frequency, and planned analytical procedures for sample analysis; 

(vi) A detailed test schedule for each hazardous waste for which the performance test 

is planned, including date(s), duration, quantity of hazardous waste to be burned, 

and other relevant factors; 

(vii) A detailed test protocol, including, for each hazardous waste identified, the ranges 

of hazardous waste feedrate for each feed system, and, as appropriate, the 

feedrates of other fuels and feedstocks, and any other relevant parameters that 

may affect the ability of the hazardous waste combustor to meet the dioxin/furan 

emission standard; 

(viii) A description of, and planned operating conditions for, any emission control 

equipment that will be used; 

VES 001563 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 52 of 134 

(ix) Procedures for rapidly stopping the hazardous waste feed and controlling 

emissions in the event of an equipment malfunction; and 

(x) Such other information as the Administrator reasonably finds necessary to 

determine whether to approve the confirmatory test plan. 

12. Operating conditions during testing. [40 C.F.R. § 63.1207(g)] /The Permittee must 

comply with the provisions of 40 C.F.R. § 63.7(e). Conducting performance testing 

under operating conditions representative of the extreme range of normal conditions is 

consistent with the requirement of 40 C.F.R. § 63.7(e)(1) to conduct performance testing 

under representative operating conditions. 

(a) Comprehensive performance testing 

(i) Operations during testing. JFor the following parameters, the Permittee must 

operate the combustor during the perfonnance test under nonnal conditions (or 

conditions that will result in higher than normal emissions): 

(A) Chlorine feedrate. The Permittee must feed normal (or higher) levels of 

chlorine during the dioxin/furan performance test; 

(B) Ash feedrate. For hazardous waste incinerators, the Pennittee must conduct 

the following tests when feeding normal (or higher) levels of ash: The 

sen-ttvolntile metalSVM and low volatile metalLVM performance tests; and the 

dioxin/furan and mercury performance tests if activated carbon injection or a 

carbon bed is used; and 

(C) Cleaning cycle of the particulate matter control device. The Permittee must 

conduct the following tests when the particulate matter control device undergoes 

its normal (or more frequent) cleaning cycle: The particulate matter, f*wmvbu4+e 

metalSVM. and low volatile metal LV M performance tests; and the dioxin/furan 

and mercury perfonnance tests if activated carbon injection or a carbon bed is 

used. 

(ii) Modes of operation. .Given that the Pennittee must establish limits for the 

applicable operating parameters specified in § 63.1209 based on operations during 

the comprehensive performance test, the Permittee may conduct testing under two 

or more operating modes to provide operating flexibility. 

(iii) Steady-state conditions. 

Prior to obtaining performance test data, the Permittee must operate under 

performance test conditions until the Permittee reaches steady-state operations 

with respect to emissions of pollutants the Permittee must measure during the 

performance test and operating parameters under 40 C.F.R. § 63.1209 for which 

VES 001564 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 53 of 134 

the Permittee must establish limits. During system conditioning, the Permittee 

must ensure that each operating parameter for which the Permittee must establish 

a limit is held at the level planned for the performance test. The Permittee must 

include documentation in the performance test plan under 40 C.F.R. § 63.1207(f) 

justifying the duration of system conditioning. 

(b) Confirmatory performance testing. The Permittee must conduct confirmatory 

performance testing for dioxin/furan under normal operating conditions for the following 

parameters: 

(i) Carbon monoxide (or hydrocarbon) CEM S emissions levels must be within the 

range of the average value to the maximum value allowed, except as provided by 

40 C.F.R. § 63.1207(g)(2)(iv). /The average value is defined as the sum of the 

hourly rolling average values recorded (each minute) over the previous 

12 months, divided by the number of rolling averages recorded during that time. 

The average value must not include calibration data, startup data, shutdown data, 

malfunction data, and data obtained when not burning hazardous waste; 

(ii) _Each operating limit (specified in 40 C.F.R. § 63.1209) established to maintain 

compliance with the dioxin/furan emission standard must be held within the range 

ofthe average value over the previous 12 months and the maximum or minimum, 

as appropriate, that is allowed, except as provided by 40 C.F.R. 

§ 63.1207(g)(2)(iv). The average value is defined as the sum of the rolling 

average values recorded over the previous 12 months, divided by the number of 

rolling averages recorded during that time. /The average value must not include 

calibration data, startup data, shutdown data, malfunction data, and data obtained 

when not burning hazardous waste; 

(iii) The Permittee must feed chlorine at normal feedrates or greater; and 

(iv) .If the combustor is equipped with carbon injection or carbon bed, normal cleaning 

cycle ofthe particulate matter control device. 

(v) The Administrator may approve an alternative range to that required by 40 C.F.R. 

§ 63.1207(g)(2)(i) and (ii) if the Permittee documents i n the confirmatory 

perfonnance test plan that it may be problematic to maintain the required range 

during the test.. In addition, when making the finding of compliance, the 

Administrator may consider test conditions outside of the range specified in the 

test plan based on a finding that the Permittee could not reasonably maintain the 

range specified in the test plan and considering factors including whether the time 

duration and level of the parameter when operations were out of the specified 

range were such that operations during the confirmatory test are detennined to be 

reasonably representative of normal operations. _In addition, the Administrator 

will consider the proximity of the emission test results to the standard. 

13. Operating conditions during subsequent testing. _[40 C.F.R. § 63.1207(h)] 

VES 001565 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 54 of 134 

(a) Current operating parameter limits established under 40 C.F.R. § 63.1209 are waived 

during subsequent comprehensive performance testing. 

(b) Current operating parameter limits are also waived during pretesting prior to 

comprehensive performance testing for an aggregate time not to exceed 720 hours of 

operation (renewable at the discretion of the Administrator) under an approved test plan 

or if the source records the results of the pretesting. Pretesting means: 

(i) Operations when stack emissions testing for dioxin/furan, mercury, se«m+4iH41** 

g «rteteSVM , low volatile metalsLVM. particulate matter, or hydrogen 

chloride/chlorine gas is being performed; and 

(ii) Operations to reach steady-state operating conditions prior to stack emissions 

testing under 40 C.F.R. § 63.1207(g)(l)(iii). 

14. Test methods. [40 C.F.R. § 63.1208] The Permittee must use the following test methods 

to determine compliance with the emissions standards of this subpart: 

(a) Dioxins and furans. 

(i) To determine compliance with the emission standard for dioxins and furans, the 

Pennittee must use: 

(A) Method 0023A, Sampling Method for Polychlorinated Dibenzo-p-Dioxins 

and Polychlorinated Dibenzofurans emissions from Stationary Sources, EP A 

Publication SW-846 (incorporated by reference—see 40 C.F.R. § 63.14); or 

(B) Method 23, provided in 40 C.F.R. Ppart 60, a/appendix A , after approval by 

the Administrator. 

(1) The Permittee may request approval to use Method 23 in the performance 

test plan required under § 63.1207(e)(#|)(i) and (ii). 

(2) In determining whether to grant approval to use Method 23, the 

Administrator may consider factors including whether dioxin/furan were 

detected at levels substantially below the emission standard in previous 

testing, and whether previous Method 0023 analyses detected low levels 

of dioxin/furan in the front half of the sampling train. 

(3) Sources that emit carbonaceous particulate matter, such as coal-fired 

boilers, and sources equipped with activated carbon injection, will be 

deemed not suitable for use of Method 23 unless the Permittee documents 

that there would not be a significant improvement in quality assurance 

with Method 0023A. 

VES 001566 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 55 of 134 

(ii) The Permittee must sample for a minimum of 3 hours, and collect a minimum 

sample volume of 2.5 dscm; 

(iii) The Pennittee may assume that nondetects are present at zero concentration. 

(b) Mercury. The Permittee must use Method 29 , provided in Aappendix A , 4 0 C.F.R. 

Ppart 60 , to demonstrate compliance with the emission standard for mercury. 

(c) Cadmium and lead. The Permittee must use Method 29 , provided in aAppendix A , 4 0 

C.F.R. Ppart 60 , to determine compliance with the emission standard for cadmium and 

lead (combined). 

(d) Arsenic, beryllium, and chromium. The Permittee must use Method 29 , provided in 

4 0 C.F.R. Ppart 60 , Aappendix A to determine compliance with the emission standard for 

arsenic, beryllium, and chromium (combined). 

(e) Hydrogen chloride and chlorine gas 

(i) Compliance with MAC T standards. /To determine compliance with the emission 

standard for hydrogen chloride and chlorine gas (combined), the Permittee must 

use: 

( A ) Method 26/26 A as provided in 4 0 C.F.R. Ppart 60 , ppendix A : or 

(B) Methods 32 0 or 321 as provided in 4 0 C.F.R. Ppart 63 , Aappendix A or 

(C) AST M D 6735-01 , Standard Test Method for Measurement of Gaseous 

Chlorides and Fluorides from Mineral Calcining Exhaust Sources—Impinger 

Method to measure emissions of hydrogen chloride, and Method 26/26 A to 

measure emissions of chlorine gas, provided that the Permittee follow the 

provisions in 4 0 C.F.R. § 63.1208(b)(5)(C)(l) through (6). 

( 1) A test must include three or more runs in which a pair of samples is 

obtained simultaneously for each run according to section 11.2.6 of AST M 

Method D6735-01 . 

( 2) The Permittee must calculate the test run standard deviation of each set of 

paired samples to quantify data precision, according to Equation 1 in 4 0 

C.F.R. § 63.1208(b)(5)(C)(2). 

( 3) The Permittee must calculate the test average relative standard deviation 

according to Equation 2 in 4 0 C.F.R. § 63.1208(b)(5)(i)(C)(3). 

(4) If RSDT A is greater than 2 0 percent, the data are invalid and the test must 

be repeated. 

VES 001567 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 56 of 134 

(5) The post-test analyte spike procedure of section 11.2.7 of AST M Method 

D6735-01 is conducted, and the percent recovery is calculated according 

to section 12.6 of AST M Method D6735-01. 

(6) If the percent recovery is between 70 percent and 130 percent, inclusive, 

the test is valid. J f the percent recovery is outside of this range, the data 

are considered invalid, and the test must be repeated. 

(ii) Compliance with risk-based limits under 40 C.F.R. § 63.1215. To demonstrate 

compliance with emission limits established under § 63.1215, the Permittee must 

use Method 26726A as provided in Aappendix A , 40 C.F.R. f Part 60, Method 320 

as provided in aAppendix A , 40 C.F.R. Ppart 63, Method 321 as provided in 40 

C.F.R. Ppart 63, Aappendix A or AST M D 6735-01, Standard Test Method for 

Measurement o f Gaseous Chlorides and Fluorides from Mineral Calcining 

Exhaust Sources—Impinger Method (following the provisions of 40 C.F.R. 

§ 63.1208(b)(5)(C)(l) through (6)), except for incinerators, boilers, and 

lightweight aggregate kilns, the Permittee must use Methods 320 or 321 as 

provided in 40 C.F.R. Ppart 63, Aappendix A or AST M D 6735-01 to measure 

hydrogen chloride, and Method 26/26A as provided in 40 C.F.R. Ppart 60, 

Aappendix A , to measure total chlorine, and calculate chlorine gas by difference 

if: 

(1) . The bromine/chlorine ratio in feedstreams is greater than 5 percent; or 

(2) _The sulfur/chlorine ratio in feedstreams is greater than 50 percent. 

(f) Particulate matter. The Permittee must use Methods 5 or 51, provided in 40 C.F.R. 

pPart 60, aAppendix A to demonstrate compliance with the emission standard for 

particulate matter. 

(g) Other Test Methods. The Permittee may use apphcable test methods in EP A 

Publication SW-846, as necessary to demonstrate compliance with requirements of this 

subpart, except as otherwise specified in 40 C.F.R. § 63.1208(b)(2)-(b)(6). 

(h) Feedstream analytical methods. The Permittee may use any reliable analytical 

method to determine feedstream concentrations of metals, chlorine, and other 

constituents. It is the Permittee's responsibility to ensure that the sampling and analysis 

procedures are unbiased, precise, and that the results are representative of the feedstream. 

(i) Opacity. Method 9, provided in 40 C.F.R. pPart 60, a Appendix A . 

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)] 

1. Summary of notification requirements, [40 C. F.R. § 63.1210(a)] 

V ES 001568 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 57 of 134 

{3^tev44i«A^ 

required notification procedures] 

(a) The Pennittee must submit the following notifications to the U.S. EPA : 

Reference Notification 

40 C.F.R. § 63.9(d) Notification that the source is subject to special 

compliance requirements 

40 C.F.R. § 63.9(j) Notification and documentation of any change in 

information already provided under 40 C.F.R. 

§63. 9 

40 C.F.R. §63.1206(b)(5) 

(i) 

Notification of changes in design, operation, or 

maintenance 

40 C.F.R. § 63.1206(c)(8) 

(iv) 

Notification of excessive bag leak detection system 

exceedances 

40 C.F.R. §§ 63.1207(e), 63.9(e), 

63.9(g)(1) and (3) 

Notification of performance test and continuous 

monitoring system evaluation, including the 

performance test plan and CM S performance 

evaluation plan* 

40 C.F.R. §§ 63.1210(d), 

63.12070), 

63.1207(k), 

63.1207(1), 63.9(h), 

63.10(d)(2) 

63.10(e)(2) 

Notification of compliance, including results of 

performance tests and continuous monitoring 

system performance evaluations 

* The Permittee may also be required on a case-by-case basis to submit a feedstream 

analysis plan under 40 C.F.R. § 63.1209(c)(3). 

(b) The Permittee must submit the following notifications to the U.S. EP A if the 

Pennittee requests or elects to comply with alternative requirements: 

Reference Notification, request, petition, or application 

40 C.F.R. § 63.9(f) The Permittee may request an adjustment of time 

periods or postmark deadlines for submittal and 

review of required information. 

40C.F.R. §63.10(e)(3)(ii) The Permittee may request approval to reduce the 

frequency of excess emissions and CM S 

performance reports. 

40C.F.R. § 63.10(f) The Permittee may request approval to waive 

recordkeeping or reporting requirements. 

VES 001569 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 58 of 134 

Reference Notification, request, petition, or application 

40 C.F.R. § 63.1206(b)(5)(i)(C) The Permittee may request approval to burn 

hazardous waste for more than 720 hours and for 

purposes other than testing or pretesting after 

making a change in the design or operation that 

could affect compliance with emission standards 

and prior to submitting revised Notification of 

ComplianceNOC. 

40 C.F.R. § 63.1206(b)(8)(iii)(B) If the Permittee elects to conduct particulate matter 

CEM S correlation testing and wishes to have 

federal particulate matter and opacity standards and 

associated operating limits waived during the 

testing, the Pennittee must notify the Administrator 

by submitting the conelation test plan for review 

and approval. 

40 C.F.R. § 63.1206(b)(8)(v) The Permittee may request approval to have the 

particulate matter and opacity standards and 

associated operating limits and conditions waived 

for more than 96 hours for a conelation test. 

40 C.F.R.-§ 63.1206(c)(2) 

00(C) 

The Permittee may request approval to make 

changes to the startup, shutdown, and malfunction 

plan. 

40 C.F.R. § 63.1206(c)(5)(i)(C) The Permittee may request an alternative means of 

control to provide control of combustion system 

leaks. 

40 C.F.R. § 63.1206(c)(5)(i)(D) The Permittee may request other techniques to 

prevent fugitive emissions without use of 

instantaneous pressure limits. 

40 C.F.R. §63.1207(d)(3) The Pennittee may request more than 60 days to 

complete a performance test if additional time is 

needed for reasons beyond its control. 

40C.F.R. §§ 63.1207(e)(3), 

63.7(h) 

The Permittee may request a time extension if the 

Administrator fails to approve or deny its test plan. 

40 C.F.R. § 63.1207(h)(2) The Permittee may request approval to waive 

cunent operating parameter limits during pretesting 

for more than 720 hours. 

40 C.F.R. § 63.1207(f)(1) 

(ii)(D) 

The Permittee may request approval to perform a 

reduced hazardous waste feedstream analysis for 

organic hazardous air pollutants if the reduced 

analysis continues to be representative of organic 

hazardous air pollutants in its hazardous waste 

feedstreams. 

40 C.F.R. § 63.1207(g)(2)(v) The Permittee may request approval to operate 

under a wider operating range for a parameter 

during confirmatory performance testing. 

VES 001570 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 59 of 134 

Reference Notification, request, petition, or application 

40 C.F.R. § 63.1207(i) The Permittee may request up to a 1-year time 

extension for conducting a performance test (other 

than the initial comprehensive performance test) to 

consolidate testing with other state or federallyrequired testing. 

40 C.F.R. § 63.1207(j)(4) Tlie Pennittee may request more than 90 days to 

submit a Notification of ComplianceNOC after 

completing a performance test if additional time is 

needed for reasons beyond its control. 

40C.F.R. § 63.12070X3) After failure of a performance test, the Permittee 

may request approval to burn hazardous waste for 

more than 720 hours and for purposes other than 

testing or pretesting. 

40 C.F.R. §§ 63.1209(a)(5), 

63.8(f) 

The Permittee may request: (1) approval of 

alternative monitoring methods for compliance with 

standards that are monitored with a CEMS ; and (2) 

approval to use a CEM S in lieu of operating 

parameter limits. 

40 C.F.R. § 63.1209(g)(1) The Permittee may request approval of: (1) 

alternatives to operating parameter monitoring 

requirements, except for standards that the 

Permittee must monitor with a continuous emission 

monitoring system fCEMS) and except for requests 

to use a CEM S in lieu of operating parameter 

limits; or (2) a waiver of an operating parameter 

limit. 

40C.F.R. § 63.1209(f)(1) The Permittee may request approval to extrapolate 

mercury feedrate limits. 

40 C.F.R. § 63.1209(n)(2) The Permittee may request approval to extrapolate 

semivolatile and low volatile metal feedrate limits. 

40 C.F.R. § 63.1211(d) The Permittee may request approval to use data 

compression techniques to record data on a less 

frequent basis than required by §63.1209. 

2. Notification of Ceompliance4740€4 J40 C.F.R. § 63.1210(d)]: 

(a) The NotifioationofComDliunceNOC status requirements of 40 C.F.R. § 63.9(h) 

apply, except that: 

(i) The notification is an Notification of ComplianoeNQC. rather than compliance 

status; 

(ii) The notification is required for the initial comprehensive perfonnance test and 

each subsequent comprehensive and confirmatory performance test; and 

VES 001571 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12, 2013 

Page: 60 of 134 

(iii) The Permittee must postmark the notification before the close of business on the 

90th day following completion of relevant compliance demonstration activity 

specified in Subpart EE E rather than the 60th day as required by 40 C.F.R. 

§ 63.9(h)(2)(H). 

(b) The Permittee must submit no later than October 10, 2008: [40 C.F.R. 71.6(c)(3)] 

(i) a report for the performance tests The test report must include the following 

information: 

(1) the raw sampling and analysis data; 

(2) the analyses of samples; 

(3) an example of each calculation performed; and 

(4) the 1-minute averages for each operating parameter. 

(iiT) ap NOC . 

(c) Upon postmark ofthe Notification of ComplianceNOC. the Permittee shall comply 

with the operating parameter limits identified in the Notification o f Compl ionceNOC. and 

the limits identified in the Documentation ol'ComplianceDOC or a previous Notification 

of-ComplianeeNOC are no longer applicable. 

(d) The Notification of ComplianceNOC requirements of 40 C.F.R. § 63.12070') also 

apply. 

3. Summary of reporting requirements under 40 C.F.R. Part. 63^ Subpart EE E [40 C.F.R. 

§ 63.1211(a)]: 

The Permittee must submit the following reports to the pennitting authority: 

Reference Report 

40 C.F.R. § 63.10(d)(5)(i) Periodic startup, shutdown, and malfunction 

reports. 

40 C.F.R. § 63.10(d)(5)(ii) Immediate startup, shutdown, and malfunction 

reports. 

40 C.F.R. § 63.10(e)(3) Excessive emissions and continuous monitoring 

system performance report and summary report. 

40 C.F.R. § 63.1206(c)(3)(vi) Excessive exceedance reports. 

40 C.F.R. § 63.1206(c)(4)(iv) Emergency safety vent opening reports. 

AWFC O Excessive exceedance reporting [40 C.F.R. § 63.1206(c)(3)(vi)]: 

(a) For each set of 10 exceedances of an emission standard or operating requirement 

while hazardous waste remains in the combustion chamber (i.e., when the hazardous 

VES 001572 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 61 of 134 

waste residence time has not transpired since the hazardous waste feed was cutoff) during 

a 60-day block period, the Permittee must submit to the Administrator, within five 

calendar days ofthe tenth exceedance, a written report documenting the exceedances, the 

results of the investigation, and the corrective measures taken. 

(b) On a case-by-case basis, the Administrator may require excessive exceedance 

reporting when fewer than 10 exceedances occur during a 60-day block period. 

5. Bag leak detection system [40 C.F.R. § 63.1206(c)(8)(iv)]: 

Excessive exceedances notification. _If the Permittee operates the combustor when the 

detector response exceeds the alarm set-point more than 5 percent of the time during any 

6-month block time period, the Permittee must submit to the Administrator within 30 

days o f the end of the 6-month block time period a notification that describes the causes 

of the exceedances and the revisions to the design, operation, or maintenance ofthe 

combustor or baghouse the Permittee is taking to minimize exceedances. To document 

compliance with these requirements the Pennittee must: 

(a) keep records of the date, time, and duration of each alarm, the time corrective action 

was initiated and completed, and a brief description of the cause of the alarm and the 

conective action taken; 

(b) record the percent of the operating time during each 6-month period that the alann 

sounds; 

(c) not count the alann time in calculating the operating time percentage, if inspection of 

the fabric filter demonstrates that no conective action is required; and 

(d) count each alarm as a minimum of 1 hour if conective action is required. 

6. Emergency Safety Vent reporting requirements [40 C.F.R. § 63.1206(c)(4)]: 

The Permittee must submit to the Administrator within 5 days of an ES V opening that 

results in failure to meet the emission standards of this subpart (as determined in 40 

C.F.R. § 63.1206(c)(4)(i)) a written report documenting the result ofthe investigation and 

conective measures taken. 

7. Periodic startup, shutdown, and malfunction reports. _[40 C.F.R. § 63.10(d)(5)(h)] 

If actions taken by the Permittee during a startup, shutdown, or malfunction of an 

affected source (including actions taken to conect a malfunction) are consistent with the 

procedures specified in the source's startup, shutdown, and malfunction plan (see 40 

C.F.R. § 63.6(e)(3)), and the startup or shutdown causes the source to exceed any 

applicable emission limitation in the relevant emission standards, the Permittee shall state 

such information in a startup, shutdown, and malfunction report. Actions taken to 

minimize emissions during such startups, shutdowns, and malfunctions shall be 

VES 001573 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 62 of 134 

summarized in the report and may be done in checklist form; if actions taken are the same 

for each event, only one checklist is necessary. Such a report shall also include the 

number, duration, and a brief description for each type of malfunction which occurred 

during the reporting period and which caused or may have caused any applicable 

emission limitation to be exceeded. .Reports shall be required only if a startup or 

shutdown caused the source to exceed any applicable emission limitation in the relevant 

emission standards, or if a malfunction occurred during the reporting period. The startup, 

shutdown, and malfunction report shall consist of a letter containing the name, title, and 

signature ofthe Permittee or other responsible official who is certifying its accuracy, that 

shall be submitted to the Administrator semiannually (or on a more frequent basis if 

specified otherwise in a relevant standard or as established otherwise by the permitting 

authority in the source's title V permit). _The startup, shutdown, and malfunction report 

shall be delivered or postmarked by the 30th day following the end of each calendar half 

or other calendar reporting period, as appropriate). If the Permittee is required to submit 

excess emissions and continuous monitoring system performance (or other periodic) 

reports under this part, the startup, shutdown, and malfunction reports required under this 

paragraph may be submitted simultaneously with the excess emissions and continuous 

monitoring system performance (or other) reports. If startup, shutdown, and malfunction 

reports are submitted with excess emissions and continuous monitoring system 

performance (or other periodic) reports, and the Permittee receives approval to reduce the 

frequency of reporting for the latter under 40 C.F.R. § 63.10(e), the frequency of 

reporting for the startup, shutdown, and malfunction reports also may be reduced if the 

Administrator does not object to the intended change. _The procedures to implement the 

allowance in the preceding sentence shall be the same as the procedures specified in 40 

C.F.R. § 63.10(e)(3). 

8. Immediate startup, shutdown, and malfunction reports. _[40 C.F.R. § 63.10(d)(5)(ii)] 

Notwithstanding the allowance to reduce the frequency of reporting for periodic startup, 

shutdown, and malfunction reports under § 63.10(d)(5)(i), any time an action taken by the 

Permittee during a startup or shutdown that caused the source to exceed any applicable 

emission limitation in the relevant emission standards, or malfunction (including actions 

taken to correct a malfunction) is not consistent with the procedures specified in the 

affected source's startup, shutdown, and malfunction plan, the Permittee shall report the 

actions taken for that event within 2 working days after commencing actions inconsistent 

with the plan followed by a letter within 7 working days after the end of the event. The 

immediate report required under 40 C.F.R. § 63.10(d)(5)(h) shall consist of a telephone 

call (or facsimile (FAX) transmission) to the Administrator within 2 working days after 

commencing actions inconsistent with the plan, and it shall be followed by a letter, 

delivered or postmarked within 7 working days after the end of the event, that contains 

the name, title, and signature of the Permittee or other responsible official who is 

certifying its accuracy, explaining the circumstances of the event, the reasons for not 

following the startup, shutdown, and malfunction plan, describing all excess emissions 

and/or parameter monitoring exceedances which are believed to have occurred (or could 

have occurred in the case of malfunctions), and actions taken to minimize emissions in 

conformance with § 63.6(e)(l)(i). 

VES 001574 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 63 of 134 

9. Notification of changes in design, operation, or maintenance [40 C.F.R. § 63.1206(b)(5)]. 

(a) The Pennittee must notify the Administrator at least 60 days prior to a change (as 

defined at 40 C.F.R. § 63.1206(b)(5)(iii)) to_the design, operation, or maintenance 

practices of the source in a manner that may adversely affect compliance with any 

emission standard that is not monitored with a CEMS , unless the Permittee documents 

circumstances that dictate that such prior notice is not reasonably feasible. The 

notification must include: 

(i) A description ofthe changes and which emission standards may be affected; and 

(ii) A comprehensive performance test schedule and test plan under the requirements 

of 40 C.F.R. § 63.1207(f) that will document compliance with the affected 

emission standard(s); 

(b) If the Pennittee detennines that a change will not adversely affect compliance 

with the emission standards or operating requirements, the Permittee must document the 

change in the operating record upon making such change. The Permittee must revise as 

necessary the performance test plan, Documentation of ComplianceDOC. Notification of 

C-offlpfianeeNOC, and start-up, shutdown, and malfunction plan to reflect these changes. 

10. Notification of perfonnance test and CM S perfonnance evaluation, and approval of test 

plan and CM S performance evaluation plan. [40 C.F.R. § 63.1207(e)] 

(a) The provisions of 40 C.F.R. §§ 63.7(b) and (c) and 63.8(e) apply, except: 

(i) Comprehensive performance test. The Permittee must submit to the 

Administrator a notification of its intention to conduct a comprehensive 

performance test and CM S performance evaluation and a site-specific test plan 

and CM S performance evaluation test plan at least 1 year before the performance 

test and performance evaluation are scheduled to begin. 

(ii) The Permittee must submit to the Administrator a notification of its intention to 

conduct the comprehensive performance test at least 60 calendar days before the 

test is scheduled to begin. 

(iii) ^Confirmatory performance test. /The Permittee must submit to the Administrator a 

notification of its intention to conduct a confirmatory performance test and CM S 

performance evaluation and a site-specific test plan and CM S performance 

evaluation test plan at least 60 calendar days before the performance test is 

scheduled to begin. The Administrator will notify the Permittee of approval or 

intent to deny approval of the site-specific test plan and CM S performance 

evaluation test plan within 30 calendar days after receipt of the original test plans. 

V ES 001575 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

| Expires: October 12,2013 

Page: 64 of 134 

(b) The Permittee must make its site-specific test plans and CM S performance 

evaluation test plan available to the public for review no later than 60 calendar days 

before initiation of the test. _The Permittee must issue a public notice to all persons on its 

facility/public mailing list (developed pursuant to 40 C.F.R. §§ 71.1 l(d)(3)(i)(E) and 

124.10(c)(l)(ix)) announcing the availability of the test plans and the location where the 

test plans are available for review. The test plans must be accessible to the public for 60 

calendar days, beginning on the date that the Pennittee issues its public notice. "The 

location must be unrestricted and provide access to the public during reasonable hours 

and provide a means for the public to obtain copies. _The notification must include the 

following information at a minimum: 

(i) The name and telephone number of the source's contact person; 

(ii) The name and telephone number of the regulatory agency's contact person; 

(iii) The location where the test plans and any necessary supporting documentation 

can be reviewed and copied; 

(iv) The time period for which the test plans will be available for public review; and 

(v) A n expected time period for commencement and completion ofthe perfonnance 

test and CM S performance evaluation test. 

(c) Petitions for time extension if Administrator fails to approve or deny test plans. _The 

Permittee may petition the Administrator under 40 C.F.R. § 63.7(h) to obtain a "waiver" 

of any performance test—initial or periodic performance test; comprehensive or 

confirmatory test. _The "waiver" would be implemented as an extension of time to 

conduct the performance test at a later date. 

(i) _Qualifications for the waiver. 

(A) The Permittee may not petition the Administrator for a waiver under this 

section if the Administrator has issued a notification of intent to deny its test 

plan(s) under 40 C.F.R. § 63.7(c)(3)(i)(B); 

(B) The Permittee must submit a site-specific emissions testing plan and a 

continuous monitoring system performance evaluation test plan at least 1 year 

before a comprehensive performance test is scheduled to begin as required by 40 

C.F.R. § 63.1207(c)(1), or at least 60 days before a confirmatory performance test 

is scheduled to begin as required by 40 C.F.R. § 63.1207(d). /The test plans must 

include all required documentation, including the substantive content 

requirements of 40 C.F.R. §§ 63.1207(f) and 63.8(e); and 

(C) The Pennittee must make a good faith effort to accommodate the 

Administrator's comments on the test plans. 

V ES 001576 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 65 of 134 

(ii) Procedures for obtaining a waiver and duration of the waiver: 

(A) The Permittee must submit to the Administrator a waiver petition or request 

to renew the petition under 40 C.F.R. § 63.7(h) separately for each source at least 

60 days prior to the scheduled date ofthe performance test; 

(B) The Permittee may submit a revised petition to renew the waiver under 40 

C.F.R. § 63.7(h)(3)(iii) at least 60 days prior to the end date ofthe most recently 

approved waiver petition; 

(iii) Content of the waiver. 

(A) The Permittee must provide documentation to enable the Administrator to 

determine that the source is meeting the relevant standard(s) on a continuous 

basis, as required by 40 C.F.R. § 63.7(h)(2). For extension requests for the initial 

comprehensive performance test, the Permittee must submit its DoewwHsntatwtt-efi^omplianoeDOC to assist the Administrator in making this detennination. 

(B) The Permittee must include in the petition information justifying its request 

for a waiver, such as the technical or economic infeasibility, or the impracticality, 

of the affected source performing the required test, as required by 40 C.F.R. 

§ 63.7(h)(3)(iii). 

(iv) Public notice. At the same time that the Permittee submits its petition to the 

Administrator, the Permittee must notify the public (e.g., distribute a notice to the 

facility/public mailing list developed pursuant to 40 C.F.R. §§71.1 l(d)(3)(i)(E) 

and 124.10(c)(l)(ix)) of its petition to waive a performance test. The notification 

must include all of the following information at a minimum: 

(A) The name and telephone number of the source'/s contact person; 

(B) The name and telephone number ofthe regulatory agency!ls contact person; 

(C) The date the source submitted its site-specific performance test plan and CM S 

perfonnance evaluation test plans; and 

(D) The length of time requested for the waiver. 

11. Time extension for subsequent performance tests. J40 C.F.R. § 63.1207(i)] After the 

initial comprehensive perfonnance test, the Pennittee may request up to a 1-year time 

extension for conducting a comprehensive or confirmatory performance test to 

consolidate perfonnance testing with other state or federally required emission testing, or 

for other reasons deemed acceptable by the Administrator. If the Administrator grants a 

time extension for a comprehensive performance test, the deadlines for commencing the 

next comprehensive and confirmatory tests are based on the date that the subject 

comprehensive performance test commences. 

VES 001577 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 66 of 134 

(a) The Permittee must submit in writing to the permitting authority any request for a 

time extension for conducting a performance test. 

(b) The Permittee must include in the request for an extension for conducting a 

performance test the following: 

(i) A description of the reasons for requesting the time extension; 

(ii) The date by which the Permittee will commence performance testing. 

12. Notification of ( compliance [40 C.F.R. § 63.1207(j)] 

(a) Comprehensive performance test. 

(i) Except as provided by 40 C.F.R. § 63.1207(j)(4) and (j)(5), within 90 days of 

completion of a comprehensive performance test, the Permittee must postmark a 

Notification of ComplianceNOC documenting compliance with the emission 

standards and continuous monitoring system requirements, and identifying 

operating parameter limits under 40 C.F.R. § 63.1209. 

(ii) Upon postmark of the NotiOeation of ComplianceNOC. the Permittee must 

comply with all operating requirements specified in the Nerifk44tiof>-of 

ComplianceNOC in lieu of the limits specified in the Documentation of 

C^nnf>j4a-HueUO(7 required under 40 C.F.R. § 63.1211(c). 

(b) Confirmatory performance test. .Except as provided by 40 C.F.R. § 63.1207(j)(4), 

within 90 days of completion of a confirmatory performance test, the Permittee must 

postmark a Notification of ComplianeeNOC documenting compliance or noncompliance 

with the applicable dioxin/furan emission standard. 

(c) The Permittee must comply with the additional requirements pertaining to the 

Notification of ComplianeoNOC (e.g., the Permittee must include results of performance 

tests in the Notification of CompuanceMjC) at 40 C.F.R. §§ 63.7(g), 63.9(h), and 

63.1210(d). 

(d) Time extension. The Permittee may submit a written request to the Administrator for 

a time extension documenting that, for reasons beyond its control, the Permittee may not 

be able to meet the 90-day deadline for submitting the Notificotion of ComplianceNOC 

after completion of testing. /The Administrator will determine whether a time extension is 

warranted. 

(e) Early compliance. If the Permittee conducts the initial comprehensive performance 

test prior to the compliance date, the Permittee must postmark the NotifTieatien-ef 

CemptirmeeN QC within 90 days of completion of the performance test or by the 

compliance date, whichever is later. 

V ES 001578 
I Veolia Environmental Services 

PermitNo.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 67 of 134 

13. Failure to submit a timely m»tiricatk)n uiV-omplianceNOC. .[40 C.F.R. 36.1207(k)] 

(a) If the Permittee fails to postmark a Notification of ComplianceNOC by the specified 

date, the Permittee immediately must cease burning hazardous waste. 

(b) Prior to submitting a revised Notification of ComplianceNOC as provided by 40 

C.F.R. § 63.1207(k)(3), the Pennittee may burn hazardous waste only for the purpose of 

pretesting or comprehensive perfonnance testing and only for a maximum of 720 hours 

(renewable at the discretion of the Administrator). 

(c) The Permittee must submit to the Administrator a Notification of ComplianeeNOC; 

subsequent to a new comprehensive performance test before resuming hazardous waste 

burning. 

14. Failure of performance test [40 C.F.R. § 63.1207(1)] 

(a) Comprehensive performance test. The provisions of 40 C.F.R. § 63.1207(1) do not 

apply to the initial comprehensive performance test if the Permittee conducts the test 

prior to its compliance date. 

(i) If the Permittee detennines (based on CE M recordings, results of analyses of 

stack samples, or results of CM S perfonnance evaluations) that the Pennittee has 

exceeded any emission standard during a comprehensive performance test for a 

mode of operation, the Permittee must cease hazardous waste burning 

immediately under that mode of operation. The Permittee must make this 

determination within 90 days following completion of the performance test. 

(ii) If the Permittee failed to demonstrate compliance with the emission standards for 

any mode of operation: 

(A) Prior to submitting a revised Notification of GomplianoeNOC as provided by 

40 C.F.R. § 63.1207(l)(l)(ii)(C), the Permittee may burn hazardous waste only for 

the purpose of pretesting or comprehensive perfonnance testing under revised 

operating conditions, and only for a maximum of 720 hours (renewable at the 

discretion of the Administrator), except as provided by 40 C.F.R. § 63.1207(1)(3); 

(B) The Pennittee must conduct a comprehensive performance test under revised 

operating conditions following the requirements for performance testing of this 

section; and 

(C) The Permittee must submit to the Administrator a N«ta44Auit»Hwrf 

C-omplftmeeNOC subsequent to the new comprehensive performance test. 

(b) Confirmatory performance test. The Permittee must determine within 90 days of the 

completion of a performance test whether it has complied with the dioxm/furan emission 

VES 001579 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 68 of 134 

standard. If the Permittee determines (based on CE M recordings, results of analyses of 

stack samples, or results of CM S performance evaluations) that it has failed the 

dioxin/furan emission standard during a confirmatory performance test, the Permittee 

immediately must cease burning hazardous waste. To bum hazardous waste following 

the failure to comply with the dioxin/furan emission standard: 

(i) __The Permittee must submit to the Administrator for review and approval a test 

plan to conduct a comprehensive performance test to identify revised limits on the 

applicable dioxin/furan operating parameters specified in 40 C.F.R. § 63.1209(k); 

(ii) The Permittee must submit to the Administrator a NeUfteatson-efComphaneeNOC with the dioxin/furan emission standard under the provisions of 

40 C.F.R. § 63.1207Q), ( k) and (1). The Permittee must include in the N<rt+fe«ot» 

of-C4>fflf4ianeeMOC the revised limits on the applicable dioxin/furan operating 

parameters specified in 40 C.F.R. § 63.1209(k); and 

(iii) Until the Notification of ComplianeeNOC is submitted, the Permittee must not 

bum hazardous waste except for purposes of pretesting or confirmatory 

performance testing, and for a maximum of 720 hours (renewable at the discretion 

of the Administrator), except as provided by 40 C.F.R. § 63.1207(1)(3). 

(c) The Permittee may petition the Administrator to obtain written approval to burn 

hazardous waste prior to submitting a Notification of ComplianceNOC for purposes other 

than testing or pretesting. The Permittee must specify operating requirements, including 

limits on operating parameters, that the Permittee determines will ensure compliance with 

the emission standards of this subpart based on available information including data from 

the failed performance test. The Administrator wil l review, modify as necessary, and 

approve if warranted the interim operating requirements. A n approval of interim 

operating requirements will include a schedule for submitting a iMyBH%a4*aan-t4 

Compl ianeeNOC. 

15. Summary of recordkeeping requirements under Subpart EE E [40 C.F.R. § 63.1211(b)]: 

The Permittee must retain the following in the operating records applicable to the 

Hazardous Waste Incinerators operated at this site: 

Reference Document, Data, or Information 

40 C.F.R. §§ 63.1200, 

63.10(b) and (c) 

General. Information required to document and maintain 

compliance with the regulations of Subpart EEE , including data 

recorded by CMSs, and copies of all notifications, reports, plans, 

and other documents submitted to the Administrator. 

40 C.F.R. 

§§ 63.1204(d)(1)(h), 

63.1220(d)(1)(h) 

Documentation of mode of operation changes for cement kilns with 

in4ineraw mills. 

40 C.F.R. Documentation of compliance with the emission averaging 

VES 001580 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 69 of 134 

Reference Document, Data, or Information 

§§ 63.1204(d)(2)(ii), 

63.1220(d)(2)(ii) 

requirements for cement kilns with in-line raw mills. 

40 C.F.R. 

§§ 63.1204(e)(2)(h), 

63.1220(e)(2)(h) 

Documentation of compliance with the emission averaging 

requirements for preheater or preheater/precalciner kilns with dual 

stacks. 

40 C.F.R. 

§ 63.1206(b)(1)(H) 

If the Permittee elects to comply with all applicable requirements 

and standards promulgated under authority of the Clean Air Act, 

including Sections 112 and 129, in lieu of the requirements of 

Subpart EE E when not burning hazardous waste, it must document 

in the operating record that it is in compliance with those 

requirements. 

40 C.F.R. 

§ 63.1206(b)(5)(ii) 

Documentation that a change will not adversely affect compliance 

with the emission standards or operating requirements. 

40 C.F.R. 

§ 63.1206(b)(ll) 

Calculation of hazardous waste residence time. 

40 C.F.R. § 63.1206(c)(2) SSMP. 

40 C.F.R. 

§ 63.1206(c)(2)(v)(A) 

Documentation of the Permittee's investigation and evaluation of 

excessive exceedances during malfunctions. 

40 C.F.R. 

§ 63.1206(c)(3)(v) 

Corrective measures for any automatic waste feed cutoff that results 

in an exceedance of an emission standard or OPL. 

40 C.F.R. 

§63.1206(c)(3)(vii) 

Documentation and results of the automatic waste feed cutoff 

operability testing. 

40 C.F.R. 

§ 63.1206(c)(4)(H) 

Emergency safety vent operating plan. 

40 C.F.R. 

§ 63.1206(c)(4)(iii) 

Corrective measures for any emergency safety vent opening. 

40 C.F.R. 

§ 63.1206(c)(5)(H) 

Method used for control of combustion system leaks. 

40 C.F.R. § 63.1206(c)(6) Operator training and certification program. 

40 C.F.R. 

§63.1206(c)(7)(i)(D) 

Operation and maintenance plan. 

40 C.F.R. § 63.1209(c)(2) Feedstream analysis plan. 

40 C.F.R. 

§ 63.1209(k)(6)(Hi), 

(k)(7)(ii), (k)(9)(ii), 

(o)(4)(iii) 

Documentation that a substitute activated carbon, D/F formation 

reaction inhibitor, or dry scrubber sorbent will provide the same 

level of control as the original material. 

40 C.F.R. 

§ 63.1209(k)(7)(i)(C) 

Results of carbon bed performance monitoring. 

40 C.F.R. § 63.1209(q) Documentation of changes in modes of operation. 

40C.F.R. § 63.1211(c) Documentation of ComplianceDOC. 

16. Documentation of Compliance [40 C.F.R. § 63.1211(c)]: 

V ES 001581 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 70 of 134 

(a) The Permittee must develop and include in the operating record a Doeaflwntotion of 

CompliaweeDOC. /The Permittee is not subject to this requirement, however, if the 

Pennittee submits a Notification of (4>mp[ianceNOC under 40 C.F.R. § 63.1207(j) prior 

to the compliance date. JJpon inclusion ofthe Documentation of CornplianceDQC in the 

operating record, hazardous waste burning incinerators are no longer subject to 

compliance with the previously applicable Notification of ComplianceNOC. 

(b) The Documentation of ComplianceDOC must identify the applicable emission 

standards under 40 C.F.R. Ppart 63, Ssubpart EE E and the limits on the operating 

parameters under 40 C.F.R. § 63.1209 that will ensure compliance with those emission 

standards. 

(c) The Permittee must include a signed and dated certification in the Deeufflenfemen-el" 

ComplianaeDOC that: 

(i) Required GFnVFnCFMS and CM S are installed, calibrated, and continuously 

operating in compliance with the requirements of Subpart EEE ; and 

(ii) /Based on an engineering evaluation prepared under the Permittee's direction or 

supervision in accordance with a system designed to ensure that qualified 

personnel properly gathered and evaluated the infonnation and supporting 

documentation, and considering at a minimum the design, operation, and 

maintenance characteristics of the combustor and emissions control equipment, 

the types, quantities, and characteristics of feedstreams, and available emissions 

data: 

(A) The Permittee is in compliance with the emission standards of this subpart; 

and 

(B) The limits on the operating parameters under 40 C.F.R. § 63.1209 to ensure 

compliance with the emission standards of 40 C.F.R. Pari 63, Subpart EEE . 

(d) The Permittee must comply with the emission standards and operating parameter 

limits specified in the Doeumentation-ef CemplianceDOC. 

17. Calculation of hazardous waste residence time. The Permittee must calculate the 

hazardous waste residence time and include the calculation in the performance test plan 

under 40 C.F.R. § 63.1207(f) and the operating record. The Permittee must also provide 

the hazardous waste residence time in the Dmmmmhj»m^^f4^mpU»AimDOC under 40 

C.F.R. § 63.1211(c) and the Notification of ComplitmeeNyC under 40 C.F.R. 

§§ 63.1207(j) and 63.1210(d). [40 C.F.R. § 63.1206(b)(l 1)] 

18. Documenting compliance with the standards based on performance testing. [40 C.F.R. 

§ 63.1206(b)(12)] 

V ES 001582 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 71 of 134 

(a) The Permittee must conduct a minimum of three runs of a performance test required 

under 40 C.F.R. § 63.1207 to document compliance with the emission standards of this 

subpart. 

(b) The Permittee must document compliance with the emission standards based on the 

arithmetic average of the emission results of each run, except that the Pennittee must 

document compliance with the destruction and removal effieienovDRB standard for each 

run ofthe comprehensive performance test individually. 

19. Compliance with the carbon monoxide and hydrocarbon emission standards. [40 C.F.R. 

1206(b)(6)] 

If the Permittee elects to comply with the carbon monoxide and hydrocarbon emissions 

standards of 40 C.F.R. Ppart 63, sSubpart EE E by documenting continuous compliance 

with the carbon monoxide standard using a continuous emissions monitoring system and 

documenting compliance with the hydrocarbon standard during the des+rwmon-and 

removal efficiency {DRE? perfonnance test or its equivalent, and a DR E test performed 

pursuant to 40 C.F.R. § 63.1207(c)(2) is acceptable as documentation of compliance with 

the DRE standard, the Permittee may use the highest hourly rolling average hydrocarbon 

level achieved during the DR E test runs to document compliance with the hydrocarbon 

standard. A n acceptable DR E test is any test for which the data and results are determined 

to meet quality assurance objectives (on a site-specific basis) such that the results 

adequately demonstrate compliance with the DR E standard. 

20. Compliance with the Destruction and Removal Efficiency -1 >R F t standard. [40 C.F.R. 

§ 63.1206(b)(7)] 

(a) The Permittee must document compliance with the DR E standard under this subpart 

only once provided that the Permittee does not modify the source after the DR E test in a 

manner that could affect the ability of the source to achieve the DR E standard. 

(b) The Permittee may use any DR E test data that documents that its source achieves the 

required level of DR E provided: 

(i) The Permittee has not modified the design or operation of its source in a manner 

that could affect the ability of its source to achieve the DR E standard since the 

D R E test was performed; and, 

(ii) The DR E test data meet quality assurance objectives determined on a site-specific 

basis. 

21. The Permittee shall maintain all records for five calendar years and make them available 

at all times for inspection by EPA , Illinois EPA , local agencies, or their duly authorized 

representatives. [40 C.F.R. § 71.6(a)(3)(i)(B)] 

V ES 001583 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 72 of 134 

2.2 Material Processing Areas 

(A) Emission Limitations and Standards .40 CFR §71.6(a)(1)] 

1. 40 C.F.R. Part 63, Subpart D D 

40 C.F.R. § 63.688 requirements: 

_For a container having a design capacity greater than 0.1 m 3 and less than or equal to 

0.46 m3, the owner or operator must control air emissions from the container in 

accordance with the standards for Container Level 1 controls as specified in 40 C.F.R. 

Ppart 63, Ssubpart PP. -National Emission Standards for Containers." _[40 C.F.R. § 

63.688(b)(l)(i)] 

2. 40 C.F.R. Part 63, Subpart PP i -National Emission Standards for Containers40 C.F.R. § 63.922(b)(1) through (b)(3) defines Container Level 1 controls as one ofthe 

following: 

(a) A container that meets the applicable U.S. Department of Transportation (DOT) 

regulations on packaging hazardous materials for transportation as specified in paragraph 

40 C.F.R. § 63.922(f). 

(b) A container equipped with a cover and closure devices that form a continuous barrier 

over the container openings such that when the cover and closure devices are secured in 

the closed position there are no visible holes, gaps, or other open spaces into the interior 

of the container. _The cover may be a separate cover installed on the container (e.g., a lid 

on a drum, a suitably secured tarp on a roll-off box) or may be an integral part of the 

container structural design (e.g., a bulk cargo container equipped with a screw-type cap). 

(c) A n open-top container in which an organic vapor-suppressing barrier is placed on or 

over the regulated-material in the container such that no regulated-material is exposed to 

the atmosphere. _One example of such a barrier is application of a suitable organic-vapor 

suppressing foam. 

3. No person shall cause or allow the discharge of more than 3.6 kg/hr (8 lb/hr) of organic 

material into the atmosphere from any emission unit, except as provided in 35 IA C 

219.302, 219.303 or 219.304 and the following exception: If no odor nuisance exists this 

limitation shall apply only to photochemically reactive material [35 IAC 219.301]. 

4. (a) No person shall cause or allow the emission of smoke or other particulate matter, with 

an opacity greater than 30 percent. _[35 IAC 212.123] 

(b) The emission of smoke or other particulate matter from any such emission source may 

have an opacity greater than 30 percent but not greater than 60 percent for a period or 

periods aggregating 8 minutes in any 60 minute period, provided that such more opaque 

V ES 001584 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 73 of 134 

emissions permitted during any 60 minute period shall occur from only one such 

emission source located within a 305 m (1000 ft) radius from the center point of any 

other such emission source owned or operated by such person, and provided further that 

such more opaque emissions permitted from each such emission source shall be limited 

to 3 times in any 24 hour period. .[35 IA C 212.123] 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

1. The affected waste processing units are not subject to 40 C.F.R. pPart 64, Compliance 

Assurance Monitoring (CAM ) for Major Stationary Sources, because the units MP1 , 

MP2 , and the labpack do not use an add-on control device to achieve compliance with an 

emission limitation or standard. 

2. The conveyor systems associated with MP 1 and MP 2 are not subject to the requirements 

o f 40 C.F.R. Ppart 63, Subpart D D for transfer systems, because this equipment is used in 

the conveyance of material using a container. [40 C.F.R. § 63.681] 

3. Units MP1 , MP 2 and the lab pack repack are not subject to the requirements of 40 C.F.R. 

Ppart 61, Ssubpart B B because this source is not part of a benzene production facility. 

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)] 

The affected waste processing units are subject to the following control requirements and 

work practices established by 40 C.F.R. § 63.922(c), (d) and (e): 

1. A container used to meet the requirements of either 40 C.F.R. § 63.922(b)(2) or (b)(3) 

shall be equipped with covers and closure devices, as applicable to the container, that are 

composed of suitable materials to minimize exposure ofthe regulated-material to the 

atmosphere and to maintain the equipment integrity for as long as it is in service. Factors 

to be considered when selecting the materials for and designing the cover and closure 

devices shall include: organic vapor permeability, the effects of contact with the material 

or its vapor managed in the container; the effects of outdoor exposure to wind, moisture, 

and sunlight; and the operating practices used for container on which the cover is 

installed.. [40 C.F.R. § 63.922(c)] 

2. Whenever a regulated-material is in a container using Container Level 1 controls, the 

owner or operator shall install all covers and closure devices for the container, and secure 

and maintain each closure device in the closed position except as follows: 

(a) Opening of a closure device or cover is allowed for the purpose of adding material to 

the container as follows: 

(i) In the case when the container is filled to the intended final level in one 

continuous operation, the owner or operator shall promptly secure the closure 

devices in the closed position and install the covers, as applicable to the container, 

upon conclusion ofthe filling operation. 

V ES 001585 
I Veolia Environmental Services 

Pennit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 74 of 134 

(ii) In the case when discrete quantities or batches of material intermittently are added 

to the container over a period of time, the owner or operator shall promptly secure 

the closure devices in the closed position and install covers, as applicable to the 

container, upon either: the container being filled to the intended final level; the 

completion of a batch loading after which no additional material will be added to 

the container within 15 minutes; the person performing the loading operation 

leaves the immediate vicinity of the container; or the shutdown of the process 

generating the material being added to the container, whichever condition occurs 

first. 

(b) Opening of a closure device or cover is allowed for the purpose of removing material 

from the container as follows: 

(i) For the purpose of meeting the requirements of this section, an empty container as 

defined in 40 CFR 63.921 maybe open to the atmosphere at any time (e.g., covers 

and closure devices are not required to be secured in the closed position on an 

empty container). 

(ii) _In the case when discrete quantities or batches of material are removed from the 

container but the container does not meet the conditions to be an empty container 

as defined in 40 CF R 63.921, the owner or operator shall promptly secure the 

closure devices in the closed position and install covers, as applicable to the 

container, upon the completion of a batch removal after which no additional 

material will be removed from the container within 15 minutes, or the person 

performing the unloading operation leaves the immediate vicinity of the 

container, whichever condition occurs first. 

(c) Opening of a closure device or cover is allowed when access inside the container is 

needed to perform routine activities other than transfer of regulated-material. Examples 

of such activities include those times when a worker needs to open a port to measure 

the depth of or sample the material in the container, or when a worker needs to open a 

manhole hatch to access equipment inside the container. Following completion of the 

activity, the owner or operator shall promptly secure the closure device in the closed 

position or reinstall the cover, as applicable to the container. 

(d) Opening of a spring-loaded pressure-vacuum relief valve, conservation vent, or 

similar type of pressure relief device which vents to the atmosphere is allowed during 

normal operations for the purpose of maintaining the container internal pressure in 

accordance with the container design specifications. The device shall be designed to 

operate with no detectable organic emissions when the device is secured in the closed 

position. The settings at which the device opens shall be established such that the 

device remains in the closed position whenever the container internal pressure is within 

the internal pressure operating range determined by the owner or operator based on 

container manufacturer recommendations, applicable regulations, fire protection and 

prevention codes, standard engineering codes and practices, or other requirements for 

V ES 001586 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 75 of 134 

the safe handling of flammable, ignitable, explosive, reactive, or hazardous materials. 

Examples of normal operating conditions that may require these devices to open are 

during those times when the container internal pressure exceeds the internal pressure 

operating range for the container as a result of loading operations or diurnal ambient 

temperature fluctuations. 

(e) Opening of a safety device, as defined in §63.921, is allowed at any time conditions 

require it to do so to avoid an unsafe condition. [40 C.F.R. § 63.922(d)] 

3. 40 C.F.R. § 63.922(e): 

The owner or operator shall inspect containers using Container Level 1 controls in 

accordance with the procedures specified in 40 C.F.R. § 63.926(a). 

4. 40 C.F.R. § 63.922(f): 

For the purpose of compliance with 40 C.F.R. § 63.922(b)(1), the Permittee shall use 

containers that meet the applicable U.S. DO T regulations on packaging hazardous 

materials for transportation as follows: 

(i) The container must meet the applicable requirements specified i n 49 C.F.R. pPart 

178 "Specifications for Packagings" or 49 C.F.R. Ppart 179 "Specifications for 

Tank Cars." 

(ii) Regulated-material is managed in the container in accordance with the applicable 

requirements specified in 49 C.F.R. Ppart 107, Staibpart B "Exemptions;" 49 

C.F.R. Ppart 172 "Hazardous Materials Table, Special Provisions, Hazardous 

Materials Communications, Emergency Response Information, and Training 

Requirements;" 49 C.F.R. Ppart 173 "Shippers—General Requirements for 

Shipments and Packaging;" and 49 C.F.R. Ppart 180 "Continuing Qualification 

and Maintenance of Packagings." 

(iii) . For the purpose of complying with 40 C.F.R. Pan 63, sSubpart PP, no exceptions 

to the 49 C.F.R. p Part 178 or Ppart 179 regulations are allowed, except as 

provided in section 2.2(C)(4)(iv) of this permit, below. 

(iv) For a lab pack that is managed in accordance with the requirements of 49 C.F.R. 

Ppart 178 for the purpose of complying with 40 C.F.R. Pars 673, ^Subpart PP, an 

owner or operator may comply with the exceptions for those packagings specified 

in49C.F.R. § 173.12(b). 

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)] 

1. Procedures to determine that there are no detectable organic emissions for the purpose of 

complying with 40 C.F.R. Ppart 63, Ssubpart PP: the Permittee shall conduct the test 

annually in accordance with the procedures specified in Method 21 of 40 C.F.R. Ppart 60, 

VES 001587 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 76 of 134 

Aappendix A . J_he Permittee shall check each potential leak interface (i.e., a location 

where organic vapor leakage could occur) on the cover and associated closure devices. 

Potential leak interfaces that are associated with covers and closure devices include, but 

are not limited to: the interface of the cover and its foundation mounting; the periphery of 

any opening on the cover and its associated closure device; and the sealing seat interface 

on a spring-loaded pressure-relief valve._ [40 C.F.R. § 63.925(a)] 

2. The Permittee shall perform the test when the unit contains a material having a total 

organic concentration representative of the range of concentrations for the materials 

expected to be managed in the unit. During the test, the cover and closure devices shall 

be secured in the closed position.. [40 C.F.R. § 63.925(a)] 

3. The detection instrument shall meet the performance criteria of Method 21 of 40 C.F.R. 

Ppart 60, Aappendix A , except the instrument response factor criteria in section 3.1.2(a) 

of Method 21 shall be the criteria for the average composition of the organic constituents 

in the material placed in the unit, not for each individual organic constituent. .[40 C.F.R. 

§ 63.925(a)] 

4. The detection instrument shall be calibrated before use on each day o f its use by the 

procedures specified in Method 21 of 40 C.F.R. Ppart 60, Aappendix A . .[40 C.F.R. § 

63.925(a)] 

5. Calibration gases shall be as follows: 

(a) Zero air (less than 10 ppmv hydrocarbon in air); and 

(b) A mixture of methane or n-hexane in air at a concentration of approximately, but less 

than 10,000 ppmv. .[40 C.F.R. § 63.925] 

6. The Permittee may choose to adjust or not adjust the detection instrument readings to 

account for the background organic concentration level. .If the Permittee chooses to 

adjust the instrument readings for the background level, the background level value must 

be determined according to the procedures in Method 21 of 40 C.F.R. Ppart 60, 

Aappendix A . .[40 CFR 63.925] 

7. Each potential leak interface shall be checked by traversing the instrument probe around 

the potential leak interface as close to the interface as possible, as described in Method 

21. In the case when the configuration ofthe cover or closure device prevents a complete 

traverse of the interface, all accessible portions of the interface shall be sampled. .In the 

case when the configuration of the closure device prevents any sampling at the interface 

and the device is equipped with an enclosed extension or horn (e.g., some pressure relief 

devices), the instrument probe inlet shall be placed at approximately the center of the 

exhaust area to the atmosphere.. [40 C.F.R. § 63.925] 

V ES 001588 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 77 of 134 

8. The Permittee must determine if a potential leak interface operates with no detectable 

emissions using the applicable procedure specified in section 2.2(D)(8)(a) or (b), below. 

[40 C.F.R. § 63.925] 

(a) If the Pennittee chooses not to adjust the detection instrument readings for the 

background organic concentration level, then the maximum organic concentration value 

measured by the detection instrument is compared directly to the applicable value for the 

potential leak interface as specified in 40 C.F.R. § 63.925(a)(9). 

(b) If the Permittee chooses to adjust the detection instrument readings for the 

background organic concentration level, the value of the arithmetic difference between 

the maximum organic concentration value measured by the instrument and the 

background organic concentration value as determined in 40 C.F.R. § 63.925(a)(6) is 

compared with the applicable value for the potential leak interface as specified in 

paragraph 40 C.F.R. § 63.925 (a)(9). 

9. A potential leak interface is determined to operate with no detectable emissions using the 

applicable criteria specified in section 2.2(D)(9)(a) and (b), below. 

(a) For a potential leak interface other than a seal around a shaft that passes through a 

cover opening, the potential leak interface is determined to operate with no detectable 

organic emissions if the organic concentration value determined in section 2.2(D)(8), 

above, is less than 500 ppmv. 

(b) For a seal around a shaft that passes through a cover opening, the potential leak 

interface is determined to operate with no detectable organic emissions if the organic 

concentration value determined in section 2.2(D)(8), above, is less than 10,000 ppmv. 

[40 C.F.R. § 63.925(a)(9)] 

10. Procedure for detennining a container to be vapor-tight for the purpose of complying 

with 40 C.F.R. Part 63, sSubpart PP. _[40 C.F.R. § 63.925] 

(a) The Permittee shall perform the test in accordance with Method 27 of 40 C.F.R. pPart 

60, Aappendix A . 

(b) T-ehTne Permittee shall use a pressure measurement device that has a precision of ± 

2.5 mm water and that is capable o f measuring above the pressure at which the container 

is to be tested for vapor tightness. 

(c) If the test results determined by Method 27 indicate that the container sustains a 

pressure change less than or equal to 750 Pascals within 5 minutes after it is pressurized 

to a minimum of 4,500 Pascals, then the container is determined to be vapor-tight. 

11. Owners and operators of containers using either Container Level 1 or Container Level 2 

controls shall inspect the container and its cover and closure devices as follows, as 

described in section 2.2(d)(l l)(a)-(c), below: 

V ES 001589 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 78 of 134 

(a) _ In the case when a regulated-material already is in the container at the time the 

Permittee first accepts possession of the container at the facility site and the container is 

not emptied (i.e., does not meet the conditions for an empty container as defmed in 

63.921) within 24 hours after the container has been accepted at the facility site, the 

Permittee shall visually inspect the container and its cover and closure devices to check 

for visible cracks, holes, gaps, or other open spaces into the interior ofthe container when 

the cover and closure devices are secured in the closed position. This inspection of the 

container must be conducted on or before the date that the container is accepted at the 

facility (i.e., the date that the container becomes subject to the standards under this 

subpart). For the purpose of this requirement, the date of acceptance is the date of 

signature ofthe Permittee on the manifest or shipping papers accompanying the 

container. If a defect is detected, the owner or operator shall repair the defect in 

accordance with the requirements o f 40 C.F.R. § 63.926(a)(3). 

(b) hi the case when a container filled or partially filled with regulated-material remains 

unopened at the facility site for a period of 1 year or more, the Pennittee shall visually 

inspect the container and its cover and closure devices initially and thereafter, at least 

once every calendar year, to check for visible cracks, holes, gaps, or other open spaces 

into the interior of the container when the cover and closure devices are secured in the 

closed position. If a defect is detected, the Permittee shall repair the defect in accordance 

with the requirements of paragraph 40 C.F.R. § 63.926(a)(3). 

(c) When a defect is detected for the container, cover, or closure devices, the Permittee 

must either empty the regulated-material from the defective container in accordance with 

40 C.F.R. § 63.926(a)(3)(i) or repair the defective container in accordance with 40 C.F.R. 

§ 63.926(a)(3)(h). 

(h-) If the owner or operator elects to empty the regulated-material from the defective 

container, the Permittee must remove the regulated-material from the defective 

container to meet the conditions for an empty container (as defined in 40 C.F.R. 

§ 63.921) and transfer the removed regulated-material to either a container that 

meets the applicable standards under this subpart or to a tank, process, or 

treatment unit that meets the applicable standards under the subpart referencing 

this subpart. .Transfer of the regulated-material must be completed no later than 5 

calendar days after detection of the defect. _The emptied defective container must 

be repaired, destroyed, or used for purposes other than management of regulatedmaterial. 

(iir) If the Permittee elects not to empty the regulated-material from the defective 

container, the Permittee must repair the defective container. First efforts at repair 

of the defect must be made no later than 24 hours after detection and repair must 

be completed as soon as possible but no later than 5 calendar days after detection. 

If repair of a defect cannot be completed within 5 calendar days, then the 

regulated-material must be emptied from the container and the container must not 

be used to manage regulated-material until the defect is repaired. 

V ES 001590 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12, 2013 

Page: 79 of 134 

12. The Permittee shall visually survey units MP1 , MP2 , and the labpack each day for the 

presence of visible emissions or fugitive emissions of particulate matter. [40 C.F.R. § 

71.6(a)(3)(i)(B)] 

(a) If the Permittee identifies any visible emissions or fugitive emissions of particulate 

matter by visual observation, the Permittee shall: 

(iv) Immediately, upon conclusion ofthe visual observation, investigate the source 

and reason for the presence of visible emissions or fugitive emissions; and 

(iir) As soon as practicable, take appropriate corrective action. 

(b-)_—If the corrective actions undertaken do not eliminate the visible or fugitive 

emissions, the Permittee shall, within 24 hours of the initial survey, shall conduct a test 

using EP A Reference Method 9 (see 40 C.F.R. Ppart 60, Aappendix A). 

(i-) If any ofthe visible emissions observations indicate visible emissions greater than 

20% opacity, the Permittee shall conduct daily visible emissions observations, for 

thirty minutes, of the emission point in question until two consecutive daily 

observations indicate visible emissions of 20% opacity or less. 

(iiAjJf the Method 9 visible emissions observation, or if two consecutive daily 

observations, indicate visible emissions of 20% opacity or less, the Permittee shall 

conduct weekly visible emissions observations of the emission point for three 

additional weeks. 

(E) Recordkeeping and Reporting [40 C.F.R. §71.6(a)(3)] 

1. The Permittee shall promptly notify the permitting authority of deviations ofthe affected 

waste processing units with the permit requirements, pursuant to 

40 C.F.R. §71.6(a)(3)(iii)(B). Reports shall describe the probable cause of such 

deviations, and any corrective actions or preventive measures taken. 

2. The Permittee shall maintain the following records of the fugitive emissions: 

(a) _Details of each visual survey or visible emissions observation, including date, time, 

observer and results for each emission unit and any other pollutant emitting activity; 

(b) _Date, time and type of any investigation conducted; 

(c) Findings ofthe investigation, including the reasons for the presence of visible 

emissions or fugitive emissions of particulate matter; 

(d) _Date, time and type of corrective actions taken; 

V ES 001591 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 80 of 134 

(e)_Results of any Method 9 visible emissions observations conducted on the source of 

visible or fugitive emissions. [40 CF R § 71.6(a)(3)(i)(B)] 

3. VOM/HA P emissions from units MP1 , MP2 , and the labpack shall be calculated based 

on the most recent version ofthe TANK S program. .[40 C.F.R. § 71.6(a)(3)(i)(B)] 

2.3 Drum Crusher 

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)] 

1. The Permittee shall not cause or allow the emission of particulate matter into the 

atmosphere in any one hour period from any new process emission unit, either alone or in 

combination with the emission of particulate matter from all other similar process 

emission units for which construction or modification commenced on or after April 14, 

1972, at a source or premises, exceeds the allowable emission rates specified in 

subsection (c) of 35 IA C 212.321 [35 IAC 212.321(a)], 

2. The Pennittee shall not cause or allow the discharge of more than 3.6 kg/hr (8 lbs/hr) of 

organic material into the atmosphere from any emission unit, except as provided in 35 

I A C 219.302, 219.303, and 219.304 and the following exception: If no odor nuisance 

exists this limitation shall apply only to photochemically reactive material [35 IA C 

219.301]. 

3. Pursuant to 35 IAC 212.123(a), the Pennittee shall not cause or allow the emission of 

smoke or other particulate matter, with an opacity greater than 30 percent, into the 

atmosphere from any emission unit other than those emission units subject to the 

requirements of 35 IA C 212.122, except as allowed by 35 IAC 212.123(b) and 212.124. 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

| 1. The drum crusher is not subject to 40 C.F.R. Ppart 64, Compliance Assurance Monitoring 

for Major Stationary Sources, because the affected drum crusher does not use an add-on 

control device to achieve compliance with an emission limitation or standard. 

(C) Work Practice and Operational Requirements [40 CFR § 71.6(a)(1)] 

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)] 

The Permittee shall visually survey the drum crusher each day for the presence of visible 

emissions or fugitive emissions of particulate matter. _[40 CF R § 71.6(a)(3)(i)(B)] 

1. If the observations conducted identify any visible emissions or fugitive emissions of 

particulate matter, the Permittee shall: 

V ES 001592 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 81 of 134 

(a) _Immediately, upon conclusion ofthe visual observation, investigate the source and 

reason for the presence of visible emissions or fugitive emissions; and 

(b) A s soon as practicable, take appropriate corrective action. 

2. If the corrective actions undertaken pursuant to section 2.3(D)(2), above, do not eliminate 

the visible or fugitive emissions, the Permittee shall, within 24 hours ofthe initial survey, 

conduct a test using EP A Reference Method 9 (see 40 C.F.R. Ppart 60, Aappendix A). 

(a) _If any ofthe visible emissions observations indicate visible emissions greater than 

20% opacity, the Permittee shall conduct Method 9 visible emissions observations ofthe 

emission point in question for thirty minutes each day, until two consecutive daily 

observations indicate visible emissions of 20% opacity or less. 

(b) If the Method 9 visible emissions observation or if two consecutive daily observations 

indicate visible emissions of 20% opacity or less, the Permittee shall conduct weekly 

visible emissions observations of the emission point for three additional weeks. 

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)] 

1. The Permittee shall maintain records of the total number of drums crushed (drums/hour 

and drums/year) for the drum crusher, pursuant to 40 C.F.R. § 71,6(a)(i)(3)(B): 

2. The Pennittee shall calculate and keep records of VO M emissions from the drum crusher 

based on the emission factor equal to 0.0914 lb VOM/ 1 drum crushed. This emission 

factor is based on the conservative assumption that only methanol residue (with the 

highest vapor pressure) is released from the crushed drums. 

3. The Permittee shall maintain the following records ofthe fugitive emissions: [40 C.FJC § 

71.6(a)(3)(i)(B)] 

(a) _Details of each visual survey or visible ernissions observation, including date, time, 

observer and results for each emission unit and any other pollutant emitting activity; 

(b) _Date, time and type of any investigation conducted; 

(c) _Findings of the investigation, including the reasons for the presence of visible 

emissions or fugitive emissions of particulate matter; 

(d) _Date, time and type of conective actions taken; 

(e) _Results of any Method 9 visible emissions observations conducted on the source of 

visible or fugitive emissions. 

V ES 001593 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 82 of 134 

2.4 Storage Tanks 

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)] 

1. Each affected liquid waste storage tank is subject to the emission standards and 

requirements established in 40 C.F.R. Ppart 61, Ssubpart FF^ -National Emission 

Standards for Hazardous Air Pollutants for Benzene Waste Operations/- when benzenecontaining waste is stored in the tank. 

(a)_For each affected liquid waste storage tank, the owner or operator shall install, 

operate, and maintain a fixed-roof and closed-vent system that routes all organic vapors 

vented from the tank to a control device, pursuant to 40 C.F.R. §§ 61.343 and 61.349. 

(ir) The fixed roof shall meet the following requirements [40 C.F.R. § 61.343(a)(1)]: 

(A) The cover and all openings (e.g., access hatches, sampling ports, and gauge 

wells) shall be designed to operate with no detectable emissions as indicated by 

an instrument reading less than 500 parts per million by volume (ppmv) above 

background, as determined initially, and thereafter at least once per year, by the 

methods specified in 40 C.F.R. § 61.355(h). 

(B) Each opening shall be maintained in a closed, sealed position (e.g., covered 

by a lid that is gasketed and latched) at all times that waste is in the tank except 

when it is necessary to use the opening for waste sampling or removal, or for 

equipment inspection, maintenance, or repair. 

(iir) The closed-vent system and control device shall be designed and operated in 

accordance with the following requirements of 40 C.F.R. § 61.349: 

(A) The closed-vent system shalh be designed to operate with no detectable 

emissions as indicated by an instrument reading of less than 500 ppmv above 

background, as determined initially, and thereafter at least once per year, by the 

methods specified in 40 C.F.R. § 61.355(h). 

(B) The control device shall be designed and operated in accordance with the 

following conditions: 

A vapor recovery system (e.g., a carbon adsorption system or a condenser) shall 

recover or control the organic emissions vented to it with an efficiency of 95 

weight percent or greater, or shall recover or control the benzene emissions 

vented to it with an efficiency of 98 weight percent or greater. 

(C) Tthe Permittee shall operate each closed-vent system and control device used 

to comply with 40 C.F.R. Ppart 61, Ssubpart FF at all times that waste is placed in 

the waste management unit vented to the control device, except when 

V ES 001594 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 83 of 134 

maintenance or repair of the waste management unit cannot be completed without 

a shutdown of the control device. 

2. Each affected liquid waste storage tank is subject to the emission standards and 

requirements established in 40 C.F.R. pi 'art 63, Ssubpart DD . "National Emission 

Standards for Hazardous Air Pollutants from Off-Site Waste and Recovery Operations\ 

when non-benzene waste is stored in the tank. 

Although the affected waste liquid storage tanks are subject to 40 C.F.R. ppart 63, 

Ssubpart DD , the provision of 40 C.F.R. § 63.683(b)(2)(i) exempts the tanks (defined by 

40 C.F.R. Ppart 63, Ssubpart D D as off-site material management units) from the control 

requirements of 40 C.F.R. § 63.683(b)(1) if such units are subject to another subpart or 

40 C.F.R. Ppart 63 or 61 and the HA P emissions (identified in Table 1 of 40 C.F.R. 'Part. 

63i_Subpart DD) are controlled. 

3. The affected liquid waste storage tanks 300, 302, 304, 306, 308 and 310 are subject to 40 

C.F.R. Ppart 60, Ssubpart Kb . t/40 C.F.R. § 60.112b(a)(3) 4: 

(a) The closed vent system shall be designed to collect all VO C vapors and gases 

discharged from the storage vessel and operated with no detectable emissions as indicated 

by an instrument reading of less than 500 ppm above background and visual inspections, 

as determined in 40 C.F.R. § 60.485(b). 

(b) The control device shall be designed and operated to reduce inlet VO C emissions by 

95 percent or greater. 

4. Each affected liquid waste storage tank is subject to 35 IA C 219.129(f) and 35 IA C 

219.122(b). 

(a) /The Pennittee shall maintain readily accessible records ofthe dimension and analysis 

of the capacity of each affected liquid waste storage tank. [35 IA C 219.129(f)] 

(b) Each affected liquid waste storage tank should be equipped with a permanent 

submerged loading pipe. _[35 IAC 219.122(b)] 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

1. The affected liquid waste storage tanks are not subject to control requirements of 35 IA C 

219.120,219.121 and 219.123, because these storage tanks are less than 151 m 3 (40,000 

gal) capacity [35 IAC 219.119, 219.121,219.123(a)(2)]. 

2. The affected liquid waste storage tanks are not subject to 40 C.F.R. Ppart 64, Compliance 

Assurance Monitoring (C-AMpfor Major Stationary Sources, because the affected liquid 

wastes storage tanks are subject to a NESHA P proposed after November 15, 1990. 

[40 C.F.R. § 64.2(b)(l)(i). 

V ES 001595 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 84 of 134 

(C) Work Practice and Operational Requirements [40 CFR § 71.6(a)(1)] 

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)] 

1. Pursuant to requirements of 40 C.F.R. § 61.343(a)(1), the Permittee must test annually 

the cover and all opening components of each fixed-roof storage tank using the methods 

specified in 40 C.F.R. § 61.355(h) in the absence of the detectable emissions.. The 

Permittee must monitor the pressure continuously to ensure that the pressure in the tank 

remains below atmospheric pressure. 

2. Pursuant to requirements of 40 C.F.R. § 61.349, the Permittee must test annually the 

closed-vent using the methods specified in 40 C.F.R. § 61.355(h). 

3. The Permitee shall comply with the following monitoring requirements as established in 

40 C.F.R. § 61.354(d): 

(a)_For a carbon adsorption system that does not regenerate the carbon bed directly on 

site in the control device (e.g., a carbon canister), the Permittee must monitor on a regular 

schedule either the concentration level of the organic compounds or the concentration 

level of benzene in the exhaust vent stream from the carbon adsorption system, and must 

replace the existing carbon with fresh carbon immediately when carbon breakthrough is 

indicated. _The Permittee must monitor the device on a daily basis or at intervals no 

greater than 20 percent of the design carbon replacement interval, whichever is greater. 

A s an alternative to conducting this monitoring, the Permittee may replace the carbon in 

the carbon adsorption system with fresh carbon at a regular predetermined time interval 

that is less than the carbon replacement interval that is determined by the maximum 

design flow rate and either the organic concentration or the benzene concentration in the 

gas stream vented to the carbon adsorption system. 

4. If a breakthrough does not occur within 365 days of operation on a high BT U tank, the 

Permittee must replace the carbon. If a breakthrough does not occur within 3 years of 

operation on a low BT U tank, the Permittee must replace the carbon._ [40 C.F.R. 

§71.6(a)(3)(i)(B)] 

5. The Permittee shall comply with the following inspection requirements as established in 

40C.F.R. § 61.349(f) and (g): 

(a) The Permittee must visually inspect each closed-vent system and control device 

quarterly. The visual inspection shall include inspection of ductwork and piping and 

connections to covers and control devices for evidence o f visible defects, such as holes in 

ductwork or piping and loose comiections. 

(b) Except as provided in 40 C.F.R. § 61.350, if the Permittee observes visible defects 

during an inspection, or if the Pennittee identifies other problems or measures detectable 

emissions, the Permittee must make a first effort to repair the closed-vent system and 

control device as soon as practicable, but no later than 5 calendar days after detection. 

V ES 001596 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 85 of 134 

The Permittee must complete the repair no later than 15 calendar days after the emissions 

are detected or the visible defect is observed. 

6. The Permittee shall also inspect the presence and condition ofthe submerged loading 

pipes from the top during the quarterly inspections and a physical inspection every five 

years. .[40 C.F.R. § 71.6(a)(3)(i)(B)] 

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)] 

1. Requirements of 40 C.F.R. § 61.356 (benzene waste operations): 

(a) /The Permittee shall maintain engineering design documentation for all control 

equipment used in accordance with 50 C.F.R. §§ 61.343 through 61.347 that is installed 

on the waste management unit. The Permittee shall retain the documentation for the life 

of the control equipment. The Permittee shall maintain the control device records 

required by 40 C.F.R. § 61.356(f)[40 C.F.R. § 61.356(d)]. 

(b) The Permittee shall maintain the following records on a closed-vent system and 

control device used in accordance with 40 C.F.R. § 61.349, pursuant to 40 C.F.R. 

§ 61.356(f). The Permittee shall retain the documentation for the life of the control 

device: 

(V) A statement signed and dated by the Permittee certifying that the closed-vent 

system and control device is designed to operate at the documented performance 

level when the waste management unit vented to the control device is or would be 

operating at the highest load or capacity expected to occur. 

(hV) .Specifications, drawings, schematics, and piping and instrumentation diagrams 

prepared by the owner or operator, or the control device manufacturer or vendor 

that describe the control device design based on acceptable engineering texts. 

The design analysis shall address the following vent stream characteristics and 

control device operating parameters: 

For a carbon adsorption system that does not regenerate the carbon bed directly 

on-site in the control device, such as a carbon canister, the design analysis shall 

consider the vent stream composition, constituent concentration, flow rate, 

relative humidity, and temperature. The design analysis shall also establish the 

design exhaust vent stream organic compound concentration level or the design 

exhaust vent stream benzene concentration level, capacity of carbon bed, type and 

working capacity of activated carbon used for carbon bed, and design carbon 

replacement interval based on the total carbon working capacity of the control 

device and source operating schedule. 

(c) For each control device, the Permittee shall maintain documentation that includes the 

following information regarding the control device operation [40 C.F.R. § 61.356(j)]: 

V ES 001597 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

| Expires: October 12,2013 

Page: 86 of 134 

(ir) Dates of startup and shutdown of the closed-vent system and control device. 

(iir) A description ofthe operating parameter (or parameters) to be monitored to 

ensure that the control device will be operated in conformance with these 

standards and the control device's design specifications and an explanation of the 

criteria used for selection of that parameter (or parameters). The Permittee shall 

keep this documentation for the life of the control device. 

(iiir) Periods when the closed-vent system and control device are not operated as 

designed including all periods and the duration when: 

(A) An y valve car-seal or closure mechanism required under 40 C.F.R. 

§ 61.349(a)(1)(h) is broken or the by-pass line valve position has changed. 

(B) The flow monitoring devices required under 40 C.F.R. § 61.349(a)(1)(h) 

indicate that vapors are not routed to the control device as required. 

(ivr) If the Permittee uses a carbon adsorber that is not regenerated directly on site in 

the control device, then the Permittee shall maintain records of dates and times 

when the control device is monitored, when breakthrough is measured, and shall 

record the date and time that the existing carbon in the control device is replaced 

with fresh carbon. 

2. Requirements of 40 C.F.R. § 60.115b(c) (NSPS): 

The Permittee must keep the following records on control equipment installed in 

accordance with 40 C.F.R. § 60.112b (a)(3) or (b)(1) (closed vent system and control 

device other than a flare) for the life of the control equipment: 

(a) A copy of the operating plan and a record of the measured values of the parameters 

monitored in accordance with 40 C.F.R. § 60.113b(c)(2)^ .The Permittee must operate the 

closed vent system and control device and monitor the parameters ofthe closed vent 

system and control device in accordance with the operating plan submitted to the 

Administrator i n accordance with 40 C.F.R. § 60.113b(c)(l), unless the plan was 

modified by the Administrator during the review process. In this case, the modified plan 

applies. 

3. Other requirements: [40 C.F.R. § 71.6(a)(3)] 

The Permittee must maintain the following records: 

(a) Total organic liquid wastes processed in gallons per month and gallons per year; 

(b) Average VOM/HA P content of received wastes, (percent by weight) 

V ES 001598 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 87 of 134 

(c) Average vapor pressure of received liquid wastes; 

(d) Records ofthe size (capacity) of the affected liquid wastes storage tanks; and 

(e) Records of all inspections performed. 

2.5 Bulk Feed Building 

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)] 

1. The affected bulk solid waste storage facility is subject to 40 C.F.R. Ppart 61, Ssubpart 

FFj. "National Emission Standards for Hazardous Air Pollutants for Benzene Waste 

Operations-,, when the storage pits are in "benzene" service. 

2. 40 C.F.R. pPart 61, Ssubpart FF: 

For the affected bulk solid waste storage facihty, the Pennittee shall install, operate, and 

maintain a fixed-roof and closed-vent system that routes all organic vapors vented from 

the tank to a control device. .[40 C.F.R. ££_61.343 and 61.349]. 

(a) The Permittee must install, operate, and maintain an enclosure and closed-vent system 

that routes all organic vapors vented from the tank, located inside the enclosure, to a 

control device. [40 C.F.R. § 61.343(a)(2)] 

(b) The Permittee must meet the following requirements for its control device that 

controls air pollutant emissions by using an enclosure vented through a closed-vent 

system to the control device: 40 C.F.R. § 61.343(e)(1) through (e)(4): 

(iz) The tank must be located inside a total enclosure. The enclosure must be 

designed and operated in accordance with the criteria for a pennanent total 

enclosure as specified in "Procedure T—Criteria for and Verification of a 

Permanent or Temporary Total Enclosure" in 40 C.F.R. § 52.741, Aappendix B. 

The enclosure may have permanent or temporary openings to allow worker 

access; passage of material into or out ofthe enclosure by conveyor, vehicles, or 

other mechanical means; entry of permanent mechanical or electrical equipment; 

or direct airflow into the enclosure. The owner or operator must perfonn the 

verification procedure for the enclosure as specified in section 5.0 of Procedure T 

initially when the enclosure is first installed and, thereafter, annually. A facility 

that has conducted an initial comphance demonstration and that performs annual 

compliance demonstrations in accordance with the requirements for Tank Level 2 

control requirements at 40 C.F.R. §§ 264.1084(f) or 265(i) is not required to make 

repeat demonstrations of initial and continuous compliance for the purposes of 

this subpart. 

V ES 001599 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 88 of 134 

(iir) The enclosure must be vented through a closed-vent system to a control device 

that is designed and operated in accordance with the standards for control devices 

specified in 40 C.F.R. § 61.349. 

(iii) The Permittee may install and operate safety devices, as defined in 40 C.F.R. 

pi 'art 61, Ssubpart FF, as necessary, on any enclosure, closed-vent system, or 

control device used to comply with the requirements of 40 C.F.R. § 61.343(e)(1) 

and (e)(2). 

(c) The Pennittee must design and operate the closed-vent system and control device in 

accordance with the following requirements of 40 C.F.R. § 61.349: 

(ir) The Permittee must design the closed-vent system to operate with no detectable 

emissions as indicated by an instrument reading of less than 500 ppmv above 

background. 

(iir) The Pennittee must design and operate the control device so that the vapor 

recovery system (e.g., a carbon adsorption system or a condenser) shall recover or 

control the organic emissions vented to it with an efficiency of 95 weight percent 

or greater, or shall recover or control the benzene emissions vented to it with an 

efficiency of 98 weight percent or greater. 

(iiir) 'The Pennittee shall operate each closed-vent system and control device used to 

comply with 40 C.F.R. Ppart 61, Ssubpart FF at all times when waste is placed in 

the waste management unit, except when maintenance or repair of the waste 

management unit cannot be completed without a shutdown of the control device. 

3. The bulk sohd waste storage facility is subject to 40 C.F.R. Ppart 63, Ssubpart DD . 

-National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and 

Recovery Operations^ wherever any waste is stored in the storage pits. 

Although the bulk solid waste storage facihty is subject to 40 C.F.R. Ppart 63, Ssubpart 

D D , this unit (defined by Subpart D D as off-site material management units) is exempt 

from the control requirements of 40 C.F.R. § 63.683(b)(1) if the units are subject to 

another subpart under 40 C.F.R. Ppart 61 or 63, and the Permittee is controlling the HA P 

listed in Table 1 of this 40 C.F.R. Ppart 63, Ssubpart D D that are emitted from the unit in 

compliance with the provisions specified in the other applicable subpart of 40 C.F.R. 

pPart 61 or 63. [40 C.F.R. § 63.683(b)(2)(i)]. 

4. 35 IAC 212.321(b)(1): 

The Pennittee shall not cause or allow the emission of particulate matter into the 

atmosphere in any one hour period from any new process emission unit, either alone or in 

combination with the emission of particulate matter from all other similar process 

emission units for which construction or modification commenced on or after April 14, 

V ES 001600 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 89 of 134 

1972, at a source or premises, exceeds the allowable emission rates specified in 

subsection (c) of 35 IAC 212.321 [35 IAC 212.321(a)]. 

5. 35 IAC 212.123(a): 

The Permittee shall not cause or allow the emission of smoke or other particulate matter, 

with an opacity greater than 30 percent, into the atmosphere from any emission unit other 

than those emission units subject to the requirements of 35 IAC 212.122, except as 

allowed by 35 IAC 212.123(b) and 212.124. 

6. 35 IAC Part 219, Subpart G: 

(a) The Permittee shall not cause or allow the discharge of more than 3.6 kg/hr (8 lbs/hr) 

of organic material into the atmosphere from any emission source, except as provided in 

Sections 219.302,219.303, 219.304 and the following exception: If no odor nuisance 

exists the limitation of this Subpart shall apply only to photochemically reactive materiaL 

[35 IA C 219.301]. 

(b) Emissions of organic material in excess of those permitted by 35 IAC 219.301 are 

allowable if such emissions are controlled by a vapor recovery system which adsorbs at 

least 85 percent of the total uncontrolled organic material that would otherwise be 

emitted to the atmosphere^ [35 IA C 219.302(b)]. 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

The affected bulk solid waste storage facility is not subject to 40 C.F.R. Ppart 64, 

Compliance Assurance Monitoring (CAM ) for Major Stationary Sources,, at this timer 

because the potential pre-control device emissions are less than major source levels as 

defined in 40 C.F.R. § 64.2(a)(3). 

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)] 

1. Except during times when bulk solid wastes are unloaded into the pits, all doors of the 

building shall be closed and all operations shall be enclosed inside the building. [40 

C.F.R. § 71.6(a)(1)] 

2. The enclosed building where bulk solid waste is accumulated shall be operated under 

permanent negative pressure. [40 C.F.R. § 71.6(a)(1)] 

(D) Monitoring and Testing [40 C.F.R. §71.6(a)(3)(i)(A)] 

1. The Permittee must test annually the cover and all opening components of each fixedroof storage tank using the methods specified in 40 C.F.R. § 61.355(h) in the absence of 

the detectable emissions. [40 C.F.R. § 61.343(a)(1)]. 

V ES 001601 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

| Expires: October 12,2013 

Page: 90 of 134 

2. The Permittee must test annually the closed-vent using the methods specified in 40 

C.F.R. § 61.355(h). [40 C.F.R. § 61.349]. 

3. The Permittee shall visually survey the bulk feed building each day for the presence of 

visible emissions or fugitive emissions of particulate matter. [40 C.F.R. § 

71.6(a)(3)(i)(B)] 

(a) _If the Permittee identifies through observations any visible emissions or fugitive 

emissions of particulate matter, the Permittee shall: 

(ir) Immediately, upon conclusion of the visual observation, investigate the source 

and reason for the presence of visible emissions or fugitive emissions; and 

(iir) As soon as practicable, take appropriate corrective action. 

(b) If the corrective actions undertaken do not eliminate the visible or fugitive emissions, 

the Permittee, within 24 hours ofthe initial survey, shall conduct a test using EP A 

Reference Method 9 (see 40 C.F.R. Ppart 60, Aappendix A). 

(ir) If any of the visible emissions observations indicate visible emissions greater than 

20% opacity, the Permittee shall conduct daily visible emissions observations, for 

thirty minutes, of the emission point in question until two consecutive daily 

observations indicate visible emissions of 20% opacity or less. 

(iir)_If the Method 9 visible emissions observation, or if two consecutive daily 

observations, indicate visible emissions of 20% opacity or less, the Pennittee shall 

conduct weekly visible emissions observations ofthe emission point for three 

additional weeks. 

4. The Pennittee must design and operate the enclosure for the affected bulk solid waste 

storage facility in accordance with the criteria for a permanent total enclosure as specified 

in "Procedure T—Criteria for and Verification of a Permanent or Temporary Total 

Enclosure" in 40 C.F.R. § 52.741, aAppendix B._ The Pennittee must perfonn annually 

the verification procedure for the enclosure as specified in section 5.0 of Procedure T. [40 

C.F.R. § 61.343(e)] 

5. The Permittee shall perform the following monitoring procedures, as required by 40 

C.F.R. § 61.354(c): 

The Permittee, on the basis of being subject to the requirements in 40 C.F.R. § 61.349, 

shall install, calibrate, maintain, and operate according to the manufacturer's 

specifications, a device to continuously monitor the control device operation as specified 

in below: 

V ES 001602 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 91 of 134 

For a carbon adsorption system that does not regenerate the carbon bed directly on site in 

the control device (e.g., a carbon canister), the concentration level of the organic 

compounds or the concentration level of benzene in the exhaust vent stream from the 

carbon adsorption system shall be monitored on a regular schedule, and the existing 

carbon shall be replaced with fresh carbon immediately when carbon breakthrough is 

indicated. The device shall be monitored on a daily basis or at intervals no greater than 

20 percent of the design carbon replacement interval, whichever is greater. 

6. The Permittee shall maintain an average facial velocity of at least 200 ft/min flowing into 

the enclosure at all natural draft openings in the building. The Permittee shall annually 

demonstrate the facial velocity according to Procedure T - Criteria for and Verification 

of a Permanent or Temporary Total Enclosure, 40 C.FJC §_52.741, Appendix B. [40 

C.F.R. § 71.6(a)(3)(i)(B)] 

7. The Permittee shall perform the following monitoring procedures: [40 C.F.R. § 61.349] 

The closed-vent system: 

(a) The Permittee shall visually inspect each closed-vent system and control device upon 

effectiveness of this permit and quarterly thereafter. The visual inspection shall include 

inspection of ductwork and piping and connections to covers and control devices for 

evidence of visible defects, such as holes in ductwork or piping and loose connections. 

[40 C.F.R. §61.349(f)] 

(b) Except as provided in 40 C.F.R. § 61.350, if the Permittee observes visible defects 

during an inspection, or if the Permittee identifies other problems or measures detectable 

emissions, the Permittee must make a first effort to repair the closed-vent system and 

control device as soon as practicable, but no later than 5 calendar days after detection. Te 

Permittee shall complete repairs no later than 15 calendar days after the emissions are 

detected or the visible defect is observed.. [40 C.F.R. § 61.349(g)]. 

(c) The Permittee shall monitor any control device used to comply with 40 C.F..R. 

§ 61.349(h)] in accordance 40 C.F.R. § 61.354(c). _[40 C.F.R. § 61.349(h)] 

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)] 

1. Recordkeeping required by 40 C.F.R. § 61.356: 

(a) The Permittee shall maintain for the life of the control device the following records 

for the closed-vent system and control device it uses in accordance with 40 C.F.R. 

§ 61.349(f): 

(i-) A statement signed and dated by the Permittee certifying that the closed-vent 

system and control device is designed to operate at the documented performance 

level when the waste management unit vented to the control device is or would be 

V ES 001603 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 92 of 134 

operating at the highest load or capacity expected to occur.. [40 C.F.R. 

§ 61.356(f)] 

(hV) If the Pennittee uses engineering calculations to detennine control device 

performance in accordance with 40 C.F.R. § 61.349(c), then a design analysis for 

the control device that includes, for example: 

Specifications, drawings, schematics, and piping and instrumentation diagrams 

prepared by the owner or operator, or the control device manufacturer or vendor 

that describe the control device design based on acceptable engineering texts. 

The design analysis shall address the following vent stream characteristics and 

control device operatingparameters: [40 C.F.R. § 61.356(f)] 

For a carbon adsorption system that does not regenerate the carbon bed directly 

on-site in the control device, such as a carbon canister, the design analysis shall 

consider the vent stream composition, constituent concentration, flow rate, 

relative humidity, and temperature. The design analysis shall also establish the 

design exhaust vent stream organic compound concentration level or the design 

exhaust vent stream benzene concentration level, capacity of carbon bed, type and 

working capacity of activated carbon used for carbon bed, and design carbon 

replacement interval based on the total carbon working capacity of the control 

device and source operating schedule. 

(iii) The Permittee shall maintain a record for each visual inspection required by 40 

C.F.R. §§ 61.343 through 61.347 that identifies a problem (such as a broken seal, 

gap or other problem) which could result in benzene emissions. The record shall 

include the date of the inspection, waste management unit and control equipment 

location where the problem is identified, a description of the problem, a 

description of the corrective action taken, and the date the corrective action was 

completed. [40 C.F.R. § 61.356(g)]. 

(iv) The Permittee shall maintain a record for each test of no detectable emissions 

required by 40 C.F.R. §§ 61.343 through 61.347 and 61.349. The record shall 

include the following information: date the test is performed, background level 

measured during test, and maximum concentration indicated by the instrument 

reading measured for each potential leak interface. If detectable emissions are 

measured at a leak interface, then the record shall also include the waste 

management unit, control equipment, and leak interface location where detectable 

emissions were measured, a description of the problem, a description ofthe 

conective action taken, and the date the conective action was completed. 

[40 C.F.R. §61.356(h)]. 

(VT) For each control device, the Permittee shall maintain documentation that includes 

the following information regarding the control device operation: [40 C.F.R. 

§ 61.356(j)] 

V ES 001604 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 93 of 134 

(A) Dates of startup and shutdown of the closed-vent system and control device. 

(B) A description of the operating parameter (or parameters) to be monitored to 

ensure that the control device will be operated in conformance with these 

standards and the control device's design specifications and an explanation of the 

criteria used for selection of that parameter (or parameters). The Permittee shall 

keep this documentation for the life of the control device. 

(C) Periods when the closed-vent system and control device are not operated as 

designed, including all periods and the duration when: 

(1) An y valve car-seal or closure mechanism required under 40 C.F.R. 

§ 61349(a)(1)(h) is broken or the by-pass line valve position has changed. 

(2) The flow monitoring devices required under 40 C.F.R. § 61.349(a)(1)(h) 

indicate that vapors are not routed to the control device as required. 

(VIT)_lf the Permittee uses a carbon adsorber that is not regenerated directly on site in 

the control device, then the Permittee shall maintain records of dates and times 

when the control device is monitored and when breakthrough is measured, and 

shall record the date and time that the existing carbon in the control device is 

replaced with fresh carbon. _[40 C.F.R. § 61.356(j)]. 

(b)/The Permittee must keep the following records required by 40 C.F.R. § 61.356 (n)(l) 

and (2) when using a total enclosure to comply with control requirements for tanks in 40 

C.F.R. § 61.343. The Permittee may use records as required in 40 C.F.R. 

§ 264.1089(b)(2)(iv) or 265.1090(b)(2)(iv) for a tank to meet the recordkeeping 

requirement in 40 C.F.R. § 61.356(n)(l). The Permittee must make the records of each 

verification of a total enclosure available for inspection by EP A upon request: 

(ir) Records of the most recent set of calculations and measurements performed to 

verify that the enclosure meets the criteria of a permanent total enclosure as 

specified i n "Procedure T—Criteria for and Verification of a Permanent or 

Temporary Total Enclosure" in 40 C.F.R. § 52.741, Aappendix B; 

(hA) Records required for a closed-vent system and control device according to the 

requirements in 40 C.F.R. § 61.356(d)(f), and Q). 

2. Other recordkeeping requirements: [40 C.F.R. § 71.6(a)(3)(i)(B)] 

The Permittee shall keep the following records: 

(a) Amount of accepted solid wastes, in tons per month and tons per year. 

(b) Lo g of maintenance and repair of air pollution control devices with the dates of 

service/repair made, and inspection conducted. 

V ES 001605 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 94 of 134 

(c) Records ofthe pressure being maintained inside the building. 

(d) Monthly and annual VOM/HA P emissions. 

3. The Permittee shall maintain the following records o f the fugitive emissions: [40 TC.F.R ^ 

§71.6(a)(3)(i)(B)] 

(a) _Details of each visual survey or visible emissions observation, including date, time, 

observer and results for each emission unit and any other pollutant emitting activity; 

(b) _Date, time and type of any investigation conducted; 

(c) _Findings ofthe investigation, including the reasons for the presence of visible 

emissions or fugitive emissions of particulate matter; 

(d) _Date, time and type of corrective actions taken; 

(e) _Results of any Method 9 visible emissions observations conducted on the source o f 

visible or fugitive emissions. 

2.6 Gasoline Storage Tanks 

(A) Emission Limitations and Standards [40 CF R §71.6(a)(1)] 

1. The Permittee shall not cause or allow the loading of any organic material in any 

stationary tank having a storage capacity of greater than 946 liters (250 gallons), unless 

such tank is equipped with a permanent submerged loading pipe or an equivalent device 

approved by the Agency according to the provisions of 35 IA C 201, and further 

processed consistent with 35 IAC 219.108, or unless such tank is a pressure tank as 

described in 35 IA C 219,121(a) or it fitted with a recovery system as described in 35 IA C 

219.121(b)(2). .[35 IA C 219.122(b)]. 

2. The Permittee shall not cause or allow the transfer of gasoline from any delivery vessel 

into the stationary storage tank at a gasoline dispensing operations unless the tank is 

equipped with a submerged loading pipe. _[35 IAC 219.583(a)(1)]. 

3. The Permittee shall not sell, offer for sale, dispense, supply, offer for supply, or transport 

for use in Illinois gasoline whose Reid vapor pressure exceeds the applicable limitations 

set forth in 35 IA C 219.585 (b) and (c) below during the regulatory control periods, 

which shall be June 1 to September 15. .[35 IA C 219.585(a)]. 

4. The Reid vapor pressure of gasoline, a measure of its volatility, shall not exceed 7.2 psi 

(49.68 kPa) during the regulatory control period in 1995 and each year thereafter. .[35 

I AC 219.585(b)]. 

V ES 001606 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 95 of 134 

5. The Reid vapor pressure of ethanol blend gasolines having at least nine percent (9%) but 

not more than ten percent (10%) ethyl alcohol by volume of the blended mixture, shall 

not exceed the limitations for gasoline set forth in subsection (b) of 35 IA C 219.585 by 

more than 1.0 pounds per square inch (psi)(6.9 kilopascals). 35 IA C 219.585(c)]. 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

1. The affected gasoline storage tank is not subject to the requirements of 35 IAC 

219.583(a)(2),(3),(4) pursuant to 35 IAC 219.583(b)(3), as it has a capacity of less than 

575 gallons. 

2. The gasoline storage tank is not subject to the requirements of 40 C.F.R. Ppart 60, 

sSubpart K b because the design capacity of the storage tank is less than 40 cubic meters 

(10,576 gallons). [40 C.F.R. § 60,110b(a)]. 

3. The gasoline storage tank is not subject to the requirements of 35 IA C 219.121 because it 

has a capacity of less than 40,000 gallons.. [35 IA C 219.121]. 

4. The gasoline storage tank is not subject to the requirements of 35 IA C 219.120 because it 

stores petroleum liquids. [35 IAC 219.119(e)]. 

5. The storage tank is not subject to 40 C.F.R. Ppart 64, Compliance Assurance Monitoring, 

because the it does not use an add-on control device to achieve compliance with an 

emission limitation or standard. 

(C) Monitormg and Testing [40 CFR §71.6(a)(3)(i)(A)] 

1. The Permittee shall have gasoline stored in the affected tank sampled and analyzed for 

Reid vapor pressure. Samples shall be conducted at least once per calendar year or 

within 15 days of a written request from EPA . [40 C.F.R. § 71.6(a)(3)(i)(B)]. 

2. The Permittee shall conduct all sampling (testing) of gasoline required by 35 IA C 

219.585 in accordance with the procedures contained in 40 C.F.R. Ppart 80, Aappendix 

D, "Sampling Procedures for Fuel Volatility." 

3. The Permittee shall measure Reid vapor pressure of gasoline in accordance with the 

procedures contained in "Tests for Determining Reid Vapor Pressure (RVP) of Gasoline 

and Gasoline-Oxygenate Blends," as set forth in 40 C.F.R. Ppart 80, Aappendix E. 

4. The Permittee shall determine the ethanol content of ethanol blend gasolines using one of 

the approved testing methodologies specified in 40 C.F.R. Ppart 80, aAppendix F. 

5. An y alternate to the sampling or testing methods or procedures contained in 35 IA C 

219.585 (d), (e), and (f) must be approved by the IEPA, which shall consider data 

comparing the performance ofthe proposed alternative to the perfonnance of one or more 

V ES 001607 
I Veolia Environmental Services 

Pennit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 96 of 134 

approved test methods or procedures. Such data shall accompany any request for IEPA 

approval of any alternate test procedure. If the IEPA determines that such data 

demonstrates that the proposed alternative will achieve results equivalent to the approved 

test methods or will achieve results equivalent to the approved test methods or 

procedures, IEPA shall approve the proposed alternative. 

6. On an annual basis, the Permittee shall conduct an inspection of the gasoline storage tank 

to review its physical condition and abihty to comply with 35 IA C 219.585. [40 C.F.R. 

§ 71.6(a)(i)(3)(B)]. 

(D) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)] 

1. The Permittee shall keep current a file for the gasoline storage tank, which contains 

design information on the capacity of the tank and documents the presence of a 

permanent submerged loading pipe._ [40 C.F.R. § 71.6(a)(3)(i)(B)]. 

2. The Pennittee shall maintain an inspection, maintenance and repair log or other records 

for the storage tank that, at a minimum, includes infonnation related to any repair or 

replacement ofthe submerged loading pipe._ [40 C.F.R. § 71.6(a)(3)(i)(B)] 

3. The Permittee shall mainitainmaintain records for each shipment of material loaded into 

the gasoline storage tank that include copies of the invoice, bill of lading or other 

documentation from the supplier that provides the type of material, the amount of 

shipment, date of delivery, and the Reid vapor pressure (psi) of the gasoline. _The 

Permittee shall keep these records for three years. _[40 C.F.R. § 71.6(a)(3)(i)(BYJ. 

4. The Permittee must maintain records of results of any testing samples. _[40 C.F.R. 

§ 71.6(a)(3)(i)(B)]. 

5. The Permittee must maintain records of the amount of gasoline dispensed from the 

gasoline storage tank (gallons/month and gallons/year). _[40 C.F.R. § 71.6(a)(3)(i)(B)]. 

2.7 Boiler 

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)] 

1. The Pennittee shall not allow the emission of carbon monoxide into the atmosphere from 

its boiler to exceed 100 ppm by volume on a dry basis conected to 3 percent oxygen. _[40 

C.F.R. § 63.52]. 

Compliance with section 2.7(Aa)(l), above, will assume compliance with the 

requirement from 35 IA C 216.121 that no person shall cause or allow the emission of 

carbon monoxide into the atmosphere from any fuel combustion emission source with 

actual heat input greater than 2.9 M W (10 mmBtu/hr) to exceed 200 ppm, conected 50 

percent excess air. 

V ES 001608 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12, 2013 

Page: 97 of 134 

2. Ernissions and operation of this boiler shall not exceed the following limits: 

Operating 

Hours 

N O x C O 

Fuel (Hr/Yr) (Lb/Hr) (Ton/Yr) (Lb/Hr) (Ton/Yr) 

Natural Gas 8760 1.46 6.41 2.1 9.2 

These limits are based upon the maximum firing rate for the boiler, and standard 

emission factors. .[Construction permit 95080025]. 

3. The Pennittee shall not cause or allow the emission of smoke or other particulate matter, 

with an opacity greater than 30 percent, into the atmosphere from any emission unit other 

than those emission units subject to the requirements of 35 IAC 212.122, except as 

allowed by 35 IA C 212.123(b) and 212.124. [35 IA C 212.123(a)]. 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

1. The affected boiler is not subject to 35 IAC 217.121, emissions ofr nitrogen oxides from 

new fuel combustion emission sources because the actual heat input of each of these 

affected boilers is less than 73.2 M W (250 mmBtu/hr). 

2. The affected boiler is not subject to 35 IAC 219.301 because fuel combustion emission 

units are not subject to 35 IAC 219.301. [35 IAC 219.303]. 

3. The affected boiler is not subject to 35 IAC 214.122 because solid or liquid fuels are not 

exclusively burned in the affected boiler. 

4. The affected boiler is not subject to 40 C.F.R. Ppart 64, ^GAMCompliatice Assurance 

monitoring,- because the affected boiler does not use an add-on control devices to 

achieve compliance with an emission limitation or standard. 

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)] 

1. Natural gas shall be the only fuel fired. [Construction pennit 95080025]. 

2. Total natural gas consumption shall not exceed 7.6 mmscf/month and 91.1 mmscf/year. 

[40C.F.R. §71.6(a)(3)(i)(B)]. 

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)] 

1. The Permittee shall perform an annual Method 9 test to ensure compliance with the 

opacity limit. _[40 C.F.R. § 71.6(a)(i)(3)(B)]. 

V ES 001609 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 98 of 134 

2. The Permittee must conduct annual performance tests for carbon monoxide from the 

affected boilers. Each annual performance test must be conducted between 10 and 12 

months after the previous performance test. [40 C.F.R. § 63.52] 

The Permittee must do the following during the annual performance tests: 

i . Select the sampling ports location and the number of traverse points using Method 

1 in 40 C.F.R. Ppart 60, Aappendix A ; 

i i . Determine oxygen and carbon dioxide concentrations of the stack gas using 

Method 3A or 3B in 40 C.F.R. Ppart 60, Aappendix A , or AST M D6522-00 

(IBR, see 40 C.F.R. § 63.14(b)), or ASM E PTC 19, Part 10 (1981) (IBR, see 40 

C.F.R.§ 63.14(i)); 

iii . Measure the moisture content ofthe stack gas using Method 4 in 40 C.F.R. pPart 

60, Aappendix A ; and 

iv. Measure the carbon monoxide emission concentration using Method 10, 10A, or 

10B in Aappendix A to 40 C.F.R. Ppart 60, or AST M D6522-00 (IBR, see 40 

C.F.R. § 63.14(b)) when the fuel is natural gas. 

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)] 

The Permittee must record and maintain: 

1. Monthly records of natural gas usage [40 C.F.R. § 60.48c(g)]; 

2. Annual records of natural gas usage (million square cubic feet per year) [Construction 

permit 95080025]; 

3. A summary of the results of the annual performance tests [40 C.F.R. § 63.52]; 

4. The Permittee must submit semiannually a compliance report which contains: [40 C.F.R. 

§ 63.52] 

(a) Company name and address; 

(b) Statement by a responsible official with that official's name, title, and signature, 

certifying the truth, accuracy, and completeness of the content of the report; 

(c) Date of report and beginning and ending dates of the reporting period; 

(d) The total fuel use by each affected source subject to an emission limit, for each 

calendar month within the semiannual reporting period, including, but not limited to, a 

description of the fuel and the total fuel usage amount with units of measure; 

V ES 001610 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 99 of 134 

(e) A summary of the results of the annual performance tests and documentation o f any 

operating limits that were reestablished during this test, if applicable. The Permittee shall 

make actual test results available to the Administrator upon request; 

(f) The hours of operation for the boiler for each calendar month within the semiannual 

reporting period; 

(g) If the boiler had a startup, shutdown, or malfunction during the reporting period and 

the Permittee took actions consistent with the SSMP, the compliance report must include 

the information in 40 C.F.R. § 63.10(d)(5)(i). 

5. The Permittee shall notify IEPA prior to any change in the types of fuel used in the 

boiler. [Construction pennit 95080025]. 

2.8 Fugitive Emissions 

(A) Emission Limitations and Standards [40 C.F.R. § 71.6(a)(1)] 

1. An y leaking equipment is subject to the following requirements of 35 IAC Part 219,, 

Subpart C: 

(a) _Pumps and Compressors [35 IA C 219.142]: 

The Pennittee shall not cause or allow the discharge of more than 32.8 ml (2 cu in) of 

V O L with vapor pressure of 17.24 kilo pascals (2.5 pounds per square inch absolute)or 

greater at 294.3°K (70°F) into the atmosphere from any pump or compressor in any 15 

minute period at standard conditions. 

(b) Vapor Blowdown [35 IA C 219.143]: 

The Pennittee shall not cause or allow the emission of organic material into the 

atmosphere from any vapor blowdown system or any safety relief valve, except such 

safety relief valves not capable of causing an excessive release, unless such emission is 

controlled: 

(i4) To 10 ppm equivalent methane (molecular weight 16.0) or less; or 

(iiv) By combustion in a smokeless flare; or 

(iii4) -By other air pollution control equipment approved by IEPA according to 

provisions of 35 IA C 201 and further processed consistent with 35 IA C 219.108. 

2. The affected leaking equipment is subject to 40 C.F.R. Ppart 61, Ssubparts V and J. The 

Permittee shall comply with the standards and requirements of 40 C.F.R. Ppart 61, 

Ssubpart V . [40 C .F.R. § 61.112(b)]. 

V ES 001611 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 100 of 134 

(B) Nonapplicable Regulations [40 C.F.R. § 71.6(f)(1)] 

1. The leaking equipment is not subject to the New Source Perfonnance Standards (NSPS) 

for the Synthetic Organic Chemicals Manufacturing Industry, 40 C.F.R. pi/art 60, 

Ssubparts W , III, NNN , and RRR; and the National Emission Standard!! For Harardoun 

A ir PellutanteNESHAP for the Synthetic Organic Chemicals Manufacturing Industry, 40 

C.F.R. pPart 63, Ssubparts F, G, H , and I, because the-it is not associated with the 

manufacture of organic chemicals. 

2. The leaking equipment is not subject to 40 C.F.R. Ppart 64, -Compliance Assurance 

Monitoring," because the it does not use an add-on control devices to achieve comphance 

with an emission limitation or standard. 

(C) Work Practice and Operational Requirements [40 C.F.R. § 71.6(a)(1)] 

The Pennittee shall comply with the following standards of 40 C.F.R. pPart 61, Ssubpart 

V : 

1. General [40 C.F.R. § 61.242-1]: 

(a) The Pennittee shall demonstrate compliance with the requirements of 40 C.F.R. §§ 

61.242-1 to 61.242-11 for each new and existing source as required in 40 C.F.R. § 61.05, 

except as provided in 40 C.F.R. §§ 61.243 and 61.244. 

(b) Compliance with this subpart will be determined by review of records, review of 

performance test results, and inspection using the methods and procedures specified in 40 

C.F.R. §61.245. 

(c) The Pennittee shall mark each piece of equipment to which this section applies in 

such a manner that it can be distinguished readily from other pieces of equipment. 

2. Pumps [40 C.F.R. § 61.242-2]: 

(a) The Permittee shall monitor each pump monthly to detect leaks by the methods 

specified in 40 C.F.R. § 61.245(b), except as provided in 40 C.F.R. §§ 61.242-l(c) and 

61.242-2(d), (e), (f) and (g). 

(b) The Permittee shall check each pump by visual inspection each calendar week for 

indications of liquids dripping from the pump seal. 

(c) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. 

(d) If there are indications of liquids dripping from the pump seal, a leak is detected. 

V ES 001612 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 101 of 134 

(e) When a leak is detected, fflie Permittee shall repair it as soon as practicable, but not 

later than 15 calendar days after it is detected, except as provided in 40 C.F.R. § 61.242-

10. 

(f) The Permittee shall make a first attempt at repair no later than 5 calendar days after 

each leak is detected. 

(g) Each pump equipped with a dual mechanical seal system that includes a barrier fluid 

system is exempt from the requirements of section 2.8(C)(2)(a) through (d) of this permit, 

provided the following requirements are met: 

(iP) Each dual mechanical seal system is: 

(A) Operated with the barrier fluid at a pressure that is at all times greater than the 

pump staffing box pressure; or 

(B) Equipped with a barrier fluid degassing reservoir that is routed to a process or 

fuel gas system or connected by a closed-vent system to a control device that 

complies with the requirements of 40 C.F.R. § 61.242-11; or 

(C) Equipped with a system that purges the barrier fluid into a process stream 

with zero volatile hazardous air pollutant (VHAP ) emissions to atmosphere. 

(iiP) The barrier fluid is not in VHA P service and, if the pump is covered by standards 

under 40 C.F.R. Ppart 60, is not in VO C service. 

(iii) Each barrier fluid system is equipped with a sensor that will detect failure of the 

seal system, the barrier fluid system, or both. 

(ivv) Each pump is checked by visual inspection each calendar week for indications of 

liquids dripping from the pump seal. 

(A) If there are indications of liquid dripping from the pump seal at the time of the 

weekly inspection, the Permittee shall monitor the pump as specified in 40 C.F.R. 

§ 61.245 to determine the presence of VO C and VHA P in the barrier fluid. 

(B) If the monitor reading (taking into account any background readings) 

indicates the presence of VHAP , a leak is detected. For the purpose of this 

paragraph, the monitor may be calibrated with VHAP , or may employ a gas 

chromatography column to limit the response of the monitor to VHAP , at the 

option ofthe Permittee. 

(C) If an instrument reading of 10,000 ppm or greater (total VOC) is measured, a 

leak is detected. 

V ES 001613 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 102 of 134 

(v) The Permittee must check each sensor as described in 40 C.F.R. § 61.242-2(d)(3) 

daily unless it is equipped with an audible alarm. 

(vi) The Permittee must detennine, based on design considerations and operating 

experience, criteria applicable to the presence and frequency of drips and to the 

sensor that indicates failure ofthe seal system, the barrier fluid system, or both. 

(viir) If indications of liquids dripping from the pump seal exceed the criteria 

established in section 2.8(C)(2)(g)(vi) of this permit, or if, based on the criteria 

established in section 2.8(C)(2)(g)(vi) of this permit, the sensor indicates failure 

of the seal system, the barrier fluid system, or both, a leak is detected. 

(viii) When a leak is detected, the Permittee shall repair it as soon as practicable, but 

no later than 15 calendar days after it is detected, except as provided in 40 C.F.R. 

§61.242-10. 

(ix) The Permittee shall make a first attempt at repair no later than five calendar days 

after each leak is detected. 

(XT) An y pump that is designated, as described in 40 C.F.R. § 61.246(e)(2), for no 

detectable emissions, as indicated by an instrument reading of less than 500 ppm 

above background, is exempt from the requirements of paragraphs (a), (c), and (d) 

if the pump: 

(A) Has no externally actuated shaft penetrating the pump housing; 

(B) Is demonstrated to be operating with no detectable emissions, as indicated by 

an instrument reading of less than 500 ppm above background, as measured by 

the method specified in 40 C.F.R. § 61.245(c); and 

(C) Is tested for compliance with paragraph 40 C.F.R. § 61.242-2(e)(2) initially 

upon designation, annually, and at other times requested by the Administrator. 

(xi) If any pump is equipped with a closed-vent system capable of capturing and 

transporting any leakage from the seal or seals to a process or fuel gas system or 

to a control device that complies with the requirements of 40 C.F.R. § 61.242-11, 

it is exempt from the requirements of 40 C.F.R. § 61.242-2(a) through (e). 

(xii) Any pump that is designated, as described in 40 C.F.R. § 61.246(f)(1), as an 

unsafe-to-monitor pump is exempt from the monitoring and inspection 

requirements of 40 C.F.R. § 61.242-2(a) and (d)(4) through (6) if: 

(A) The Permittee demonstrates that the pump is unsafe to monitor because 

monitoring personnel would be exposed to an immediate danger as a consequence 

of complying with 40 C.F.R. § 61.242-2(a); and 

VES 001614 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 103 of 134 

(B) The Permittee has a written plan that requires monitoring of the pump as 

frequently as practicable during safe-to-monitor times but not more frequently 

than the periodic monitoring schedule otherwise applicable, and repair ofthe 

equipment according to the procedures in 40 C.F.R. § 61.242-2(c) if a leak is 

detected. 

(xiii) Any pump that is located within the boundary of an unmanned plant site is 

exempt from the weekly visual inspection requirement of 40 C.F.R. § 61.242-

2(a)(2) and (d)(4), and the daily requirements of 40 C.F.R. § 61.242-2(d)(5), 

provided that the Permittee visually inspects each pump as often as practicable 

and at least monthly. 

3. Compressors [40 C.F.R. § 61.242-3]: 

(a) Each compressor shall be equipped with a seal system that includes a barrier fluid 

system and that prevents leakage of process fluid to atmosphere, except as provided in 40 

C.F.R. §§ 61.242-l(c) and 61.242-3(h) and (i). 

(b) Each compressor seal system required in paragraph 2.8(C)(3)(a), above, shall be: 

(ir) Operated with the barrier fluid at a pressure that is greater than the compressor 

stuffing box pressure; or 

(iir) Equipped with a barrier fluid system degassing reservoir that is routed to a 

process or fuel gas system or connected by a closed-vent system to a control 

device that complies with the requirements of 40 C.F.R. § 61.242-11; or 

(iii) Equipped with a system that purges the barrier fluid into a process stream with 

zero VHA P emissions to atmosphere. 

(c) The barrier fluid shall not be in VHA P service and, if the compressor is covered by 

standards under 40 C.F.R. Ppart 60, shall not be in VO C service. 

(d) The Permittee shall equip each barrier fluid system as described in 40 C.F.R. 

§ 61.242-3(a)-(c) with a sensor that will detect failure of the seal system, barrier fluid 

system, or both. 

(e) The Permittee shall check each sensor as required in 40 C.F.R. § 61.242-3(d) daily or 

shall equip the sensor with an audible alarm unless the compressor is located within the 

boundary of an unmanned plant site. 

(f) The Permittee shall determine, based on design considerations and operating 

experience, a criterion that indicates failure of the seal system, the barrier fluid system, or 

both. 

V ES 001615 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 104 of 134 

(g) If the sensor indicates failure ofthe seal system, the barrier fluid system, or both 

based on the criterion determined under paragraph (e)(2) of 40 CF R 61.242-3, a leak is 

detected. 

(h) When a leak is detected, the Permittee shall repair it as soon as practicable, but not 

later than 15 calendar days after it is detected, except as provided in 40 C.F.R. § 61.242-

10. 

(i) The Permittee shall make a first attempt at repair no later than 5 calendar days after 

each leak is detected. 

(k) A compressor is exempt from the requirements of 40 C.F.R. § 61.242-3(a) and (b) if it 

is equipped with a closed-vent system to capture and transport leakage from the 

compressor drive shaft back to a process or fuel gas system or to a control device that 

complies with the requirements of 40 C.F.R. § 61.242-11, except as provided in 40 

C.F.R. § 61.242-3(i). 

(1) An y compressor that is designated, as described in 40 C.F.R. § 61.246(e)(2), for no 

detectable emission as indicated by an instrument reading of less than 500 ppm above 

background is exempt from the requirements of 40 C.F.R. § 61.242-3(a)-(h) if the 

compressor: 

(ir) Is demonstrated to be operating with no detectable emissions, as indicated by an 

instrument reading of less than 500 ppm above background, as measured by the 

method specified in 40 C.F.R. § 61.245(c); and 

(iir) Is tested for compliance with 40 C.F.R. § 61.242-3(i)(l) initially upon 

designation, annually, and at other times requested by the Administrator. 

4. Open-ended valves or lines [40 C.F.R. § 61.242-6]: 

(a) The Permittee shall equip each open-ended valve or line with a cap, blind flange, 

plug, or a second valve, except as provided in 40 C.F.R. § 61.242-1(c). 

(b) The cap, blind flange, plug, or second valve shall seal the open end at all times except 

during operations requiring process fluid flow tlirough the open-ended valve or line. 

(c) The Permittee shall operate each open-ended valve or line equipped with a second 

valve in a manner such that the valve on the process fluid end is closed before the second 

valve is closed. 

(d) When a double block and bleed system is being used, the bleed valve or line may 

remain open during operations that require venting the line between the block valves but 

shall comply with 40 C.F.R. § 61.242-6(a) at all other times. 

V ES 001616 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 105 of 134 

(e) Open-ended valves or lines in an emergency shutdown system which are designed to 

open automatically in the event of a process upset are exempt from the requirements of 

40 C.F.R. § 61.242-6(a), (b) and (c). 

(f) Open-ended valves or lines containing materials which would autocatalytically 

polymerize or would present an explosion, serious overpressure, or other safety hazard if 

capped or equipped with a double block and bleed system as specified in 40 C.F.R. 

§ 61.242-6(a) through (c) are exempt from the requirements of 40 C.F.R. § 61.242-6(a) 

through (c). 

5. Valves [40 C.F.R. § 61.242-7]: 

(a) The Permittee shall monitor each valve monthly to detect leaks by the method 

specified in 40 C.F.R. § 61.245(b) and shall comply with 40 C.F.R. 

§ 61.242-7(b)-(e), except as provided in 40 C.F.R. §§ 61.242-7(4), (g), and (h), 61.243-1 

or 61.243-2, and 61.242-1(c). 

(b) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. 

(c) The Permittee may monitor any valve for which a leak is not detected for 2 successive 

months the first month of every quarter, beginning with the next quarter, until a leak is 

detected. 

(d) If a leak is detected, the Permittee shall monitor the valve monthly until a leak is not 

detected for 2 successive months. 

(e) When a leak is detected, the Permittee shall repair it as soon as practicable, but no 

later than 15 calendar days after the leak is detected, except as provided in 40 C.F.R. 

§ 61.242-10. 

(f) The permittee shall make a first attempt at repair no later than 5 calendar days after 

each leak is detected. 

(g) First attempts at repair include, but are not limited to, the following best practices 

where practicable: 

(iv) Tightening of bonnet bolts; 

(iir) Replacement of bonnet bolts; 

(iii-) Tightening of packing gland nuts; and 

(iv-) Injection o f lubricant into lubricated packing 

V ES 001617 
I Veolia Environmental Services Page: 106 of 134 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

(h) An y valve that is designated, as described in 40 C.F.R. § 61.246(e)(2), for no 

detectable emissions, as indicated by an instrument reading of less than 500 ppm above 

background, is exempt from the requirements of 40 C.F.R. § 61.242-7(a) if the valve: 

(ir) Has no external actuating mechanism in contact with the process fluid; 

(iir) Is operated with emissions less than 500 ppm above background, as measured by 

the method specified in 40 C.F.R. § 61.245(c); and 

(iii-) Is tested for compliance with 40 C.F.R. § 61.242-7(f)(2) initially upon 

designation, annually, and at other times requested by the Administrator. 

(i) _Any valve that is designated, as described in 40 C.F.R. § 61.246(f)(1), as an unsafe-tomonitor valve is exempt from the requirements of 40 C.F.R. § 61.242-7(a) if: 

(i.) The Permittee demonstrates that the valve is unsafe to monitor because 

monitoring personnel would be exposed to an immediate danger as a consequence 

of complying with 40 C.F.R. § 61.242-7(a); and 

(iir) The Permittee has a written plan that requires monitoring of the valve as frequent 

as practicable during safe-to-monitor times. 

(j) An y valve that is designated, as described in 40 C.F. R. § C44*-61.246(f)(2), as a 

difficult-to-monitor valve is exempt from the requirements of paragraph (a) of 40 C.F.R.. 

£C4RR-61.242-7 if: 

(17) The Permittee demonstrates that the valve cannot be monitored without elevating 

the monitoring personnel more than 2 meters above a support surface; 

(iir) The process unit within which the valve is located is an existing process unit; and 

(iii) The Permittee follows a written plan that requires monitoring of the valve at least 

once per calendar year. 

6. Alternative standards for valves in VHA P service allowable percentage of valves 

leaking [40 C.F.R. § 61.243-1]: 

(a) The Permittee may elect to have all valves within a process unit comply with an 

allowable percentage of valves leaking of equal to or less than 2.0 percent. 

(b) The following requirements shall be met if the Permittee decides to comply with an 

allowable percentage of valves leaking: 

(i) The Permittee must notify the Administrator that it has elected to have all valves 

within a process unit to comply with the allowable percentage of valves leaking 

V ES 001618 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 107 of 134 

before implernenting this alternative standard, as specified in 40 C.F.R. 

§ 61.247(d). 

(iir) The Permittee conducts a performance test as specified in 40 C.F.R. § 61.243-l(c) 

initially upon designation, annually, and at other times requested by the 

Administrator. 

(iiiv) If a valve leak is detected, the Permittee shall repair it in accordance with 40 

C.F.R. § 61.242-7(d)and(e). 

(c) The Permittee shall conduct performance tests in the following manner: 

(i-) The Permittee shall monitor all valves in VFLAP service within the process unit 

within 1 week by the methods specified in 40 C.F.R. § 61.245(b). 

(iir) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. 

(iii) The Permittee shall determine the leak percentage by dividing the number of 

valves in VHA P service for which leaks are detected by the number of valves in 

VHA P service within the process unit. 

(d) If the Permittee elects to have all valves comply with this alternative standard, no 

process unit shall have a leak percentage greater than 2.0 percent. 

(e) If the Permittee decides no longer to comply with 40 C.F.R. § 61.243-1, the Permittee 

must notify the Administrator in writing that it will follow the work practice standard 

described in 40 C.F.R. § 61.242-7(a)-(e). 

7. Alternative standards for valves in VHA P service [40 C.F.R. § 61.243-2]: 

(a) The Permittee may elect for all valves within a process unit to comply with one of the 

alternative work practices specified in 40 C.F.R. § 61.243-2(b)(2) and (3). 

(b) The Permittee must notify the Administrator before implementing one of the 

alternative work practices, as specified in 40 C.F.R. § 61.247(d). 

(c) The Permittee shall comply initially with the requirements for valves, as described in 

40 C.F.R. § 61.242-7. 

(d) After 2 consecutive quarterly leak detection periods with the percentage of valves 

leaking equal to or less than 2.0, the Permittee may begin to skip one of the quarterly leak 

detection periods for the valves in VHA P service. 

(e) After five consecutive quarterly leak detection periods with the percentage of valves 

leaking equal to or less than 2.0, the Permittee may begin to skip three ofthe quarterly 

leak detection periods for the valves in VHA P service. 

V ES 001619 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 108 of 134 

(f) If the percentage of valves leaking is greater than 2.0, the Permittee shall comply with 

the requirements as described in 40 C.F.R. § 61.242-7, but may again elect to use this 

section. 

(D) Monitoring and Testing [40 C.F.R. § 71.6(a)(3)(i)(A)] 

1. The Permittee shall comply with the following test methods and procedures requirements 

of 40 C.F.R. § 61.245: 

(a) The Permittee shall monitoring, as required in 40 C.F.R. §§ 61.242, 61.243, 61.244, 

and 61.135, as follow: 

(ir) The Permittee shall monitor as required by Method 21 of 40 C.F.R. Ppart 60, 

Aappendix A . 

(it) The detection instrument shall meet the performance criteria of Method 21. 

(iii-) The instrument shall be calibrated before use on each day of its use by the 

procedures specified in Method 21. 

(ivT) Calibration gases shall be: 

(A) Zero air (less than 10 ppm of hydrocarbon in air); and 

(B) A mixture of methane or n-hexane and air at a concentration of 

approximately, but less than, 10,000 ppm methane or n-hexane. 

(vr) The instrument probe shall be traversed around all potential leak interfaces as 

close to the interface as possible, as described in Method 21 of 40 C.F.R. Ppart 

60, aAppendix A . 

(c) When equipment is tested for compliance with or monitored for no detectable 

emissions, the Permittee shall comply with the following requirements: 

(iP) The Permittee shall test equipment as required by 40 C.F.R. § 61.245(b)(1) 

through (4). 

(iir) The background level shall be determined, as set forth in Method 21 of 40 C.F.R. 

pPart 60, Aappendix A . 

(ih-) Tlie instrument probe shall be traversed around all potential leak interfaces as 

close to the interface as possible as described in Method 21 of 40 C.F.R. Ppart 60, 

aAppendix A . 

V ES 001620 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 109 of 134 

(IVT) The arithmetic difference between the maximum concentration indicated by the 

instrument and the background level is compared with 500 ppm for determining 

compliance. 

(d) Each piece of equipment within a process unit that can conceivably contain 

equipment in VHA P service is presumed to be in VHA P service unless the Permittee 

demonstrates that the piece of equipment is not in VHA P service. For a piece of 

equipment to be considered not in VHA P service, it must be determined that the percent 

VHA P content can be reasonably expected never to exceed 10 percent by weight. For 

purposes of determining the percent VHA P content ofthe process fluid that is contained 

in or contacts equipment, the Permittee shall use procedures that conform to the methods 

described in AST M Method D-2267 (incorporated by reference as specified in 40 C.F.R. 

§61.18). 

(e) The Permittee may use engineering judgment rather than the procedures in 40 C.F.R. 

§ 61.245(d)(1) to demonstrate that the percent VHA P content does not exceed 10 percent 

by weight, provided that the engineering judgment demonstrates that the VHA P content 

clearly does not exceed 10 percent by weight. _When the Permittee and the Administrator 

do not agree on whether a piece of equipment is not in VHA P service, however, the 

Permittee shall use the procedures in 40 C.F.R. § 61.245(d)(1). 

(f) If the Permittee determines that a piece of equipment is in VHA P service, the 

determination can be revised only after following the procedures in paragraph 40 C.F.R. 

§ 61.245(d)(1). 

(g) Samples used in determining the percent VHA P content shall be representative ofthe 

process fluid that is contained in or contacts the equipment or the gas being combusted in 

the flare. 

2. 40 C.F.R. § 61.246 

(a) The Permittee may comply with the recordkeeping requirements for multiple process 

units subject to the provisions of 40 C.F.R. Ppart 61, Ssubpart V in one recordkeeping 

system if the system identifies each record by each process unit. 

(b) When each leak is detected as specified hi 40 C.F.R. §§ 61.242-2, 61.242-3, 61.242-7, 

and 61.242-8, the following requirements apply: 

(ir) The Permittee shall attach a weatherproof and readily visible identification, 

marked with the equipment identification number, to the leaking equipment. 

(iir) The Pennittee may remove the identification on a valve after it has monitored the 

valve for 2 successive months as specified in 40 C.F.R. § 242-7(c) and no leak has 

been detected during those 2 months. 

VES 001621 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 110 of 134 

(iii-) The Permittee may remove the identification on equipment, except on a valve, 

after it has repaired the equipment. 

(c) When the Permittee has detected each leak as specified in 40 C.F.R. §§ 61.242-2, 

61.242-3, 61.242-7, 61.242-8, and 61.135, the Permittee shall record the following 

information in a log and shall keep the information for 2-two vears in a readily accessible 

location: 

(hr) The instrument and operator identification numbers and the equipment 

identification number. 

(iir) The date the leak was detected and the dates of each attempt to repair the leak. 

(iii) Repair methods applied i n each attempt to repair the leak. 

(iv) "Above 10,000" if the maximum instrument reading measured by the methods 

specified in 40 C.F.R. § 61.245(a) after each repair attempt is equal to or greater 

than 10,000 ppm. 

(v) "Repair delayed" and the reason for the delay if a leak is not repaired within 15 

calendar days after discovery of the leak. 

(vi) The signature of the responsible official whose decision it was that repair could 

not be affected without a process shutdown. 

(vii) The expected date of successful repair of the leak if a leak is not repaired within 

15 calendar days. 

(viii) Dates of process unit shutdowns that occur while the equipment is unrepaired, 

(ix) The date of successful repair of the leak. 

(d) The Permittee shall record in a log and keep in a readily accessible location the 

following information pertaining to all equipment to which a standard applies: 

(ir) A list of identification numbers for equipment (except welded fittings) subject to 

the requirements of 40 C.F.R. Ppart 61, Ssubpart V . 

(iir) A list of identification numbers for equipment that the Permittee elects to 

designate for no detectable emissions as indicated by an instrument readmg of less 

than 500 ppm above background. 

(iii) The designation of this equipment for no detectable emissions shall be signed by a 

responsible official. 

V ES 001622 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 111 of 134 

(iv) The dates of each compliance test required in 40 C.F.R. §§ 61.242-2(e), 61.242-

3(i), 61.242-4, and 61.242-7(f). 

(v) The background level measured during each compliance test. 

(vi) The maximum instrument reading measured at the equipment during each 

compliance test. 

(e) The Permittee shall record in a log and keep in a readily accessible location the 

following information pertaining to all valves subject to the requirements of 40 CFT C £ 

61.242-7(g) and (h) and to all pumps subject to the requirements of 40 C.F.R. § 61.242-

2(g): 

(iv) A list of identification numbers for valves and pumps that are designated as 

unsafe to monitor, an explanation for each valve or pump stating why the valve or 

pump is unsafe to monitor, and the plan for monitoring each valve or pump. 

(iir) _A list of identification numbers for valves that are designated as difficult to 

monitor, an explanation for each valve stating why the valve is difficult to 

monitor, and the planned schedule for monitoring each valve. 

(f) The Permittee shall record and keep in a readily accessible location the following 

infonnation: 

(i) Design criterion required in 40 C.F.R. §§ 61.242-2(d)(5) and 61.242-3(e)(2), and 

an explanation ofthe design criterion; and 

(iir) Any changes to this criterion and the reasons for the changes. 

(g) Hours of operation of each component. 

(h) Emissions of VOC . 

(E) Recordkeeping and Reporting [40 C.F.R. § 71.6(a)(3)] 

1. The Permittee shall promptly notify the permitting authority of deviations ofthe affected 

leaking equipment from the permit requirements. Reports shall describe the probable 

cause of such deviations, and any conective actions or preventive measures taken. 

[40 C.F.R. § 71.6(a)(3)(iii)(B)]. 

2. 40 C.F.R. § 61.247 

(a) The Permittee shall submit a statement in writing notifying the Administrator that it is 

implementing the requirements of 40 C.F.R. §§ 61.242, 61.245, 61.246, and 61.247. 

V ES 001623 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 112 of 134 

(b) In the case of an existing source or a new source which has an initial startup date 

preceding the effective date, the Permittee shall submit the statement to the Administrator 

along with the information required under 40 C.F.R. § 61.10 within 90 days of the 

effective date, unless a waiver of compliance is granted under 40 C.F.R. § 60.11. If a 

waiver of compliance is granted, the4he Permittee must submit the statement on a date 

scheduled by the Administrator. 

(c) The Permittee must include the following information for each source in the 

statement: 

(IT) Equipment identification number and process unit identification, 

(iiv) Type of equipment (for example, a pump or pipeline valve). 

(iii) Percent by weight VHA P in the fluid at the equipment. 

(iv) Process fluid state at the equipment (gas/vapor or liquid). 

(vr) Method of compliance with the standard (for example, "monthly leak detection 

and repair" or "equipped with dual mechanical seals"). 

(d) The Permittee shall submit to the Administrator a report, semiannually starting 6 

months after the initial report required in 40 C.F.R. § 61.247(a), that includes the 

following information: 

(IT) Process unit identification. 

(iiv) For each month during the semiannual reporting period: 

(A) Number of valves for which leaks were detected as described in 40 C.F.R. 

61.242-7(b) or 61.243-2. 

(B) Number of valves for which leaks were not repaired as required in 40 C.F.R. 

§61.242-7(d). 

(C) Number of pumps for which leaks were detected as described in 40 C.F.R. 

§61.242-2(b) and (d)(6). 

(D) Number of pumps for which leaks were not repaired as required in 40 C.F.R. 

§61.242-2(c) and (d)(6). 

(E) Number of compressors for which leaks were detected as described in 40 

C.F.R. § 61.242-3(f). 

(F) Number of compressors for which leaks were not repaired as required in 40 

C.F.R. § 61.242-3(g). 

V ES 001624 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 113 of 134 

(G) The facts that explain any delay of repairs and, where appropriate, why a 

process unit shutdown was technically infeasible. 

2.9 Insignificant Activities 

(A) List of insignificant activities 

The following are emissions units at the facility that are insignificant activities: 

2.5 mmBtu/hr Tioga portable boiler, two emergency generators (<112kW), aAsh handling, 

h Wandling of spent dry scrubber solids, it ime unloading and proportioning, "Gasoline storage 

and dispensing, use of absorbent, gGeneral Vvehicle maintenance and servicing (assumed to 

include diesel fuel handling), ftaboratory, piping and storage system for natural gas, nNonhalogenated cold cleaning degreasers, f internal combustion engines of motor vehicles, and 

s Storage and handling of closed drums. 

(B) Compliance with applicable requirements 

1. For each particulate matter process emission unit, the Permittee shall comply with the 

applicable particulate matter emission limit of 35 LAC 212.321 or 212.322 and 35 IAC 

Part 266. For example, the particulate matter emissions from a process emission unit 

shall not exceed 0.55 pounds per hour if the emission unit's process weight rate is 100 

pounds per hour or less, pursuant to 35 IA C 266.110. 

2. For each organic material emission unit that uses organic material, e.g., a mixer or 

printing line, the Permittee shall comply with the applicable VO M emission limit of 35 

I A C 215.301, which requires that organic material emissions not exceed 8.0 pounds per 

hour or, if no odor nuisance exists, do not qualify as photochemically reactive material as 

defined in 35 IAC 211.4690. 

3. For each open burning activity, the Permittee shall comply with 35 IA C Part 237, 

including the requirement to obtain a permit for open burning in accordance with 35 IA C 

237.201, if necessary. 

3.0 FACILITY-WIDE PERMIT REQUIREMENTS 

(A) General Part 71 Recordkeeping [40 C.F.R. § 71.6(a)(3)(ii)] 

1. The Permittee shall keep records of required monitoring information that include 

the following: 

l . The date, place, and tune of sampling or measurements; 

V ES 001625 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 114 of 134 

i i . The date(s) analyses were performed; 

iii. The company or entity that performed the analyses; 

iv. The analytical techniques or methods used; 

v. The results of such analyses; and 

v i. The operating conditions existing at the time of sampling or measurement. 

2. The Permittee shall retain records of all required monitoring data and support 

information for a period of at least 5 calendar years from the date ofthe 

monitoring sample, measurement, report, or application. Support infonnation 

includes, but is not limited to, all calibration and maintenance records, all original 

strip-chart recordings for continuous monitoring instrumentation, and copies of all 

reports required by this pennit. 

(B) General Part 71 Reporting [40 C.F.R. § 71.6(a)(3)(iii)] 

1. The Permittee shall submit to EP A semi-annual reports o f all required monitoring 

each six month reporting period from January 1 to June 30 and from July 1 to 

December 31, except that the first reporting period shall begin on the effective 

date of this pennit and end on December 31. Al l reports shall be submitted to the 

E P A and shall be postmarked by the 30th day following the end ofthe reporting 

period. Al l instances of deviations from permit requirements must be clearly 

identified in such reports. Al l required reports must be certified by a responsible 

official consistent with Condition 4.0(H)(1) of this permit. [40 C.F.R. 

§71.6(a)(3)(iii)(A)], 

i . A monitoring report under this section must include the following: 

(a) . The company name and address; 

(b) . The beginning and ending dates of the reporting period; 

(c) . The emissions unit or activity being monitored; 

(d) . The emissions limitation or standard, including operational 

requirements and limitations (such as parameter ranges), specified 

in the permit for which compliance is being monitored; 

(e) . Al l instances of deviations from permit requirements whether 

demonstrated by referenced test method, monitoring, or through 

any other credible evidence, including those attributable to upset 

V ES 001626 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 115 of 134 

conditions as defined in this permit, and the date on which each 

deviation occurred; 

(f) . The total time when monitoring required by this pennit was not 

performed during the reporting period and, at the source's 

discretion, either the total duration of deviations indicated by such 

monitoring or the actual records of deviations; 

(g) . Al l other monitoring results, data, or analyses required to be 

reported by the applicable requirement; 

(h) . The name, title, and signature of the responsible official who is 

certifying to the truth, accuracy, and completeness of the report. 

i i . An y report required by an applicable requirement that provides the same 

information described in section 3.0(B)(l)(i)(a) through (h), above, shall 

satisfy the requirement under (B)(1). 

iii. "Deviation" means any situation in which an emissions unit fails to meet a 

permit term or condition. A deviation is not always a violation. A 

deviation can be determined by observation or through review of data 

obtained from any testing, monitoring, or record keeping established in 

accordance with 40 C.F.R. § 71.6(a)(3)(i) and (ii). For a situation lasting 

more than 24 hours, each 244iour period is considered a separate 

deviation. "Deviations" includes, but is not limited to, any of the 

following: [40 C.F.R. § 71.6(a)(3)(iii)(C)] 

(a) . A situation when emissions exceed an emission limitation or 

standard; 

(b) . A situation where process or emissions control device parameter 

values indicate that an emission limitation or standard has not been 

met; and 

(c) . A situation in which observations or data collected demonstrates 

noncompliance with an emission limitation or standard or any 

work practice or operating condition required by the pennit. 

2. The Pennittee shall promptly report to the EP A deviations from permit 

requirements, including those attributed to malfunction, emergency or other upset 

conditions, the probable cause of such deviations, and any conective actions or 

preventive measures taken. "Prompt" is defined as follows: 

[40 C.F.R. § 71.6(a)(3)(iii)(B)] 

V ES 001627 
Veolia Environmental Services Page: 116 of 134 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

i . An y definition of "prompt" or specific timeframe for reporting deviations 

provided in an underlying applicable requirement (as identified in this 

permit); or 

i i . Where the underlying applicable requirement does not define prompt or 

provide a timeframe for reporting deviations, reports of deviations will be 

submitted based on the following schedule: 

(a) . For emissions of a hazardous air pollutant or a toxic air 

pollutant(as identified in an applicable regulation) that continue for 

more than an hour in excess of permit requirements, the report 

must be made within 24 hours of the occurrence. 

(b) . For emissions of any regulated pollutant excluding a hazardous air 

pollutant or a toxic air pollutant that continue for more than two 

hours in excess of permit requirements, the report must be made 

within 48 hours. 

(c) . For all other deviations from permit requirements, the report shall 

be submitted with the semi-annual monitoring report required in 

paragraph (1) of this section. 

2. If any of the conditions in Condition 3.0(B)(2)(ii)(a) through (c) above are met, 

the source must notify EP A by telephone or facsimile based on the timetable 

listed. A written notice, certified consistent with Condition 4.0(H)(1), must be 

submitted within 10 working days of the occurrence. Al l deviations reported 

under this section must also be identified in the 6-month report required under 

paragraph (1) of this section. 

(C) Performance Testing [40 C.F.R. § 71.6(a)(3)(I)] 

The Permittee shall provide performance testing facilities that include the following: 

1. Sampling ports adequate for the applicable test methods; 

2. Safe sampling platform(s); 

3. Safe access to sampling platform(s); and 

4. Utilities for sampling and testing equipment. 

(D) Facility-wide Applicable Requirements 

1. The Permittee shall not cause or allow the emission of fugitive particulate matter 

from any process, including any material handling or storage activity that is 

V ES 001628 
Veolia Environmental Services 

PermitNo.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 117 of 134 

visible by an observer looking generally toward the zenith at a point beyond the 

property line of the emission source. [35 IA C 212.301]. 

2. Open Burning 

(a) The Permittee shall not cause or allow open burning, except as provided in 35 

I A C 237. 

(b) The Permittee shall not cause or allow open burning of any refuse in any 

chamber or apparatus, unless such chamber or apparatus is designed for the 

purpose of disposing ofthe class of refuse being burned. 

3. The Permittee shall not cause or allow the emission of smoke or other particulate 

matter, with an opacity greater than 30 percent, into the atmosphere from any 

emission unit other than those emission units subject to the requirements of 35 

I AC 212.122, except as allowed by 35 IA C 212.123(b) and 212.124. [35 IA C 

212.123(a)]. 

4. The Permittee shall comply with the standards for recycling and emissions 

reduction of ozone depleting substances pursuant to 40 C.F.R. Ppart 82, Ssubpart 

F, except as provided for motor vehicle air conditioners in 40 C.F.R. Ppart 82, 

sSubpart B: 

(aP)_Persons opening appliances for maintenance, service, repair, or disposal must 

comply with the required practices pursuant to 40 C.F.R. § 82.156. 

(brXEquipment used during the maintenance, service, repair, or disposal of 

appliances must comply with the standards for recycling and recovery equipment 

pursuant to 40 C.F.R. § 82.158. 

(cr)_Persons performing maintenance, service, repair, or disposal of appliances 

must be certified by an approved technician certification program pursuant to 40 

C.F.R. § 82.161. 

5. Risk Management Plan (RMP) 

Should this stationary source, as defmed in 40 C.F.R. § 68.3, become subject to the 

federal regulations for Chemical Accident Prevention in 40 C.F.R. Ppart 68, then the 

Permittee shall submit the items below. [40 C.F.R. § 68.215(a)(2)(i) and (ii)]. 

(av)_A compliance schedule for meeting the requirements of 40 C.F.R. pPart 68 by 

the date provided in 40 C.F.R. § 68.10(a); or 

(br)_A certification statement that the source is in compliance with all 

requirements of 40 C.F.R. Ppart 68, including the registration and submission of 

the RMP , as part of the annual compliance certification. 

V ES 001629 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 118 of 134 

6. Episode Action Plans 

The Pennittee shall maintain at the source and have on file with the IEPA a written 

episode action plan (plan) for reducing the levels of emissions during yellow alerts, red 

alerts, and emergencies, consistent with safe operating procedures. The plan shall 

contain the information specified in 35 IAC 244.144 and is incorporated by reference into 

this pennit. [35 IAC 244 A Subpart C]. 

7. Annual benzene waste quantity determination [40 C.F.R. § 61.355]: 

(A) Tthe Permittee shall determine the total annual benzene quantity from facihty waste 

by the following procedure: 

1. For each waste stream subject to 40 C.F.R. Ppart 61, Ssubpart FF having a flowweighted annual average water content greater than 10 percent water, on a volume 

basis as total water, or which is mixed with water or other wastes at any time and 

the resulting mixture has an annual average water content greater than 10 percent 

as specified in 40 C.F.R. § 61.342(a), the Permittee shall: 

(a) Detennine the annual waste quantity for each waste stream using the 

procedures specified in 40 C.F.R. § 61.355(b). 

(b) Determine the flow-weighted annual average benzene concentration for each 

waste stream using the procedures specified in 40 C.F.R. § 61.355(c). 

(c) Calculate the annual benzene quantity for each waste stream by multiplying 

the annual waste quantity ofthe waste stream times the flow-weighted annual 

average benzene concentration. 

2. Total annual benzene quantity from facility waste is calculated by adding together 

the annual benzene quantity for each waste stream generated during the year and 

the annual benzene quantity for each process unit turnaround waste annualized 

according to 40 C.F.R. § 61.355(b)(4). 

3. If the total annual benzene quantity from facility waste is equal to or greater than 

10 megagram per year (11 ton/yr), then the owner or operator shall comply with 

the requirements of 40 C.F.R. § 61.342(c), (d), or (e). 

8. No person shall cause or threaten or allow the discharge or emission of any 

contaminant into the environment in any State so as, either alone or in 

combination with contaminants from other sources, to cause or tend to cause air 

pollution in Illinois, or so as to violate the provisions of this Chapter, or so as to 

prevent the attainment or maintenance of any applicable ambient air quality 

standard. .[35 IA C 201.141] 

V ES 001630 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 119 of 134 

9. Facility-wide testing 

(A) Testing. .[35 IA C 201.282] 

Every emission source e^r-and air pollution control equipment shall be subject to the 

following testing requirements for the purpose of determining the nature and quantities of 

specified air contaminant emissions and for the purpose of determining ground level and 

ambient air concentrations of such air contaminants: 

(a) Testing by Permittee. .The IEPA may require the Permittee to conduct tests in 

accordance with procedures adopted by the IEPA, at such reasonable times as 

may be specified by the Agency and at the expense of the owner or operator ofthe 

emission source or air pollution control equipment. The IEPA may adopt 

procedures detailing methods of testing and formats for reporting results of 

testing. Such procedures and formats, and revisions thereto, shall not become 

effective until filed with the Index Division of the Office ofthe Secretary of State 

as Required by "An Ac t concerning administrative rules," approved June 14, 

1951, as amended. Al l such tests shall be made by or under the direction of a 

person qualified by training and/or experience in the field of air pollution testing. 

The IEPA shall have the right to observe all aspects of such tests. 

(b) Testing by the IEPA. .The IEPA shall have the right to conduct such tests at 

any time at its own expense. Upon request of the IEPA, the Pennittee shall 

provide, without charge to the IEPA, necessary holes in stacks or ducts and other 

safe and proper testing facihties, including scaffolding, but excluding instruments 

and sensing devices, as may be necessary. 

(B) The determination of annual benzene waste quantity for the off-site wastes received 

by the Permittee shall be made by using the methods and procedures established in 40 

C.F.R. § 61.355 along with the following: 

For the purposes ofthe calculation required by 40 C.F.R. § 61.355(a), the Permittee shall 

detennine the flow-weighted annual average benzene concentration in a manner that 

meets the requirements given in 40 C.F.R. § 61.355(c)(1) using either of the methods 

given in 40 C.F.R. § 61.355(c)(2) and (c)(3). 

1. The determination for wastes that are received from offsite shall be made at the 

point where the waste enters the hazardous waste treatment, storage, or disposal 

facility. 

2. Knowledge of the waste. .The Pennittee shall provide sufficient information to 

document the flow-weighted annual average benzene concentration of each waste 

stream. Examples of information that could constitute knowledge include 

material balances, records of chemicals purchases, or previous test results 

provided the results are still relevant to the cunent waste stream conditions. If 

test data are used, then the owner or operator shall provide documentation 

V ES 001631 
I Veolia Environmental Services Page: 120 of 134 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

describing the testing protocol and the means by which sampling variability and 

analytical variability were accounted for in the determination of the flowweighted annual average benzene concentration for the waste stream. When the 

Pennittee and the Administrator do not agree on detenninations of the flowweighted annual average benzene concentration based on knowledge ofthe waste, 

the procedures under 40 C.F.R. § 61.355(c)(3) shall be used. 

3. Measurements of the benzene concentration in the waste stream in accordance 

with the following procedures: 

(a) _Collect a minimum of three representative samples from each waste stream. 

Where feasible, samples shall be taken from an enclosed pipe prior to the waste 

being exposed to the atmosphere. 

(b) _For waste in enclosed pipes, the following procedures shall be used: 

(h) Samples shall be collected prior to the waste being exposed to the 

atmosphere in order to minimize the loss of benzene prior to sampling. 

(iir) A static mixer shall be installed in the process line or in a by-pass line 

unless the owner or operator demonstrates that installation of a static 

mixer i n the line is not necessary to accurately determine the benzene 

concentration of the waste stream. 

(iii) The sampling tap shall be located within two pipe diameters of the static 

mixer outlet. 

(IVT) Prior to the initiation of sampling, sample lines and cooling coil shall be 

purged with at least four volumes of waste. 

(VT) After purging, the sample flow shall be directed to a sample container and 

the tip of the sampling tube shall be kept below the surface of the waste 

during sampling to minimize contact with the atmosphere. 

(vi4) Samples shall be collected at a flow rate such that the cooling coil is able 

to maintain a waste temperature less than 10°C (50°F). 

(vhV) After filling, the sample container shall be capped immediately (within 5 

seconds) to leave a minimum headspace in the container. 

(viiir) The sample containers shall immediately be cooled and maintained at a 

temperature below 10°C (50°F) for transfer to the laboratory. 

(c) When sampling from an enclosed pipe is not feasible, a minimum of three 

representative samples shall be collected in a manner to minimize exposure of the 

sample to the atmosphere and loss of benzene prior to sampling. 

VES 001632 
Veolia Environmental Services 

Permit No.; V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 121 of 134 

(d) Each waste sample shall be analyzed using one of the following test methods 

for determining the benzene concentration i n a waste stream: 

(17) Method 8020, Aromatic Volatile Organics, in "Test Methods for 

Evaluating Solid Waste, Physical/Chemical Methods," EP A Publication 

No. SW-846 (incorporation by reference as specified in 40 C.F.R. 

§61.18); 

(iir) Method 8021, -Volatile Organic Compounds in Water by Purge and Trap 

Capillary Column Gas Chromatography with Photoionization and 

Electrolytic Conductivity Detectors in Series, in "Test Methods for 

Evaluating Solid Waste, Physical/Chemical Methods," EP A Publication 

No. SW-846 (incorporation by reference as specified in 40 C.F.R. 

§61.18); 

(iii) Method 8240, ^a s Clrromatography/Mass Spectrometry for Volatile 

Organics 1^ in "Test Methods for Evaluating Solid Waste, 

Physical/Chemical Methods," EP A Publication No. SW-846 

(incorporation by reference as specified in 40 C.F.R. §61.18); 

(iv) Method 8260, -Gas Chromatography/Mass Spectrometry for Volatile 

Organics: Capillary Column Technique ', in "Test Methods for Evaluating 

Solid Waste, Physical/Chemical Methods," EP A Publication No. SW-846 

(incorporation by reference as specified in 40 C.F.R. §61.18); 

(vr) Method 602, Purgeable Aromatics, as described in 40 C.F.R. pPart 136, 

Aappendix A , 'Test Procedures for Analysis of Organic Pollutants,- for 

wastewaters for which this is an approved EP A methods; or 

(vi) Method 624, Purgeables, as described in 40 C.F.R. pPart 136, 

Aappendix A , "Test Procedures for Analysis of Organic Pollutants, 1 for 

wastewaters for which this is an approved EP A method. 

(e) The Permittee shall calculate the flow-weighted annual average benzene 

concentration by averaging the results of the sample analyses as follows: 

C = — x X (Qi)(Ci) 

Qt i = i 

Where: 

^ 5=_Flow-weighted annual average benzene concentration for waste stream, 

ppmw. 

Qt = Total annual waste quantity for waste stream, kg/yr (lb/yr). 

Nrp= Number of waste samples (at least 3). 

VES 001633 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 122 of 134 

Q i = Annual waste quantity for waste stream represented by Ci , kg/yr (lb/yr). 

C i = Measured concentration of benzene in waste sample i , ppmw. 

10. _ Facility-wide Recordkeeping [40 .C.F.R § 71.6(a)(3)(B)]. 

(A) If testing is required by section 3.0(D)(7), the Permittee shall keep records of the 

testing, including the test date, conditions, methodologies, calculations, test results, and 

any discrepancies between the test results. 

(B) Reporting requirements established by 40 C.F.R. Ppart 61, Subpart FF (40 C.F.R. 

§61.357) 

If the total annual benzene quantity from facility waste is equal to or greater than 10 

Mg/yr (11 ton/yr), then the Permittee shall submit to the Administrator the following 

reports: 

1. The Pennittee shall submit annually to the Administrator a report that updates the 

information listed in 40 C.F.R. § 61.357(a)(1) through (a)(3). If the information 

in the annual report required by pafagfaphfr4t)C.F.R. § 61.357(a)(1) through 

(a)(3) ef4Ms-se€4H»-is not changed in the following year, the Permittee may 

submit a statement to that effect. 

2. The Pennittee must include the following infonnation in the annual report: [40 

C.F.R. § 61.357(a)(1) through (a)(iii)] 

(aP) Total annual benzene quantity from facility waste determined in accordance 

with 40 C.F.R. § 61.355(a). 

(br) A table identifying each waste stream and whether or not the waste stream 

will be controlled for benzene emissions in accordance with the requirements of 

40 C.F.R. Ppart 61, Ssubpart FF. 

(cP) For each waste stream identified as not being controlled for benzene 

emissions in accordance with the requirements of 40 C.F.R. Ppart 61, sSubpart 

FF, the Permittee shall add the following information to the table: 

(i) Whether or not the water content of the waste stream is greater than 10 

percent; 

(iir) Whether or not the waste stream is a process wastewater stream, product 

tank drawdown, or landfill leachate; 

(iiiP) Annual waste quantity for the waste stream; 

(ivt) Range of benzene concentrations for the waste stream; 

V ES 001634 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 123 of 134 

(VT) Annual average flow-weighted benzene concentration for the waste 

stream; and 

(vi) Annual benzene quantity for the waste stream. 

3. Beginning 3 months after the date that the equipment necessary to comply with 

these standards has been certified in accordance with paragraph 40 C.F.R. 

§ 61.357(d)(1), the Permittee shall submit quarterly to the Administrator a 

certification that all of the required inspections have been carried out in 

accordance with the requirements of 40 C.F.R. Ppart 61, Subpart FF. 

4. Beginning 3 months after the date that the equipment necessary to comply with 

these standards has been certified in accordance with paragraph 40 C.F.R. 

§ 61.357(d)(1), the Permittee shall submit a report quarterly to the Administrator 

that includes: 

(aP) If a treatment process or wastewater treatment system unit is monitored in 

accordance with 40 C.F.R. § 61.354(a)(1) of this subpart, then each period of 

operation during which the concentration of benzene in the monitored waste 

stream exiting the unit is equal to or greater than 10 parts per million by weight. 

(b7) If a treatment process or wastewater treatment system unit is monitored in 

accordance with 40 C.F.R. § 61.354(aX2) of this subpart, then each 3-hour period 

of operation during which the average value of the monitored parameter is outside 

the range of acceptable values or during which the unit is not operating as 

designed. 

(ch) If a treatment process or wastewater treatment system unit is monitored in 

accordance with 40 C.F.R. § 61.354(b), then each period of operation during 

which the flow-weighted annual average concentration of benzene in the 

monitored waste stream entering the unit is equal to or greater than 10 ppmw 

and/or the total annual benzene quantity is equal to or greater than 1.0 mg/yr. 

(dr) For a control device monitored in accordance with 40 C.fP.R. § 61.354(c) oh 

ttesHa+bptH t, each period of operation monitored during which any of the 

conditions established by 40 C.F.R. § 61.357(d)(7)(iv) occur, as applicable to the 

control device. 

5. For a cover and closed-vent system monitored in accordance with 40 C.F.R. 

§ 61.354(g), the permittee shall submit a report quarterly to the Administrator that 

identifies any period in which the pressure in the waste management unit is equal 

to or greater than atmospheric pressure. 

6. The Permittee shall submit annually to the Administrator a report that summarizes 

all inspections required by 40 C.F.R. §§ 61.342 through 61.354 during which 

detectable emissions are measured or a problem (such as a broken seal, gap or 

V ES 001635 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 124 of 134 

other problem) that could result in benzene emissions is identified, including 

information about the repairs or corrective action taken. 

4.0 PART 71 GENERA L REQUIREMENTS 

(A) Definitions [40 C.F.R. § 71.2] 

Terms and conditions have the meaning assigned to them in 40 C.F.R. Ppart 71 unless 

other regulations or statutes are referenced. 

(B) Annual Fee Payment [40 C.F.R. §§ 71.6(a)(7) and 71.9] 

1. The Permittee shall pay an annual permit fee in accordance with the procedures 

outlined below. [40 C.F.R. § 71.9(a)] 

2. The Permittee shall submit an annual report of its actual emissions for the 

preceding calendar year, a fee calculation work sheet (based on the report), and 

full payment of the annual fee each year. The Pennittee shall submit the annual 

report and pay the annual permit fee each year on or before the anniversary date 

(3 months from the issuance of this permit) of its initial fee calculation work 

sheet. 

The Permittee shall submit the annual report to: 

Air Permits Section (AR-18J) 

Air and Radiation Division 

EPA Region 5 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

3. The fee payment shall be in United States cunency and shall be paid by money 

order, bank draft, certified check, corporate check, or electronic funds transfer 

payable to the order of the U.S. Environmental Protection Agency. 

4. The Permittee shall send fee payment and a completed fee filing form to: 

US Environmental Protection Agency 

FOIA and Miscellaneous Payments, 

Cincinnati Finance Center, 

PO Box 979078, 

St. Louis, M O 63197-9000 

5. The Permittee shall send an updated fee calculation worksheet form and a 

photocopy of each fee payment check (or other confirmation of actual fee paid) 

submitted annually by the same deadline as required for fee payment to the 

V ES 001636 
I Veolia Environmental Services Page: 125 of 134 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

address listed in Condition 4.0(H)(2) of this permit. .(The Permittee should note 

that an annual emissions report, required at the same time as the fee calculation 

worksheet by 40 C.F.R. § 71.9(h), has been incorporated into the fee calculation 

worksheet fonn as a convenience.) 

6. Basis for calculating annual fee: 

i . The annual emissions fee shall be calculated by multiplying the total tons 

of actual emissions of all regulated pollutants (for fee calculation) emitted 

from the source, including fugitive emissions by the presumptive 

emissions fee (in dollars/ton) in effect at the time of calculation. 

(a) . "Actual emissions" means the actual rate of emissions in tons per 

year of any "regulated pollutant (for fee calculation)" emitted from 

a Ppart 71 source over the preceding calendar year. Actual 

emissions shall be calculated using each emissions unit's actual 

operating hours, production rates, in-place control equipment, and 

types of materials processed, stored, or combusted during the 

preceding calendar year. _[40 C.F.R. § 71.9(c)(6)]. 

(b) . Actual emissions shall be computed using methods required by the 

permit for determining compliance, such as monitoring or source 

testing data. .[40 C.F.R. § 71.9(h)(3)]. 

(c) . If actual emissions cannot be determined using the compliance 

methods in the permit, the Permittee shall use other federally 

recognized procedures.. [40 C.F.R. § 71.9(e)(2)]. 

(d) . The term "regulated pollutant (for fee calculation)" is defined in 40 

C.F.R. § 71.2. 

(e) . Prior to the start of each calendar year, the EP A will revise for 

inflation and make available the presumptive fee amount. 

i i . The Permittee shall exclude the following emissions from the calculation 

of fees: 

(a) . The amount of actual emissions of each regulated pollutant (for fee 

calculation) that the source emits in excess of 4,000 tons per year 

[40C.F.R.§71.9(c)(5)(I)]; 

(b) . Actual emissions of any regulated pollutant (for fee calculation) 

already included in the fee calculation. .[40 C.F.R. 

§ 71.9(c)(5)(h)]; and 

V ES 001637 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 126 of 134 

(c). The quantity of actual emissions (for fee calculation) of 

insignificant activities [defined in 40 C.F.R. § 71.5(c)(l l)(i)] or of 

insignificant emissions levels from emissions units identified in the 

Permittee's application [pursuant to 40 C.F.R. § 71.5(c)(l l)(ii)]. 

[40 C.F.R. § 71.9(c)(5)(iii)]. 

7. Fee calculation worksheets shall be certified as to truth, accuracy, and 

completeness by a responsible official in accordance with section 4.0(H)(1). (The 

Permittee should note that the fee calculation worksheet incorporates a section to 

help meet this responsibility.) 

8. The Permittee shall retain fee calculation worksheets and other emissions-related 

data used to determine fee payment for 5 years following submittal of fee 

payment. Emission-related data include, for example, emissions-related forms 

provided by the EP A and used by the Permittee for fee calculation purposes, 

emissions-related spreadsheets, and emissions-related data, such as records of 

emissions monitoring data and related support infonnation required to be kept in 

accordance with 40 C.F.R. § 71.6(a)(3)(h). .[40 C.F.R. § 71.9(1)] 

9. Failure of the Permittee to pay fees in a timely manner shall subject the Permittee 

to assessment of penalties and interest in accordance with 40 C.F.R. § 71.9(1). 

10. When notified by the EP A of underpayment of fees, the Permittee shall remit full 

payment within 30 days of receipt of notification. .[40 C.F.R. § 71.9(j)(l) and 

(2)]-

11. A Pennittee who believes that the EP A assessed fee is in enor and who wishes to 

challenge such fee shall provide a written explanation ofthe alleged enor to the 

E P A along with full payment ofthe EP A assessed fee. .[40 C.F.R. § 71.90X3)]. 

(C) Compliance Statement [40 C.F.R. § 71.6(a)(6)] 

1. The Permittee must comply with all conditions of this Ppart 71 permit. An y 

noncompliance with this permit constitutes a violation ofthe CA A and is grounds 

for: .[40 C.F.R. § 71.6(a)(6)(I)] 

i . Enforcement action; 

i i. Permit termination, revocation and reissuance, or modification; or 

iii. Denial of a permit renewal apphcation. 

2. It shall not be a defense for a Permittee in an enforcement action that it would 

have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this pennit. _[40 C.F.R. § 71.6(a)(6)(h)] . 

V ES 001638 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 127 of 134 

(D) Compliance Certifications [40 C.F.R. § 71.6(c)(5)] 

1. The Permittee shall submit to EP A a certification of compliance with all permit 

terms and conditions, including emission limitations, standards, or work practices, 

each calendar year for the reporting period from January 1 to December 31, 

except the first reporting period shall begin on the effective date of this permit and 

end on December 31. Al l reports shall be submitted to the EP A and shall be 

postmarked by the 30t h day following the end of the reporting period. The 

compliance certification shall be certified as to truth, accuracy, and completeness 

by a responsible official in accordance with section 4.0(H)(1) of this permit. The 

certification shall include the following: 

i . Identification of each permit term or condition that is the basis ofthe 

certification; 

i i . Identification of the method(s) or other means used for determining the 

compliance status of each term and condition during the certification 

period, and whether such methods or other means provide continuous or 

intermittent data. If necessary, the Permittee also shall identify any other 

material information that must be included in the certification to comply 

with section 113(c)(2) of the CAA , which prohibits knowingly making a 

false certification or omitting material information; 

iii. The compliance status of each term and condition of the permit, including 

whether monitoring data is continuous and whether that data or any other 

credible evidence shows the compliance is continuous. The certification 

shall identify each deviation and take it into account in the compliance 

certification; and 

iv. A statement indicating the compliance status of the source with any 

apphcable enhanced monitoring and compliance certification requirements 

ofthe CAA . 

(E) Schedule of Compliance [40 C.F.R. §§ 71.6(c)(3) and 71.5(c)(8)(iii)] 

1. For applicable requirements with which the Permittee is in compliance, the 

Permittee will continue to comply with such requirements. 

2. For applicable requirements that will become effective during the permit term, the 

Permittee shall meet such requirements on a timely basis. 

(F) Duty to Provide and Supplement Information-_[40 C.F.R. §§ 71.6(a)(6)(v) and 

71.5(b)], 

1. The Permittee shall furnish to the EPA , within a reasonable time, any information 

that the EP A may request in writing to determine whether cause exists for 

V ES 001639 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 128 of 134 

modifying, revoking and reissuing, or terminating this permit or to determine 

compliance with this permit. Upon request, the Pennittee shall also furnish to 

E P A copies of records that are required to be kept pursuant to the terms of this 

pennit, including infonnation claimed to be confidential. Infonnation claimed to 

be confidential should be accompanied by a claim of confidentiality according to 

the provisions of 40 C.F.R. pPart 2, Ssubpart B. 

2. The Permittee, upon becoming aware that any relevant facts were omitted or 

incorrect information was submitted in the permit application, shall promptly 

submit such supplementary facts or conected information. The Permittee shall 

also provide additional information as necessary to address any requirements that 

become apphcable to the facility after this permit is issued. 

(G) Enforceability [40 C.F.R. § 71.6(b)] 

A l l terms and conditions in this permit, including any provisions designated to limit the 

source's potential to emit, are enforceable by the EP A and citizens in accordance with the 

CAA . 

(H) Submissions [40 C.F.R. §§ 71.5(d), 71.6 and 71.9], 

1. A responsible official of the Pennittee shall certify as to the truth, accuracy, and 

completeness of any document required to be submitted by this permit. Such 

certifications shall state that based on information and belief formed after 

reasonable inquiry, the statements and information in the document are true, 

accurate, and complete. Except as otherwise noted, the Permittee shall submit all 

documents required to be submitted by this permit to: 

Air Enforcement and Compliance Assurance Branch (AE-17J) 

Air and Radiation Division 

E PA Region 5 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

2. The Permittee shall submit permit applications, applications for permit 

amendments, and other applicable pennit infonnation, which includes but is not 

limited to installation of control equipment, replacement of an emissions unit, fee 

calculation worksheets, and applications for renewals and permit modifications, 

to: 

Air Permits Section, 

Air Programs Branch (AR-18J) 

E PA Region 5 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

V ES 001640 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 129 of 134 

(I) Severability Clause [40 C.F.R. § 71.6(a)(5)], 

The provisions of this pennit are severable, and in the event of any challenge to any 

portion of this permit, or if any portion is held invalid, the remaining permit conditions 

shall remain valid and in force. 

(J) Permit Actions [40 C.F. R § 71.6(a)(6)(iii)] 

This permit may be modified, revoked, reopened and reissued, or terminated for cause. 

The filing of a request by the Permittee for a permit modification, revocation and 

reissuance, or termination, or of a notification of planned changes or anticipated 

noncompliance does not stay any permit condition. 

(K) Administrative Permit Amendments 

The Pennittee may request the use of administrative pennit amendment procedures for a 

permit revision in accordance with 40 C.F.R. § 71.7(d). 

(L) Minor Permit Modifications 

The Permittee may request the use of minor permit modification procedures for those 

modifications that meet the requirements contained in 40 C.F.R. § 71.7(e)(1). 

(M) Significant Permit Modifications 

The Permittee must request the use of significant pennit modification procedures for 

those modifications that meet the requirements contained in 40 C.F.R. § 71.7(e)(3). 

(N) Reopening for Cause [40 C.F.R. § 71.7(f)] 

The EP A shall reopen and revise the pennit prior to expiration under any of the following 

circumstances: 

1. Additional applicable requirements under the CA A become applicable to this 

source if the remaining pennit tenn is 3 or more years. 

2. The EP A determines that the permit contains a material mistake or that inaccurate 

statements were made in establishing the emissions standards or other terms or 

conditions of the permit. 

3. The EP A determines that the pennit must be revised or revoked to assure 

compliance with the applicable requirements. 

V ES 001641 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 130 of 134 

(O) Property Rights [40 C.F.R. § 71.6(a)(6)(iv)] 

This permit does not convey any property rights of any sort, or any exclusive privilege. 

(P) Inspection and Entry [40 C.F.R. § 71.6(c)(2)] 

Upon presentation of credentials and other documents as may be required by law, the 

Permittee shall allow EP A or an authorized representative to perform the following as 

authorized by the CAA : 

1. Enter upon the Permittee's premises where the Ppart 71 source is located or 

emissions-related activity is conducted, or where records are kept under the 

conditions of the permit; 

2. Have access to and copy, at reasonable times, any records that must be kept under 

the conditions of the permit; 

3. Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under 

the permit; and 

4. Sample or monitor at reasonable times substances or parameters for the purpose 

of assuring compliance with the permit or applicable requirements. 

(Q) Emergency Provisions [40 C.F.R. § 71.6(g)], 

1. In addition to any emergency or upset provision contained in any applicable 

requirement, the Permittee may seek to establish that noncompliance with a 

technology-based emission limitation under this permit was due to an emergency. 

To do so, the Pennittee shall demonstrate the affirmative defense of emergency 

through properly signed, contemporaneous operating logs, or other relevant 

evidence that: 

i . A n emergency occuned and that the Pennittee can identify the cause(s) of 

the emergency; 

i i . The permitted facility was at the time being properly operated; 

iii . During the period ofthe emergency the Permittee took all reasonable steps 

to minimize levels of emissions that exceeded the emissions standards, or 

other requirements in this permit; and 

iv. The Permittee submitted notice of the emergency to EP A within 2 

working days of the time when emission limitations were exceeded due to 

the emergency. This notice must contain a description ofthe emergency, 

any steps taken to mitigate emissions, and conective actions taken. This 

V ES 001642 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12,2013 

Page: 131 of 134 

notice fulfills the requirements of section 3.0(B)(2) of this permit, 

concerning prompt notification of deviations. 

2. In any enforcement proceeding, the Permittee attempting to establish the 

occurrence of an emergency has the burden of proof. 

3. A n "emergency" means any situation arising from sudden and reasonably 

unforeseeable events beyond the control of the source, including acts of God, 

which situation requires immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology-based emission limitation under 

the permit due to unavoidable increases in emissions attributable to the 

emergency. A n emergency shall not include noncomphance to the extent caused 

by improperly designed equipment, lack of preventive maintenance, careless or 

improper operation, or operator error. 

(R) Off Permit Changes [40 C.F.R. § 71.6(a)(12)] 

1. The Permittee is allowed to make certain changes without a permit revision, 

provided that the following requirements are met: 

i . Each change is not addressed or prohibited by this permit; 

i i . Each change must comply with all applicable requirements and may not 

violate any existing permit term or condition; 

iii . Changes under this provision may not include changes subject to any 

requirement of 40 C.F.R. pParts 72 through 78 or modifications under any 

provision of Title I of the CAA ; 

iv. The Pennittee must provide contemporaneous written notice to EP A of 

each change, except for changes that qualify as insignificant activities 

under 40 C.F.R. § 71.5(c)(l 1). The written notice must describe each 

change, the date ofthe change, any change in emissions, pollutants 

emitted, and any applicable requirements that would apply as a result of 

the change; 

v. The permit shield does not apply to changes made under this provision; 

and 

v i. The Permittee must keep a record describing all changes that result in 

emissions of any regulated air pollutant subject to any applicable 

requirement not otherwise regulated under this pennit, and the emissions 

resulting from those changes. 

V ES 001643 
I Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

I Expires: October 12, 2013 

Page: 132 of 134 

(S) Permit Expiration and Renewal [40 C.F.R. §§ 71.5(a)(l)(iii), 71.6(a)(l 1), 

71.7(b), 71.7(c)(l)(i) and (ii), 71.8(d)], 

1. Except as provided in section 4.0(S)(3), below, this permit shall expire five years 

from the effective date. 

2. Expiration of this permit terminates the Permittee's right to operate unless the 

Permittee has submitted a timely and complete permit renewal application to the 

permitting authority at least six calendar months, but not more than eighteen 

calendar months, prior to the date of expiration of this permit. 

3. If the Permittee submits a timely and complete permit application for renewal, 

consistent with 40 C.F.R. § 71.5(a)(1) and (2) and section 4.0(S)(2), above, but 

the permitting authority fails to issue or deny the renewal permit, then this peimit 

shall not expire until the permitting authority has issued or denied a renewal 

permit. An y permit shield granted under section 4.0(U) of this permit may be 

extended during the period that the permitting authority fails to act on the renewal 

application. 

4. If the Permittee has submitted a timely and complete application for renewal 

consistent with 40 C.F.R. § 71.5(a)(1) and (2) and section 4.0(S)(2), above,, the 

Permittee's failure to have a Ppart 71 peimit is not a violation of Ppart 71 or the 

C A A until the permitting authority takes Final action on the pennit renewal 

application. This protection shall cease to apply if, subsequent to the 

completeness determination, the Permittee fails to submit any additional 

information identified as being needed to process the application by the deadline 

specified in writing by the permitting authority. 

5. Renewal of this permit is subject to the same procedural requirements that apply 

to initial pennit issuance, including those for public participation and affected 

state and tribal review. 

6. The application for renewal shall mclude the cunent permit number, description 

of permit revisions and off-permit changes that occuned during the permit term, 

any applicable requirements that were promulgated and not incorporated into the 

pennit during the pennit term, and other infonnation required by the application 

form. 

(T) Operational Flexibility [40 C.F.R. § 71.6(a)(13)] 

The Permittee may make changes within the pennitted facility without a permit revision, 

including the addition of a new generator or replacement of an existing generator, 

provided the following conditions are met: 

1. The changes are not modifications under any provision of Title I of the CAA ; 

V ES 001644 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12,2013 

Page: 133 of 134 

2. The changes do not exceed the emissions allowed under this permit (whether 

expressed therein as a rate of emissions or in terms of total emissions); and 

3. The Permittee notifies the EP A at least 7 days in advance of the proposed 

changes. The written notification shall include a brief description of the change 

within the permitted facility, the date on which the change will occur, any change 

in emissions, and any permit term or condition that is no longer applicable as a 

result of the change. 

(U) Permit Shield [40 C.F.R. § 71.6(f)] 

1. i . Except as noted in section 4.0(U)(l)(ii) and (iii), below, compliance with 

the conditions of this permit shall be deemed compliance, as of the date of 

permit issuance, with any applicable requirements that are specifically 

identified and included in this permit or that are specifically identified in 

this permit as not applying to the facility. 

i i . Compliance with this permit shall not be deemed to be compliance with 

any requirement of 40 C.FJR . part 61, subpart V , the National Emission 

&ntsskm Standard for Pf*wd«»Afr ^ 

Remv6iy4>p ^ 

fifwrM»r^ ^ C.F.R. Ppart 63, 

Ssubpart EE E (including the appendix and any requirement of the 

General Provisions (40 C.F.R. pPart 63, sSubpart A ) identified in Table 1 

as applicable to 40 C.F.R. Pari 63. ^Subpart EEE). 

iii. The permit shield shall not apply, and compliance with this permit shall 

not be deemed to be compliance with, Pparts C and D of Title I of the 

CAA , or any requirements of the Illinois SIP, or federal or state 

regulations that govern the pennitting of major modifications to sources of 

air emissions. 

2. Nothing in this permit shall alter or affect the following: 

i . The liability of the Permittee for any violation of applicable requirements 

prior to or at the time of permit issuance; 

i i . The ability of EP A to obtain information under Section 114 of the CAA ; 

iii. The applicable requirements of the acid rain program, consistent with 

section 408(a) of the CAA ; or 

iv. The provisions of Section 303 of the CA A (emergency orders), including 

the authority of the Administrator under that section. 

VES 001645 
Veolia Environmental Services 

Permit No.: V-IL-1716300103-08-01 

Expires: October 12, 2013 

Page: 134 of 134 

(V) Credible Evidence [62 Fed. Reg. 8314 (February 24,1997); 42 U.S.C. § 7413] 

Notwithstanding the conditions of this permit specifying compliance practices for 

applicable requirements, any person (including the Permittee) may also use other credible 

evidence to establish compliance or noncompliance with applicable requirements. 

V ES 001646 
UNITED STATES ENVIRONMENTAL PROTECTION AGENC Y 

REGION 5 

In the Matter of: 

Veolia Environmental Services 

7 Mobile Avenue 

Sauget, St. Clair County, Illinois 

Title V Permit No. V-IL-1716300103-08-01 

Proceeding Pursuant to Title V 

of the Clean Air Act, 

42 U.S.C. § 7661, etseq. 

NOTICE OF INTENT T O DENY A PERMIT MODIFCATION REQUEST B Y 

VEOLIA ENVIRONMENTA L SERVICES 

AND 

PROPOSED REOPENING OF VEOLIA'S TITLE V PERMIT 

This notice is to inform the public that the U.S. Environmental Protection Agency has received 

and reviewed an application from Veolia Environmental Services (Veolia), located at 7 Mobile 

Avenue, Sauget, St. Clair County, Illinois, to modify its Clean Air Act Title V operating permit 

to add feedrate limits for certain heavy metals. The heavy metals include mercury, semivolatile 

metals (cadmium and lead), and low volatile metals (arsenic, beryllium, and chromium). EP A 

has determined that the requested limits are unacceptable under existing federal regulations and 

guidance. EP A is proposing to deny Veolia's application to incorporate feedrate limits, and to 

reopen Veolia's Title V permit to incorporate feedrate limits that EP A considers to be supported 

by available performance test data. EP A is issuing this notice pursuant to 40 C.F.R. § 71.11 (a) 

and (d). 

A. Summary of Veolia's Request 

Veolia's Title V permit, which EP A issued on September 12, 2008 in accordance with 40 C.F.R. 

Part 71, requires Veolia to submit a significant modification application to incorporate heavy 

metal feedrate limits. The heavy metal feedrate limits (also called operating parameter limits or 

OPLs) are required by the National Emission Standards for Hazardous Air Pollutants (NESHAP) 

from Hazardous Waste Combustors, 40 C.F.R. Part 63, Subpart EEE . The limits are reported as 

pounds of metal fed into each incinerator per hour. 

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, pursuant to 40 C.F.R. § 63.1209(l)(l)(v) and (n)(2)(vii), and requested that EP A 

incorporate the extrapolated feedrates into the Title V permit as operating parameter limits. 

Veolia has requested feedrate limits that are three times higher than the performance test 

feedrates. 

1 

V ES 001647 
B. Facility Description 

Veolia owns and operates a hazardous waste incinerator in Sauget, St. Clair County, Illinois. 

Veolia's Sauget facility is a treatment, storage and disposal facility, which accepts offsite waste 

for disposal through incineration. Veolia receives containers and bulk shipments of hazardous 

and solid wastes, transfers them to temporary storage facilities, processes them, and incinerates 

them in one of three combustion units. The facility includes two fixed-hearth, dual chamber, 

multi-type feed incinerators (Incinerators 2 and 3), each rated at 16 million British thermal units 

per hour (mmBtu/hr), and one rotary kiln incinerator (Incinerator 4), rated at 50 mmBtu/hr. 

Incinerators 2 and 3 each use spray dry absorbers with lime slurry injection to control hydrogen 

chloride emissions and baghouses for particulate matter. Incinerator 4 uses a spray dry absorber 

for hydrogen chloride control, an activated carbon injection system for mercury control, and a 

baghouse for particulate matter control. 

Veolia's Sauget facility is located just east of St. Louis, Missouri, in an area with potential 

environmental justice concerns. 

C. Proposed Actions 

Upon review of Veolia's application, which EP A received on March 2, 2010, EP A has 

determined that Veolia cannot achieve the maxhnum achievable control technology (MACT ) 

standards for heavy metals under the Hazardous Waste Combustor NESHAP , 40 C.F.R. Part 63, 

Subpart EEE , using the requested feedrate hmits. EP A therefore intends to 1) deny the 

application for extrapolated feedrate limits, 2) pursuant to 40 C.F.R. § 71.7(f)(iv) reopen 

Veolia's permit to incorporate feedrate limits that EP A considers to be supported by the available 

test data, and 3) supplement monitoring requirements, as necessary, to assure compliance with 

the proposed feedrate limits. Thus, EP A is making available for public comment a draft 

significant modification to Title V Permit No. V-IL-1716300103-08-01 (draft permit) that 

contains heavy metals feedrate limits proposed by EPA . The draft pennit is subject to a 

minimum 30-day public comment period as required by 40 C.F.R. §§71.11 (a)(3) and (d). See 

Section E below for details on the public comment period. 

D. Basis for the Proposed Action 

A s required by 40 C.F.R. § 71.11(b), EP A has provided the reasons supporting our determination 

in a statement of basis, which is available as part of the administrative record for this action. 

E P A also has summarized those reasons below. 

/ . Mercury Feedrate Limits 

Based on the available information, EP A does not believe that any extrapolation is appropriate 

for mercury because a) Veolia's requested mercury feedrate limits could result in violations of 

the applicable mercury MAC T limits; b) for Incinerator 4, Veoha has not provided sufficient 

data to understand the relationship between the necessary amount of activated carbon needed to 

maintain the calculated system removal efficiency at different mercury federates; and c) since 

mercury was spiked during comprehensive performance testing, the mercury spike rates and the 

2 

V ES 001648 
native mercury content of the waste should be used to set the feedrate limit without 

extrapolation. Therefore, EP A is proposing to deny Veolia's application to modify its Title V 

permit and, because EP A has determined that Veolia's current Title V permit does not assure 

compliance with the standards at 40 C.F.R. §63.1219, incorporate into Veolia's Title V permit as 

mercury feedrate limits the feedrates at which Veolia conducted its 2008 testing. 

2. Semi-volatile metals and low-volatile metals 

Veolia has applied for a modification to its permit to incorporate feedrate limits for semi-volatile 

metals (SVM) and low-volatile metals (LVM ) which are significantly higher than the highest 

reported historical feedrates for these metals - in some cases more than twice the maximum 

historical rates. EPA's policy is not to grant requests for extrapolated feedrate limits that are 

significantly higher than the reported historical normal metal feedrates for the source. See, for 

example, 62 Federal Register 24238. Therefore, we are proposing to deny Veolia's application 

to modify its Title V permit to incorporate extrapolated feedrate limits for SV M and LVM . A t 

the same time, EP A has detennined that, because Veolia's current Title V permit does not 

include OPLs for SV M and LVM , it does not assure compliance with the hmitations at 40 C.F.R. 

§63.1219. Thus, we are proposing to reopen Veolia's permit pursuant to 40 C.F.R. §71.7(f)(iv) 

to incorporate into Veolia's Title V permit SV M and LV M feedrate limits that EP A considers to 

be supported by the available test data. 

E . Request for Public Comment 

E P A requests public comment on our proposal to deny Veoha's request to modify its Title V 

permit to incorporate extrapolated feedrate limits and on the heavy metal feedrate limits and 

proposed monitoring requirements in the draft permit. The public comment period for both the 

denial of Veolia's modification request and EPA's modifications to the permit ends March 4, 

2013. Members ofthe public may review the administrative record for the modifications 

contained in the draft permit, including copies ofthe draft permit prepared by EPA , the statement 

of basis for the draft permit, the application, and all data and supporting materials submitted by 

the applicant at www.reguiations.gov docket ID EPA-R05-OAR-2012-0649 or at EP A Region 5, 

77 West Jackson Boulevard, 18th floor, Chicago, Illinois 60604, by contacting David Ogulei at 

(312) 353-0987 or ogulei.david@epa.gov. Al l documents will be available for review at the 

E P A Region 5 office in Chicago Monday through Friday from 8:15 A M until 4:45 P M 

(excluding federal holidays). 

Pursuant to 40 C.F.R. §71.11 (f), EP A is holding a Public Hearing on February 19,2013 at the 

Southern Illinois University Edwardsville - East St. Louis Higher Education Campus, 601 James 

R. Thompson Blvd., East St. Louis, Illinois 62201 from 3:00 P M to 7:00 PM . The public 

hearing will provide interested parties the opportunity to present data, views, or arguments 

concerning the proposed action. The EP A may ask clarifying questions during the oral 

presentations, but will not respond to the presentations at that time. The EP A will consider 

written statements and supporting information submitted during the comment period with the 

same weight as any oral comments and supporting information presented at the public hearing. 

Supporting materials submitted with written comments must be included in full and may not be 

incorporated by reference unless they are already part of the administrative record, or consist of 

3 

V ES 001649 
state or federal statutes or regulations, EP A documents of general applicability, or other 

generally available reference materials. 

If you would like to provide oral testimony at the hearing, you must register your name on the 

sign-in sheet that will be available at the hearing venue on the date of the hearing. Yo u will be 

called to testify on a first-come-first-serve basis. Oral testimony will generally be limited to five 

to ten minutes, depending on the number of speakers, for each commenter to address the draft 

permit. EP A will not provide equipment for commenters to show overhead slides or make 

computerized slide presentations. Commenters should notify David Ogulei at 

Ogulei.david@epa.gov, by [insert date], if they need specific translation services for nonEnglish speaking commenters. 

The EP A encourages commenters to provide written versions of their oral testimonies either 

electronically or on computer disk or C D RO M or in paper copy. Written comments and 

requests to receive notices of any future actions may be submitted to EP A by [insert date], using 

one of the following methods: (1) www.regulations.gov: Docket ID No. EPA-R05-OAR-2012-

0649; (2) http://www.epa.gov/region5/publicnotices/veolia.htm; (3) E-mail: 

Ogulei.david@epa.gov; (4) Fax: (312) 692-2080; or, (5) Mail: George Czerniak, Director, Air 

and Radiation Division (A-18J), at the above EP A address. Al l written comments should 

include: the reason for interest in the draft permit, requested actions for EP A to take, and the 

justification for such actions. Al l comments should include sufficient specificity and regulatory 

references to allow EP A to investigate the merits ofthe position. Al l comments will be included 

in the public docket without change and may be made available to the public, including any 

personal information provided, unless the comment includes Confidential Business Infonnation 

(CBI) or other information whose disclosure is restricted by statute. Information that you 

consider CBI or otherwise protected should be clearly identified as such and should not be 

submitted through e-mail. Ifyo u send e-mail directly to EPA , your e-mail address will be 

captured automatically and included as part of the public comment. 

F. Final Decision 

Shortly after the close of the public comment period, and after EP A has considered all relevant 

comments received prior to the end of the pubhc comment period and all comments made during 

the public hearing, EP A will decide whether or not to proceed with denial of Veolia's requested 

permit modifications and adoption of EPA's proposed feedrate limits and monitoring 

requirements. 

If EP A makes a final decision to deny the modification request and adopt EPA's proposed 

feedrate limits, the final decision will become effective 30 days after the service of notice ofthe 

decision, pursuant to 40 C.F.R. § 71.1 l(i)(2), unless (i) a later effective date is specified in the 

decision; (ii) review is requested under 40 C.F.R. § 71.11(1) (in which case the specific terms and 

conditions of the permit which are the subject of the request for review shall be stayed); or (iii) 

no comments requested a change in the draft pennit, in which case the permit shall become 

effective immediately upon issuance. If EP A determines that the initial decision to deny 

Veolia's request was inconect, we will withdraw the notice of intent to deny and proceed to 

prepare a revised draft permit under 40 C.F.R. § 71.11 (a)(3) and (4). 

4 

V ES 001650 
The final permit is a public record that can be obtained upon request. A statement of reasons for 

changes made to the draft permit and responses to comments received will be sent to all persons 

who commented on the draft permit. Please note that an e-mail or postal address must be 

provided with your comments if you wish to receive direct notification of EPA's final decision 

regarding the permit and its responses to comments submitted during the public comment period. 

If you believe any condition of the draft permit is inappropriate or that our initial decision to 

deny Veolia's application or prepare the draft permit is inappropriate, you must raise all 

reasonably ascertainable issues and submit all reasonably ascertainable arguments supporting 

your position by the end of the comment period. 

G. Appeal Procedures 

Within 30 days after a final permit decision has been issued, any person who filed comments or 

participated in the public hearing may petition the Environmental Appeals Board to review any 

condition ofthe permit decision, in accordance with 40 C.F.R. §71.11(1). Appeals should be 

filed with the Hearing Clerk at the following address: 

Environmental Appeals Board 

M C 1103B 

U.S. Environmental Protection Agency 

401 M Street, SW 

Washington, D C 20460 

5 

V ES 001651 
United States Environmental Protection Agency, Region 5 

Air Programs Branch 

Air & Radiation Division 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

STATEMEN T OF BASIS 

Air Pollution Control 

Title V Permit to Operate 

Permit No. V-IL-1716300103-08-01 

Significant Modification 

November 2012 

The purpose of this document is to set forth the legal and factual bases for permit conditions, 

including references to applicable provisions of the Clean Ai r Act (CA A or Act) and 

implementing regulations. This document also gives the derivation of conditions as required by 

40 C.F.R. § 71.11(b). 

CONTENTS 

1.0. GENERA L INFORMATION 2 

(A) Applicant and Stationary Source Information 2 

(B) Facility Description 2 

(C) Area Classification 2 

(D) Basis for Title V Applicability 3 

(E) Enforcement Issues and Permit Shield 3 

(F) Permitting History 4 

2.0. PROCESS DESCRIPTION AND EMISSIONS 5 

(A) Process Description 5 

(B) Insignificant Activities 7 

3.0. BACKGROUND ON CURREN T PERMITTING ACTIONS 7 

(A) Regulatory Background 7 

(B) Pollutants Affected by this Permit Action 8 

(C) Extrapolation of Performance Test Feedrates 9 

(D) Application Review Timeline 10 

4.0. UNIT-SPECIFIC CONDITIONS 12 

(A) Applicable Requirements 12 

(B) HW C MAC T OPLs 12 

(C) Non-Applicability Determinations 16 

(D) Periodic Monitoring 16 

(E) Streamlining 22 

5.0. ENVIRONMENTAL JUSTICE 22 

V ES 001652 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

1.0. GENERA L INFORMATION 

(A) Applicant and Stationary Source Information 

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

Facility Name & Address: Veolia Environmental Services 

7 Mobile Avenue 

Sauget, Illinois 62201 

SIC Code: 4953 

Responsible Official & Mailing 

Address: 

Doug Harris 

7 Mobile Avenue 

Sauget, Illinois 62201 

Telephone: (618)271-2804 

Facility Contact: Dennis Warchol, (618) 271-2804 

(B) Facility Description 

Veolia Environmental Services Technical Solutions, L.L.C. (Veolia or Permittee) owns and 

operates a hazardous waste incinerator in Sauget, St. Clair County, Illinois. Veolia's Sauget 

facility is a treatment, storage and disposal facility, which accepts offsite waste for further 

disposal through incineration. Containers and bulk shipments of hazardous and solid wastes are 

received, analyzed and transferred to temporary storage facilities, processed and incinerated in 

one of three combustion units. The facility includes two fixed-hearth, dual chamber, multi-type 

feed incinerators (Combustion Units 2 and 3), each rated at 16 million British thermal units per 

hour (rmriBtu/hr), and one rotary kiln incinerator (Combustion Unit 4), rated at 50 mmBtu/hr. 

Combustion Units 2 and 3 each use spray dry absorbers with lime slurry injection to control 

hydrogen chloride (HCI) emissions and baghouses for particulate matter (PM). Combustion Unit 

4 uses a spray dry absorber for HCI control, an activated carbon injection system for mercury 

(Hg) control, and a baghouse for P M control. 

Veolia's Sauget facility is operating under a Title V peimit that EP A issued on September 12, 

2008, pursuant to 40 C.F.R. Part 71. 

(C) Area Classification 

St. Clair County, Illinois is designated as a moderate nonattainment area for the 8-hour ozone 

National Ambient Air Quality Standard (NAAQS). It is also designated as a nonattainment area 

2 

V ES 001653 
Veoli a Environmental Services Statement o f Basis 

Permit No. V-IL-1716300103-08-01 Sigmficant Modification 

for the 1997 annual NAAQ S for particulate matter less than 2.5 micrograms (PM2.5). 1 St. Clair 

County is in attainment with NAAQ S for all other criteria pollutants. 

(D) Basis for Title V Apphcability 

Veolia requires a Title V permit because it is a major source of hazardous air pollutant (HAP) 

emissions and because it is subject to the requirements established under 40 C.F.R. Part 63, 

Subpart EEE , "National Emission Standards for Hazardous Air Pollutants from Hazardous Waste 

Combustors" (HWC MACT) . 

The current permitting action is a significant modification to Veolia's existing Title V operating 

pennit to add feedrate limits for certain heavy metals. The heavy metals include mercury, 

semivolatile metals (cadmium and lead), and low volatile metals (arsenic, beryllium, and 

chromium). EP A is modifying Veolia's Title V permit pursuant to the significant modification 

procedures of 40 C.F.R. § 71.7(e)(3). 

(E) Enforcement Issues and Permit Shield 

On June 12, 2008, the U.S. Environmental Protection Agency issued a Finding of Violation 

(FOV) to Veolia notifying the company that the Agency found it to be in violation of the CA A 

and the HW C MACT , 40 C.F.R. Part 63, Subpart EE E (64 Fed. Reg. 53038). On August 24, 

2012, after further investigation into Veolia's compliance with the HW C MACT , EP A issued 

another FO V to Veolia notifying Veolia that the Agency found it to be in violation of the CA A 

and the HW C MACT . 

EPA's regulations at 40 C.F.R. Part 71 allow permitting authorities the discretion to include a 

provision in the permit stating that compliance with the conditions of the permit shall be deemed 

compliance with any applicable requirements as of the date of permit issuance, which is 

commonly refened to as a "pennit shield". (See 40 C.F.R. § 71.6(f).) Because a resolution of 

the allegations discussed above and any additional allegations identified as a result of the 

ongoing investigation may result in incorporation into the permit of a compliance schedule to 

bring this facility into comphance, EP A has determined that it is not appropriate at this time to 

grant a permit shield for the applicable requirements of the HW C MAC T standard, including 

those portions of the general provisions of Part 63 applicable to the source as a result of the 

applicability of 40 C.F.R. Part 63, Subpart EEE . EP A intends to reconsider whether a permit 

shield for these provisions is appropriate when EP A revises the permit, if necessary, to 

incorporate changes pursuant to the settlement of the enforcement action, and may provide a full 

permit shield at that time. 

On May 23, 2011, EPA took final action determining that the Saint Louis PM2.5 nonattainment area in Illinois and 

Missouri has attained the 1997 annual PM2.s NAAQS , based upon quality-assured, quality-controlled, and certified 

ambient air monitoring data for the 2007-2009 monitoring period. This final determination suspends the States' 

obligation to submit a number of plans for this area but is not equivalent to redesignating the area to attainment. 

The designation ofthe area will remain nonattainment for the 1997 annual PM2.5 NAAQS until such time as EPA 

determines that this area meets the Clean Air Act requirements for redesignation to attainment. See 76 Fed. Reg. 

29652. 

3 

V ES 001654 
Veoli a Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Sigmficant Modification 

In addition, EP A notes that 40 C.F.R. § 71.6(f)(3) expressly provides that nothing in any Part 71 

permit shall alter or affect the following: 

(i) The provisions of section 303 of the Act (emergency orders), including the authority of 

the Administrator under that section; 

(ii) The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; 

(iii) The applicable requirements ofthe acid rain program, consistent with section 408(a) of 

the Act; or 

(iv) The ability of EP A to obtain information from a source pursuant to section 114 of the 

Act. 

E P A may reopen the permit to add or modify permit terms and conditions if EP A determines that 

additional measures are necessary to assure compliance. (See permit conditions 4.0 (J), (K), (L), 

(M), and (N).) 

(F) Permitting History 

(a) New Source Review (NSR) Permits 

The Illinois Environmental Protection Agency (IEPA) has issued the following construction 

permits to this source: 

Permit # Date Issued 

00110030 2/6/01 

95080025 8/11/95 

87100024 8/19/88 

88010001 8/3/88 

88030101 6/27/88 

83120053 9/2/86 

(b) Title VPermits 

E P A issued a final Title V permit (Permit No. V-IL-1716300103-08-01) to Veolia on September 

12, 2008, and the permit became effective on October 12, 2008. 2 Prior to issuing the final 

permit, EP A reviewed historical metal feedrate data supplied by Veolia to support Veolia's 

proposed operating parameter limits (OPLs) for hazardous air pollutants required by the HW C 

MACT , 40 C.F.R. Part 63, Subpart EEE . EP A concluded that reliance on the OPLs submitted by 

Veolia would not assure Veolia's compliance with the applicable requirements in the HW C 

2

 Final permit and support documents are available at www.regulations.gov; Docket ID: EPA-R05-OAR-2008-0235 

4 

V ES 001655 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Sigmficant Modification 

MACT. 3 Specifically, EP A determined that the past data were not reliable for determining 

feedrate OPLs for mercury (Hg), semivolatile metals (SVM) - lead (Pb) and cadmium (Cd), or 

low volatile metals (LVM ) - arsenic (As), chromium (Cr) and beryllium (Be)). 

Based upon EPA's review of Veolia's historical data, on February 22, 2008, EP A issued a 

Request for Information under Section 114 of the Act, 42 U.S.C. § 7414, requiring Veolia to 

complete comprehensive performance tests on all three combustion units. The required testing 

was limited to mercury, low volatile metals and semi-volatile metals. 4 Veolia conducted the 

comprehensive performance tests in August and September 2008. 

Since the test results and the OPLs were not available at the time that EP A made the initial 

permit available for public comment, EP A provided the opportunity for the public to comment 

on the compliance schedule, Veolia's performance test plan, and the OP L calculation 

methodologies. EP A required Veolia to submit the results of its testing and a request for a 

significant modification to its Title V permit to incorporate OPLs by October 10, 2008. 

On October 10,2008, Veolia submitted to EP A the August and September 2008 test results, and 

requested a significant modification to its Title V permit to incorporate OPLs. The significant 

modification apphcation is the subject of the current permitting action. 

2.0. PROCESS DESCRIPTION AND EMISSIONS 

(A) Process Description 

Veolia has three combustion units: Units 2, 3, and 4. Combustion Unit 1 was decommissioned 

and closed in 1992. Combustion Units 2 and 3 are custom fixed hearth incinerators. 

Combustion Unit 4 is a rotary kiln incinerator (transportable system converted to a stationary 

unit). Al l three combustion units are fed liquid and solid waste streams, although Veolia 

processes bulk waste only in Combustion Unit 4. 

Veolia receives a variety of wastes in containers (drums, roll offs, etc.) and in bulk. These 

wastes come into the facility predominantly in the form of solids and liquids. Drums are stored 

in various buildings on the property (including an explosives magazine), depending on the 

characteristics of the material. 

Drummed liquids may be transferred via drum pumps to tank farm #1 or tank farm #3, or may be 

directly injected into one of the three combustion units. Tank farm #1, which services 

3

 See Statement of Basis for Permit No. V-IL-1716300103-08-01 at 8 , September 12, 2008 (citing April 16, 2008 

memorandum from Charles Hall to the permit file, "Operating Parameter Limits for Veolia ES Technical Solutions, 

LLC, Sauget, IL."). Available at www.repulations.gov: Docket ID: EPA-R05-OAR-2008-0235. 

4

 Veolia explained that it could not meet the deadlines in the February 22, 2008 Request for Information because 

stack testing crews and materials were not available. Therefore, EPA extended the testing schedule and limited the 

testing to mercury, low volatile metals and semi-volatile metals. For all other required OPLs, EPA incorporated into 

the draft Title V permii parameters that EPA calculated based upon data submitted by Veolia. See Statement of 

Basis for Permit No. V-IL-1716300103-08-01, September 12,2008. 

5 

V ES 001656 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Sigmficant Modification 

Combustion Units 2 and 3, is made up of ten vertical fixed roof storage tanks. Tank farm #3, 

which services Combustion Unit 4, is made up of eight vertical fixed roof storage tanks. These 

storage tanks release fugitive emissions during filling and emptying of the tanks, as well as when 

the tanks are empty. Emissions from these storage tanks are controlled by an individual carbon 

adsorption unit on each tank. 

Bulk solid wastes are stored in four pits in the bulk feed building. The building is enclosed and 

equipped with a cyclone, baghouse, and carbon adsorption unit. Veolia's Title V permit requires 

Veolia to operate the enclosed building under permanent negative pressure. A clam shell moves 

bulk solids from the bulk feed building through an enclosed gallery to Combustion Unit 4. 

Material processing occurs at units MP-1 and MP-2 , and the lab pack repack areas. Material 

processing involves the repackaging of drummed solids into more manageable containers for 

subsequent incineration. Some of these solids may have free liquids, which are fixed with an 

inert absorbent material before repackaging. Lab packs are opened and repackaged into 

acceptable containers for charging to the combustion units. 

Each combustion unit has a primary combustion chamber (PCC) and a secondary combustion 

chamber (SCC). The PCCs and SCCs have natural gas-fired auxiliary burners, which are used 

during startup, shutdown, malfunctions and additional heat input. Liquid wastes are fed into the 

combustion units by air atomized injection nozzles. These feeds are made up of wastes with 

high energy content (high Btu), and aqueous streams, which are fed to the PCCs on all three 

units. High Btu streams can be fed to the SCCs as well; however, this is done only on 

Combustion Unit 4. Solid waste is fed in batches to the PCCs by conveyors. Each combustion 

unit has an air pollution control train consisting o f a spray dryer absorber and baghouse. In 

addition, Combustion Unit 4 has a tempering chamber and activated carbon injection. 

The three combustion units are supported by lime handling systems and ash handling systems. 

The lime handling systems are made up of lime storage silos and slurry mix tanks. There is one 

system for Combustion Units 2 and 3 and one for Combustion Unit 4. The silos are controlled 

by bin vents. As h handling consists of material collection from the combustion chambers, the 

spray dryer and baghouse. The combustion chamber ash is collected in roll-off boxes. Veolia 

tarps the roll-off boxes to minimize P M emissions. Veolia continuously monitors each 

combustion unit for carbon monoxide and hydrogen chloride/chlorine emissions via a continuous 

emission monitoring system. 

Veolia operates small combustion sources comprising a natural gas-fired boiler as well as two 

emergency generators and a portable Tioga heater. 

Veolia also operates a drum crusher. Drums that are unsuitable for reuse are crushed at the drum 

crusher. Some empty drums may contain residual waste when crushed. These emissions are not 

controlled. 

Fugitive emissions occur facility-wide. The most significant source of fugitive emissions is 

equipment leaks from pipelines and pumps that handle liquid organic waste. The evaporation of 

6 

V ES 001657 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

organics from spills, leaks, and drum sampling also contribute to facility-wide fugitive 

emissions. 

(B) Insignificant Activities 

a) 2.5 mmBtu/hr Tioga portable boiler 

b) Two emergency generators (<112kW) 

c) As h handling 

d) Handling of spent dry scrubber solids 

e) Lime unloading and proportioning 

f) Gasoline storage and dispensing 

g) Use of absorbent material 

h) General vehicle maintenance and servicing (assumed to include diesel fuel handling) 

i) Laboratory 

j) Piping and storage system for natural gas 

k) Non-halogenated cold cleaning degreasers 

1) Internal combustion engines of motor vehicles 

m) Storage and handhng of closed drums 

3.0. BACKGROUN D ON CURRENT PERMITTING ACTIONS 

Today's permitting action is a significant modification to Veolia's Title V permit to add feedrate 

limits for heavy metals. In addition to minor formatting changes, EP A has revised condition 

2.1(C)(2) by adding feedrate limits for mercury, semi-volatile metals, and low volatile metals. 

E P A has also included additional periodic monitoring requirements for the proposed feedrate 

limits in conditions 2.1(D)(l)(i) and 2.1(D)(4)(d)(2). See Section 4.D. for details. 

(A) Regulatory Background 

The HW C MAC T requires subject facilities to develop OPLs either by using existing 

performance tests or by performing new tests.5 As allowed by 40 C.F.R. § 63.1207(c)(2), Veolia 

chose to use previous emissions test data in lieu ofthe initial comprehensive performance test. 

As part of its application for the initial Title V permit, Veolia submitted its notice of compliance 

(NOC), including proposed OPLs, some of which Veoha calculated based upon historical 

emissions test data. EP A reviewed the data that Veolia used to calculate the OPLs and 

concluded that reliance on the OPLs submitted by Veolia would not assure Veolia's compliance 

with the applicable requirements in the HW C MACT . 

Hazardous waste combustors generally emit their highest emissions while demonstrating 

compliance with emission standards during Resource Conservation and Recovery Act (RCRA) 

compliance testing. For real-time compliance during periods between compliance tests, sources 

are required to establish and comply with operating parameters that are representative of 

operating levels achieved during compliance testing. Thus, the emission levels achieved during 

See 40 C.F.R. § 63.1207. 

7 

V ES 001658 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

these compliance tests are typically the highest emission levels a source emits under reasonably 

anticipatable circumstances. 

To ensure that these operating limits do not impede normal day-to-day operations, sources 

generally take measures to operate during compliance testing under conditions that are at the 

extreme high end of the range of normal operations. For example, sources often feed ash, 

metals, and chlorine during compliance testing at substantially higher than normal levels (e.g., by 

spiking the waste feed) to maximize the feed concentration, and they often detune the air 

pollution control equipment to establish operating limits on the control equipment that provide 

operating flexibility. 7 

By designing the compliance test to generate emissions at the extreme high end of the normal 

range of emissions, sources can establish operating limits that account for variability in 

operations (e.g., composition and feedrate of feedstreams, as well as variability of pollution 

control equipment efficiency) and that do not impede normal operations. Thus, the feedrate limit 

would be based on waste levels fed during the comprehensive performance test unless the 

regulatory authority approves a request for the source to extrapolate to a higher allowable 

feedrate (and emission rate) limit. 8 

(B) Pollutants Affected by this Permit Action 

The proposed permit action sets feedrate limits for mercury, semi-volatile metals (cadmium and 

lead), and low-volatile metals (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. EP A is setting feedrate limits in this action that comply with applicable 

federal regulations. Each ofthe pollutants affected by this action is described in further detail 

below. 

Mercury is a naturally occurring element (Hg on the periodic table) that is found in air, water 

and soil. It exists in several forms: elemental or metallic mercury, inorganic mercury 

compounds, and organic mercury compounds. Elemental or metallic mercury is a shiny, silverwhite metal and is liquid at room temperature. If heated, it is a colorless, odorless gas. 

Exposures to mercury can affect the human nervous system and harm the brain, heart, kidneys, 

lungs, and immune system. 

Cadmium, in its purest form, is a soft silver-white metal found naturally in the earth's crust. 

Cadmium doesn't have a distinct taste or smell. Breathing high doses of cadmium can irritate 

and damage the lungs and can cause death. However, the greatest concern is from exposure to 

lower doses of cadmium over a long period. The lower and long-term exposure to cadmium 

through air can cause kidney damage. Although the damage is not life threatening, it can lead to 

the formation of kidney stones and affect the skeleton, which can be painful and debilitating. 

6

 69 Fed. Reg. 21197, 21218, April 20, 2004, HWC MACT Proposed Rule. See also 40 C.F.R. §§ 63.1206(b)(2), 

63.1207(f)(1) and (g)(1). 

7

 69 Fed. Reg. at 21218. 

8

 69 Fed. Reg. at 21309-10, fh. 202 & 204. 

8 

V ES 001659 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

Lung damage has also been observed. The U.S. Department of Health and Human Services has 

classified cadmium and certain cadmium compounds as probable or suspected carcinogens 

(substances that cause cancer). 

Lead is a naturally occurring metal found in small amounts in rock and soil. Exposure to lead 

occurs mainly through inhalation of air and ingestion of lead in food, water, soil, or dust. Once 

taken into the body, lead distributes throughout the body in the blood and is accumulated in the 

bones. Depending on the level of exposure, lead can adversely affect the nervous system, kidney 

function, immune system, reproductive and developmental systems and the cardiovascular 

system. Infants and young children are especially sensitive to even low levels of lead, which 

may contribute to behavioral problems, learning deficits and lowered IQ. 

Arsenic is a naturally occurring element widely distributed in the earth's crust. Inorganic forms 

of arsenic are found throughout the environment; it is released into the air by volcanoes, the 

weathering of arsenic-containing minerals and ores, and by commercial or industrial processes. 

Short-term high-level inhalation exposure to arsenic dust or fumes can cause nausea, diarrhea, 

abdominal pain and nervous system disorders. Long-term inhalation exposure to inorganic 

arsenic can cause irritation of the skin and mucous membranes and lung cancer. 

Beryllium is an inorganic metallic element in the periodic table. Because it is an element, it 

does not degrade nor can it be destroyed. Compounds of beryllium are either white or colorless 

and do not have a particular smell. Short-term inhalation exposure to high levels of beryllium 

has been observed to cause irritation and swelling ofthe lungs; after exposure ends, these 

symptoms may be reversible. Long-term inhalation exposure of humans to beryllium has been 

reported to cause chronic beryllium disease, in which noncancerous lesions develop in the lung. 

Human epidemiology studies are limited, but suggest a causal relationship between beryllium 

exposure and an increased risk of lung cancer. 

Chromium occurs naturally in rocks, animals, plants, and soil. It can exist in several different 

forms. Depending on the form it takes, it can be a liquid, solid, or gas. The form of chromium 

of most concern from a health perspective is chromium ( VI), also called hexavalent chromium. 

Inhalation of hexavalent chromium at high levels can damage the respiratory system and cause 

cancer. Exposure to chromium occurs from ingesting contaminated food or drinking water or 

breathing contaminated air. It is odorless and tasteless. Air emissions of chromium are 

predominantly of chromium (III), an essential nutrient that helps the body use sugar, protein, and 

fat and in the form of small particles or aerosols. 

(C) Extrapolation of Performance Test Feedrates 

40 C.F.R. § 63.1209(l)(l)(v) and (n)(2)(vii) allows each facility to include as part ofthe 

performance test plan required under 40 C.F.R. §§ 63.7(b) and (c) and 63.1207(e) and (f) a 

request to use the mercury, SV M and LV M feedrates and associated emission rates during the 

comprehensive performance test to extrapolate to higher allowable feedrate limits and emission 

rates, subject to a number of statutory and policy provisions. 9 EP A has previously provided the 

9

See also 64 Fed. Reg. 52827, 52946-47, September 30, 1999; 40 C.F.R. § 63.1209(l)(l)(v) and (n)(2)(vii). 

9 

V ES 001660 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

following guidance on extrapolation of performance test feedrate levels to calculate metal 

feedrate limits: 1 0 

Extrapolation can be advantageous because it avoids much of the spiking that sources 

normally undertake during comphance testing and the associated costs, risks to operating 

and testing personnel, and environmental loading from emissions. Under an approved 

extrapolation approach, you would be required to feed metals at no less than normal rates 

to narrow the amount of extrapolation requested. Further, we expect that some spiking 

would be desired to increase confidence in the measured, performance test feedrate levels 

that will be used to project feedrate limits (i.e., the errors associated with sampling and 

analyzing heterogeneous feedstreams can be minimized by spiking known quantities). 

Extrapolation approaches that request feedrate limits that are significantly higher than the 

historical range of feedrates should not be approved. Extrapolated feedrate limits should 

be limited to levels within the range of the highest historical feedrates for the source. We 

are taking this policy position to avoid creating an incentive to burn wastes with higher 

than historical levels of metals. Metals are not destroyed by combustion but rather are 

emitted as a fraction of the amount fed to the combustor. If [a source wants to] burn 

wastes with higher than historical levels of metals, [the source] must incur the costs and 

address the hazards to plant personnel and testing crews associated with spiking metals 

into [the] feedstreams during comprehensive performance testing. 

(D) Application Review Timeline 

On October 10, 2008, Veolia submitted a request for a significant modification to its Title V 

permit to incorporate feedrate limits (i.e., OPLs). Veolia requested that EP A estimate metal 

feedrate limits by extrapolating the results of tests performed in August and September 2008 to 

higher metal feedrates, pursuant to 40 C.F.R. § 63.1209(l)(l)(v) and (n)(2)(vii), and to 

incorporate the extrapolated OPLs into the Title V permit. Veolia applied for feedrate limits that 

were 7 to 10 times higher than the 2008 comprehensive tests feedrates. 

E P A denied Veolia's requested extrapolation in a letter dated July 17, 2009. EP A denied 

Veolia's request because: 1) Veolia did not consistently conduct its performance tests at the 

"extreme range of normal"; therefore, EP A could not reliably conclude that Veolia would have 

equal system removal efficiencies at the requested feedrate limits; 2) EP A believed that 

extrapolation of mercury feedrates for Unit 4 is not appropriate since the tests did not provide 

sufficient data to understand the relationship between the necessary amount of activated carbon 

needed to maintain the calculated system removal efficiency and different mercury feedrates; and 

3) EP A had a number of concerns with the 2008 comprehensive test procedures. 

On March 2, 2010, Veolia submitted a revised application for a significant modification of its 

Title V permit, including a revised request to extrapolate metal feedrates. In the application, 

Veolia requested feedrate limits that are about three times higher than the 2008 comprehensive 

64 Fed. Reg. at 52946-47. 

10 

V ES 001661 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

tests feedrates. Veolia submitted additional supporting data on historical metal feedrates on 

March 12 and June 7, 2012. A table showing relevant dates is provided below. 

Table 1. Summary of Application Review Timeline. 

Relevant Dates , Activity 

October 10, 2008 Veolia submits its initial significant modification application 

requesting extrapolated feedrates for metals. 

December 5 & 10, 2008 Veolia submits to Charles Hall, EPA , by electronic mail, the 

highest historical 12-hour rolling feedrate data for mercury, 

low volatile metals and semi-volatile metals. 

January 7, 2009 Veoha submits a revised significant modification 

application, dated January 6,2009, which revises feedrate 

calculations to account for the moisture content of the solid 

waste fed. 

January 22, 2009 E P A requests additional information. 

March 27, 2009 In response to EPA's request for additional information, 

Veolia submits laboratory reports for the 2008 performance 

tests. 

July 17, 2009 E P A denies Veolia's request for extrapolation, included in 

the significant modification application. 

March 2,2010 Veolia submits a revised significant modification 

application, dated February 25, 2010, which revises moisture 

content calculations, historical feedrates, and the requested 

feedrate limits. 

March 8, 2012 E P A informs Veolia, by conference call, that it does not 

intend to approve the significant modification application as 

proposed, and requests Veolia to submit additional 

information by April 13, 2012. 1 1 

March 27, 2012 Veoha states in an e-mail message to David Ogulei, EPA , 

that it will not be revising its extrapolation request. 

June 7, 2012 Veolia re-submits historical metal feedrate data, at the 

request of EPA . 

[Date] E P A denies Veolia's significant modification application for 

extrapolated feedrates and issues a draft revised Title V 

permit to Veolia. 

1 1

 David Ogulei, EPA Region 5, sent Doug Harris, Veolia, meeting notes and a schedule for Veolia to submit 

additional information to by email on March 12, 2012. 

11 

V ES 001662 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

4.0. UNIT-SPECIFIC CONDITIONS 

(A) Applicable Requirements 

The Title V permit details the requirements applicable to Veolia, including the HW C MAC T 

requirements. A chart detailing all applicable requirements for each of the emission units was 

provided on Pages 5 and 6 ofthe Statement of Basis for the initial permit, dated September 12, 

2008. 1 2 

No new requirements have become applicable to the source since the last pennit was issued. 

(B) HWC MAC T OPLs 

E P A has reviewed Veolia's significant modification application and determined that the 

extrapolated feedrate limits requested by Veolia are not approvable. For the reasons provided 

below, EP A has detennined that the requested feedrate limits are unacceptable under the HW C 

MACT ; therefore, we are concunently denying Veolia's proposed feedrate limits and 

incorporating into the draft revised Title V permit feedrate limits which EP A considers to be 

supported by the available test data. In addition, EP A has based the mercury feedrate limits on 

the mercury spike concentrations calculated using the minimum purity ofthe original spike 

material instead of the mercury spike concentrations calculated by Veolia's contractor, Maxxam 

Analytics, Inc. 1 3 

Table 2 provides a summary of EPA's proposed feedrate limits. Table 2 also compares Veolia's 

proposed OPLs to the limits EP A has incorporated into Veolia's draft permit. The feedrate limits 

are based on historical feedrate data provided to EP A by Veolia on June 7,2012 (Table 3), and 

comprehensive performance test data conducted by Veolia in August and September, 2008. 

1 2

 Final permit and support documents are available at www .re pulation s. eo v: Docket ID: EPA-R05-OAR-2008-0235 

1 3

 In its laboratory report, Maxxam warned that its mercury spike results should be "viewed with discretion" due to 

the presence of uncertainty in the laboratory measurements. Our review of Veolia's mercury spike preparation 

methodology and data shows that an estimate of spike mercury concentration based on Veolia's spike preparation 

and procedures, including equipment specifications and interviews with Veolia personnel, most accurately 

represents the spike concentrations used in the 2008 test burns. 

12 

V ES 001663 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

Table 2. Proposed Metal Feed Rate Operating Parameter Limits. 

Unit Metal 

Average 

Metal 

Feedrate 

During 

2008 

Testing 

(lb/hr)" 

Was Testing 

Done at > 

Median 12-hr 

Historical 

Rate? " 

Veolia's 

Proposed 

Feedrate 

Limits 

(Ib/hr) 

EPA's 

Proposed 

Feedrate 

Limits 

(lb/hr) 

Estimated 

Stack Cone. 

Assuming 

Veolia's 

Proposed 

Limits 

(Ug/dscm @ 

7%02 )

c 

Estimated 

Stack Cone. 

Assuming 

EPA's 

Proposed 

Limits 

(ug/dscm @ 

7%0 2 )

c 

HWC 

MACT Limit 

(Ug/dscm @ 

7% 02 )

d 

2 

Mercury 0.00165 Yes 0.0057 0.0017 183 53 130 

2 L VM 47.2 Yes 140 68.5 20 10 92 

SVM 63.6 Yes 189 91.0 65 31 230 

3 

Mercury 0.0018 Yes 0.0057 0.0018 181 57 130 

3 L V M 47.7 Yes 143 77.8 70 38 92 

SVM 64.3 Yes 193 81.6 173 73 230 

4 

Mercury 0.0214 Yes 0.078 0.021 89 24 130 

4 L VM 50.3 Yes 151 77.3 30 15 92 

SVM 63.6 Yes 191 98.1 81 42 230 

a. Mercury feedrates were calculated by EPA using calculated mercury spike composition and offsite waste 

feed concentrations provided by Veolia's laboratory contractor (Maxxam). 

b. Median historical feedrate was calculated by EPA from data provided by Veolia on June 7, 2012. 

c. Stack concentrations are estimated from exhaust parameters and "removal efficiencies" reported by Veolia 

in its application, except that mercury removal efficiencies were recalculated by EPA. The pg/dscm 

calculation is a linear estimate and should only be used to generally compare the recommended limits with 

the HWC MACT emission limitations. Red-colored values are greater than the MACT limit. 

d. HWC MACT limits are found in 40 C.F.R. § 63.1219. 

Table 3. Summary of Historical Metal Feedrate Data Submitted By Veolia (12-hour 

Unit# Metal 

Date Range 

Considered 

Minimu 

m (Ib/hr) 

Median 

(Ib/hr) 

Average 

(Ib/hr) 

Maximum 

(lb/hr) 

Mercury 7/1/04-5/31/09 0 0.0000065 0.00027 0.0064 

2 L V M 1/2/05-12/31/08 0 0.116 0.859 68.5 

S V M 1/2/05-12/31/08 0 0.078 0.832 91.0 

Mercury 7/1/04-5/31/09 0 0.0000065 0.00025 0.0059 

3 L V M 1/2/05-12/31/08 0 0.140 0.993 77.8 

S V M 1/2/05-12/31/08 0 0.0582 0.829 81.6 

Mercury 7/1/04-5/31/09 0 0.0034 0.0087 0.060 

4 L V M 1/2/05-12/31/08 0 1.66 2.79 77.3 

S V M 1/2/05-12/31/08 0 1.13 2.63 98.1 

Following is a discussion of how EP A calculated the feedrate limits shown in Table 2. 

13 

VES 001664 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

a) Mercury 

Based on the available information, EP A does not believe that any extrapolation is appropriate 

for mercury for several reasons: 

i . The requested mercury feedrate limits could result in violation of the applicable mercury 

MAC T limits at Combustion Units 2 and 3. EP A estimates that if the requested mercury 

feedrate limits are granted, corresponding mercury stack concentrations for Combustion 

Units 2 and 3 (calculated as approximately 183 and 181 micrograms per dry standard 

cubic meter @ 7% oxygen (pg/dscm @ 7% O2)) would exceed the mercury MAC T limit 

of 130pg/dscm@7%O2. 

i i . For Combustion Unit 4, which uses an activated carbon injection system to control 

mercury emissions, Veolia has not provided sufficient data to understand the relationship 

between the necessary amount of activated carbon needed to maintain the calculated 

system removal efficiency at different mercury feedrates. 

iii. Mercury was spiked as part of the comprehensive performance test. 1 4 The intended 

purpose of metal spiking when conducting comprehensive tests is to enable a facility to 

verify compliance with MAC T limits under worst-case conditions. 1 5 To protect workers 

E P A does not encourage unnecessary spiking of metals during comprehensive tests. 

Therefore, if a facility spikes metals when conducting comprehensive tests, the metal 

spike rates and the native mercury content of the waste should be used to set the feedrate 

limit with little or no extrapolation, provided the corresponding stack emissions assure 

compliance with all MAC T limits with an ample margin of safety. 

Therefore, we are proposing to deny Veolia's extrapolated feedrate limits for mercury. At the 

same time, EP A has determined that, because Veolia's current Title V permit does not include 

OPLs for mercury, it does not assure compliance with the limitations at 40 C.F.R. §63.1219. 

Thus, we are proposing to reopen Veolia's permit pursuant to 40 C.F.R. §71.7(f)(iv) to 

incorporate as mercury feedrate limits the feedrates at which Veolia conducted its 2008 testing. 

b) SVM and LVM 

In a June 2008 letter to Veolia, 1 6 EP A stated, "[i]n order to conduct performance tests under 

operating conditions that represent the extreme range of normal conditions - as 40 C.F.R. §§ 

63.7(e)(1) and 63.1207(g) require - Veolia must feed each metal group (i.e., Mercury, LVM , and 

SVM ) at no less than the highest 12-hour rolling average during the previous 5 years". However, 

Veolia did not consistently feed metals at rates that are representative of the extreme range of 

normal conditions, as required by 40 C.F.R. §§ 63.7(e)(1) and 63.1207(g). While Veolia claims 

that theh test feedrates are within the range of their historical feedrates, they are requesting 

For the 2008 test burns, Veolia spiked lead nitrate, chromic acid, mercury nitrate, and hexachloroethane. 

1 5

 69 Fed. Reg. at 21218 

1 6

 George Czerniak, Chief, Air Enforcement & Compliance Assurance Branch, EPA Region 5, to Douglas Harris, 

General Manager, Veolia ES Technical Solutions, L.L.C, June 12, 2008. 

14 

V ES 001665 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

extrapolation to feedrate limits that significantly exceed their highest historical feedrates. Some 

ofthe requested feedrate limits for LV M and SV M are more than twice the highest reported 

historical feedrates for these metals. See Tables 3 and 4. EPA's policy is not to grant 

applications for feedrate limits that are significantly higher than the reported historical metal 

feedrates. 1 7 

According to Veolia, EP A previously indicated to Veolia that the level of extrapolation which 

Veolia requested in its March 2, 2010 application "would more likely be approved" by EPA . See 

e-mail from Doug Harris, Veolia, to David Ogulei, EPA , on March 27, 2012. Although EP A has 

previously approved extrapolations of up to 3 times the test feedrates for some facilities, those 

approvals have been based upon source-specific considerations. We believe that source-specific 

circumstances at Veolia, including the issues discussed above and Veolia's location in an 

environmental justice (EJ) area, support EPA's proposed decision to deny the application. 

Because the feedrate limits proposed by Veolia are significantly higher than the historical normal 

metal feedrates for the source, we are proposing to deny Veolia's proposed feedrate limits for 

S V M and LVM . At the same time, EP A has determined that, because Veolia's current Title V 

permit does not mclude OPLs for SV M and LVM , it does not assure compliance with the 

standards at 40 C.F.R. §63.1219. Thus, we are proposing to reopen Veolia's permit pursuant to 

40 C.F.R. §71.7(f)(iv) to incorporate SV M and LV M feedrate limits, which EP A considers to be 

supported by the available test data. EP A calculated the LV M and SV M feedrate limits as 

follows: 

i . If the feedrate during the 2008 comprehensive performance tests was higher than the 

highest historical 12-hour rolling average feedrate, we used the performance test feedrate 

as the proposed feedrate limit; 

i i . If the feedrate during the 2008 comprehensive performance tests was less than the highest 

historical 12-hour rolling average feedrate, but it was greater than the median historical 

12-hour rolling average feedrate, we used the highest historical 12-hour rolling average 

feedrate as the proposed feedrate limit; 1 8 

1 7

 62 Fed. Reg. 24211, 24238, Fn 51, explains that EPA does not want sources to extrapolate to allowable feedrates 

that are significantly higher than their historical range of feedrates ("... i.e., extrapolated feedrates should be limited 

close to the historical levels that a source actually fed."). 64 Fed. Reg. 52947 adds that EPA took this policy 

position "to avoid creating an incentive to burn wastes with higher than historical levels of metals." Additionally, 

facilities that want to burn wastes with higher than historical levels of metals could do so through spiking of metals 

during comprehensive performance testing, but they "must incur the costs and address the hazards to plant personnel 

and testing crews associated with spiking metals into [their] feed streams." Id. See also 64 Fed. Reg. at 52946. 

1 8

 Veolia spiked Pb and Cr during the 2008 comprehensive tests, but did not spike As, Be, or Cd. Pb is a 

semivolatile metal (SVM) while Cr is a low volatile metal (SVM). We believe a limited amount of extrapolation up 

to the highest historical 12-hour rolling average feedrate is justifiable in this case because only a fraction of SVM 

was spiked (Cd was not spiked), and only a fraction of LVM was spiked (As and Be were not spiked). 

15 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Sigmficant Modification 

iii . If the feedrate during the 2008 comprehensive perfonnance tests was less than the 

median historical 12-hour rolling average feedrate, we used the median historical 12-hour 

rolling average feedrate as the proposed feedrate limit. 1 9 

(C) Non-Applicability Determinations 

40 C.F.R. § 71.6(f)(1)(h) provides that a permitting authority "may expressly include in a part 71 

permit a provision stating that compliance with the conditions of the permit shall be deemed 

compliance with any applicable requirements as of the date of permit issuance, provided that: ... 

[t]he permitting authority, in acting on the permit apphcation ... determines in writing that... 

requirements specifically identified are not applicable to the source, and the permit includes the 

determination or a concise summary thereof." Conditions 2.1(B), 2.2(B), 2.3(B), 2.4(B), 2.5(B), 

2.6(B), 2.7(B), and 2.8(B) of the Part 71 permit each describe federal regulations or portions of 

the Illinois SIP that EP A has determined do not apply to this facility. Al l of the determinations 

made in the above listed conditions of the permit, which are based on each rule's applicability 

criteria, not the source's potential to emit, or other artificially imposed limits, are described 

specifically in the pennit. 

N o additional non-applicability determinations have been made with the cunent pennitting 

action. 

(D) Periodic Monitoring 

(a) Proposed Requirements 

Where the applicable requirement does not require periodic testing or instrumental or 

noninstrumental monitoring (which may consist of recordkeeping designed to serve as 

monitoring), 40 C.F.R. § 71.6(a)(3)(i)(B) requires that each permit contain "periodic monitoring 

sufficient to yield reliable data from the relevant time period that are representative ofthe 

source's compliance with the permit.... Such monitoring requirements shall assure use of terms, 

test methods, units, averaging periods, and other statistical conventions consistent with the 

apphcable requirement. Recordkeeping provisions may be sufficient to meet [these monitoring] 

requirements...." The initial permit established periodic monitoring in the following conditions: 

2.2(D)(12); 2.2(E)(2); 2.2(E)(3); 2.3(D); 2.3(E)(2); 2.4(D)(4); 2.4(D)(6); 2.5(D)(3); 2.5(D)(6); 

2.6(D)(1); and 2.7(D)(1). 

Under the HW C MACT , each subject facility must conduct comprehensive perfonnance tests to 

establish metal feedrate limits, and must analyze its feedstream prior to feeding the material into 

the incinerator and document the amount of mercury, low volatile metals (arsenic, beryllium, 

chromium) and semi-volatile metals (lead and cadmium) in each feedstream. The facility must 

either comply with the feedrate limits or it may petition EP A to install and operate continuous 

emission monitoring systems (CEMS) to directly measure emissions and document compliance 

with the MAC T limits. 40 C.F.R. § 63.1209(c) requires that a subject facility have a feedstream 

As shown in Tables 3 and 4, all ofthe LVM and SVM test feedrates were higher than the respective median 

historical 12-hour rolling average federates. 

16 

V ES 001667 
Veolia Environmental Services Statement of Basis 

Pennit No. V-IL-1716300103-08-01 Significant Modification 

analysis plan (FAP) "that is sufficient to document compliance with the applicable feedrate 

limits." The plan must be submitted to EP A on request. 

E P A has reviewed Veolia's FA P and determined that it is necessary to supplement the mercury, 

L V M and SV M analysis procedures contained in the FA P in order to assure compliance with 

H W C MAC T limits and the proposed feedrate limits. To address the identified deficiencies in 

Veolia's FAP , and assure compliance with the operating parameter limits, EP A has specified 

mercury, LV M and SV M analysis procedures in the permit. Additionally, as further discussed 

below, we are proposing that Veolia install and operate a multi-metals continuous emissions 

monitoring system (CEMS) on Combustion Unit 3 for a period of at least 12 months. The 

temporary use ofthe CEM S in conjunction with compliance with the OPLs, the feedstream 

analysis plan, and the supplements to the plan included in the permit will assure that the OPLs 

established in the pennit are adequate to assure compliance with the metals emissions limits in 

the MACT . 

The proposed feedstream analysis procedures, which are found in conditions 2.1(D)(l)(i) and 

2.1(D)(4)(d)(2), supplement any other mercury, LV M and SV M analysis procedures specified in 

Veolia's FA P and supersede any less stringent provisions in the FAP . Incorporation of these 

requirements into the Title V peimit does not eliminate Veolia's obligation to maintain an 

adequate FAP , consistent with 40 C.F.R. § 63.1209(c); rather, we are specifying minimum 

feedstream analysis procedures to assure compliance with the applicable HW C MAC T limits. 

(b) Advantages of Using Multi-Metals CEMS 

Generally, feedstream analysis poses several challenges including the uncertainty associated with 

1) measurement of extremely low metal concentrations in the feedstream (i.e., concentrations at 

or near the detection limit of the measurement device); 2) heterogeneity of the hazardous waste, 

which may lead to a non-representative sample and hence an inaccurate estimate ofthe metal 

feed concentration; 3) inability to demonstrate continuous compliance with MAC T limits, as 

required by the HW C MACT , since there is generally a considerable time lag time between 

sampling and analysis. 

The uncertainties caused by feedstream analysis are largely solved when an EPA-approved 

CEM S is used to directly measure emissions. First, unlike feedstream analysis, CEM S monitor 

emissions continuously or semi-continuously. 2 0 The use of CEM S is the most direct means of 

ensuring compliance with emissions limits, which helps protect public health and the 

environment. Generally, EP A considers other options for monitoring compliance when CEM S 

are not available or when we determine that requiring CEM S is unnecessary or unreasonable. 

For example, the HW C MAC T does not mandate the use of CEM S to document compliance with 

Depending on the sampling and analytical technique used by the CEMS, a brief time lag typically exists between 

measurements due to the amount of time needed to collect and analyze each sample and to conduct quality assurance 

checks. For example, in the XactTM multi-metals CEMS (Cooper Environmental Services, LLC, Portland, Oregon), 

sampling and analysis occurs simultaneously within the instrument except for the time required to advance the tape 

(about 20 seconds) and the time required for automated quality assurance checks. See XactTM 640 Multi-Metal 

Continuous Emissions Monitoring Syslem. Specification Data Sheet. Available at: http://stalic,pall.com/pdfs/QEMMedia-Membranes-and-Materials/PGXACT640BN.pdf. 

17 

V ES 001668 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

the HW C MAC T hmits for mercury, LVM , SVM , or chlorine based in part on EPA's 

determination that performance specifications for mercury or multi-metals CEM S were not yet 

available at the time of finalization of that rule. However, pursuant to 40 C.F.R. § 

63.1209(a)(l)(i), the source must use either a carbon monoxide or hydrocarbon CEM S to 

demonstrate and monitor compliance with the carbon monoxide and hydrocarbon standard, and 

an oxygen CEM S to continuously correct the carbon monoxide or hydrocarbon level to 7 percent 

oxygen. For PM , pursuant to 40 C.F.R. § 63.1209(a)(l)(iii), the source must install, calibrate, 

maintain, and operate a P M CEM S to demonstrate and monitor compliance with the P M 

standards at such time that the Agency promulgates all performance specifications and 

operational requirements applicable to P M CEMS . Under 40 C.F.R. § 63.1209(a)(5), the source 

may petition the Administrator to use CEM S for compliance monitoring for PM , mercury, 

semivolatile metals, low volatile metals, and hydrogen chloride and chlorine gas under 40 C.F.R. 

§ 63.8(f) in lieu of compliance with the corresponding operating parameter limits. 

Second, modern multi-metals CEM S have been shown to be more accurate and reliable than 

feedstream analysis for monitoring mercury and other hazardous metal emissions from 

combustion of heterogeneous feedstreams. Without a CEM S most emission excursions from 

combustion of such heterogeneous feedstreams would go undetected. A CEM S could alleviate 

this concern by giving the facility instantaneous data, thus enabling it to make changes that 

compensate for the increased metals in the feedstream before emissions become excessive. 2 1 

Although a momentary exceedance of the emission limit would not be expected to immediately 

affect the 12-hour rolling average used for demonstrating compliance, the facility operator could 

rely on the instantaneous data to initiate various corrective actions before there is a compliance 

or safety problem. Instantaneous data typically gives a facility plenty of time to optimize 

performance before employee or public safety is threatened. 

Third, the use of CEM S has the potential to enable the facility to increase waste feedrates by 

directly monitoring emissions and showing that the MAC T limits are not exceeded at higher 

feedrates. This could be attractive to a facility that wants flexibility in feedrates to account for 

expected or unplanned variability in waste profiles. 

(c) Availability of Multi-Metals CEMS 

Multi-metals CEM S are commercially available and have been demonstrated to be reliable for 

measuring mercury and other metal emissions from hazardous waste combustors. Multi-metals 

CEM S measure the amount of mercury and a number of other trace metals, thus the installation 

of a multi-metals CEM S eliminates the need for a mercury CEMS . Unlike mercury CEMS , 

which measure only mercury emissions, a multi-metals CEM S enables a facility such as Veolia 

to directly measure the actual stack concentrations of a number of HA P metals in the 

homogeneous exhaust gas stream instead of sampling and analyzing a fraction of the 

heterogeneous waste being fed to the incinerator. Because the multi-metals CEM S provides 

real-time data, Veolia can determine its compliance with MAC T limits in near real time and 

2 1

 French, N.B., and Priebe, S.J. (1999). Implementing Mercury CEMS in DOE Mixed Waste Treatment Systems. 

Presented at the WM'99 Conference, February 28 - March 4, 1999. Available al 

http://www.wmsym.or.a/archives/1999/3 2/32-6. pdf (accessed October 16, 2012). 

18 

V ES 001669 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

make prompt adjustments to process parameters (temperature, oxygen, feed rate, etc.) to 

minimize emissions. 

E P A has approved the use of multi-metals CEM S as alternative monitoring methodologies at 

hazardous waste combustors. EP A has performed side-by-side evaluations of multi-metals 

CEM S with EP A Method 29 of Appendix A- 8 to 40 C.F.R. Part 60 at industrial waste 

incinerators and found good correlation between the two methods. 75 Fed. Reg. 31962 (June 4, 

2010). In addition, performance specifications and quality assurance (QA) procedures are now 

available for both mercury and multi-metals CEMS .

 2 EP A has published performance 

specifications and Q A procedures for multi-metal CEM S as OT M 16 (Specifications and Test 

Procedures for X-ray Fluorescence Based Multi-Metals Continuous Emission Monitoring 

Systems at Stationary Sources) and OT M 20 (Quality Assurance Requirements for X-RayFluorescence Based Multi-Metals Continuous Emission Monitoring Systems at Stationary 

Sources). 2 3 Moreover, multi-metals CEM S are an accepted option for metals emission 

compliance in the recently promulgated mercury and air toxics (MATS ) rule. 77 Fed. Reg. 9303 

(February 16, 2012). Therefore, the multi-metals CEM S has been proven to be reliable for 

measuring actual emissions of HA P metals from a hazardous waste combustor such as Veolia. 

E P A recently evaluated, at several facilities, a commercial version of a multi-metals CEM S 

capable of measuring up to twenty or more hazardous air pollutant (HAP) metals in real time. 

The XactTM multi-metals CEM S was developed by Cooper Environmental Services, LL C (10180 

SW Nimbus Avenue, Suite J6, Portland, Portland, Oregon 97223) and is now being marketed by 

Pall Corporation (25 Harbor Park Drive, Port Washington, New York 11050). The system uses 

reel-to-reel (RTR) filter tape sampling technology followed by X-ray fluorescence (XRF) 

analysis of metals in the deposit. The process begins when an isokinetic sub-sample of stack gas 

is taken from the stilling chamber and drawn through a chemically-reactive filter tape. Vapor 

phase metals, including Hg, are deposited on the reactive filter tape along with the particulate 

matter. The resulting deposit is then automatically advanced and analyzed by XR F for selected 

metals while the next sample is being collected. The XR F sample analysis technique does not 

destroy the sample, which allows for possible sample archiving and re-analysis at a later time. 2 4 ' 

2 5

 The XactTM multi-metals CEM S can measure up to 20 or more metals simultaneously 

2 2

 Performance Specification 10 (for multi-metals CEMS) and Performance Specification 12 for mercury CEMS 

were proposed in 1996 in conjunction with the original Hazardous Waste Combustor MACT. However, because the 

multi-metals and mercury CEMS measurement technologies had not been fully developed and demonstrated, neither 

performance specification was promulgated. Between 2003 and 2005, Perfonnance Specification 12A for mercury 

CEMS was proposed and promulgated in conjunction with the Clean Air Mercury Rule (CAMR) after extensive 

demonstration of mercury CEMS and identification of appropriate performance parameters. In 2007, CAMR was 

vacated by the DC Circuit Court, which called into question the legality of using Performance Specification 12A. It 

has since been re-proposed in conjunction with amendments to the Portland Cement NESHAP. See 

http://www.epa.gOv/ttn/emc/monitor.html#metals 

2 3

 See http://Avww.epa.gov/ttn/emc47reli1n/otiTii 6.pdf and http:/Avw vv.epa.pov/ttn/emc/prelim/otm20.pd 1". 

2 4

 Hay, K.J., Johnsen, B.E., and Cooper, J.A. (2005). X-Ray Fluorescence-Based Multi-Metal Continuous Emission 

Monitor: Development. Final Report ERDC/CERL TR-05-3, January 2005. Available at: 

http://www.dtic.mil/dtic/tr/fiilHext/u2/a430237.pdf (accessed October 16, 2012). 

2 5

 Yanca, C.A., Barth, D.C, Petterson, K.A., Nakanishi, M.P., Cooper, J.A., Johnsen, B.E., Lambert, R.H., and 

Bivins, B.G. (2006). Validation of Three New Methods for Determination of Metal Emissions Using a Modified 

19 

V E S 001670 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

including arsenic, cadmium, chromium, mercury, and lead. 2 6 The system reports analytical 

results every 15 minutes in the units of the MAC T standards (u.g/dscm). 2 7 

Cooper Environmental Services has also developed and received EP A approval for a 

Quantitative Aerosol Generator (QAG), which generates a reference aerosol for calibrating the 

multi-metals CEM S and for performing relative accuracy test audits (RATAs) of the multimetals CEMS. 2 8

 Yanca et al. evaluated both the XactTM and the QA G using a modified EP A 

Method 301 at a hazardous waste combustor by comparing measured and reference aerosol 

concentrations. The authors found that both the XactTM and the QA G met the Method 301 

validation criteria with precisions and accuracies on the order of 5% over a wide range of 

29 

concentrations. 

In 2006, El i Lill y and Company received approval from EP A to use a multi-metals CEM S as an 

alternative to operating parameter monitoring at the El i Lill y Tippecanoe Laboratories 

manufacturing facility near Lafayette, Indiana. El i Lill y successfully installed, certified, and 

operated, for at least six years, the XactTM multi-metals CEM S on a 50 mmBtu/hr rotary kiln 

hazardous (solid and liquid) waste incinerator at the El i Lill y Tippecanoe Laboratory Facility 

from 2005 until 2010. El i Lill y used the XactTM multi-metals CEM S in conjunction with a P M 

and hydrochloric acid (HCI) CEMS. 30,3 1 Evonik Degussa Corporation purchased the 

Tippecanoe Laboratory facility in 2010 and continued to operate the multi-metals, P M and HCI 

CEM S for monitoring compliance with the HW C MACT . 

E l i Lilly's stack gases at the Tippecanoe facility averaged approximately 8% moisture content 

and 140 °F while the multi-metals CEM S was being operated. However, Pall Corporation has 

assured EP A that trial tests on their CEM S demonstrate that the unit can operate reliably at 

moisture contents above 40%. 

Environmental Protection Agency Method 301. Journal of the Air & Waste Management Association, 56: 1733 -

1742. 

2 6

 Lambert, R., and Foster, M. (2011). Eli Lilly's Experience Using a Multi-Metals Continuous Emission 

Monitoring System. Available at: http://events.awma.org/it32011 /presentation s/SE SSION%201.4/1.4-

3%20tAllv%%20Experience%20with%20Using 

(accessed October 17, 2012) 

2 7

 Cooper environmental Services reports that the XactTM multi-metals CEMS can be used at waste incinerators 

(hazardous, sewage, municipal, medical, industrial), cement kilns, lime kilns, foundries, coal-fired power plants, 

industrial furnaces and boilers, primary and secondary metal smelters, etc. The unit has been tested at hazardous 

waste incinerators, coal-fired boilers, wet and dry stacks and 50 ppm acid gases. See 

hUp://cooperenvironmenlal.com/wp-content/uploads/2010/l l/2010-Xact-640-Presentation-al-lhe-AWMASymposium-on-Air-Oualily-Measurement-Methods-and-Technology.pdf (Slide 37). In one test case at a coal-fired 

power plant, the XactTM was installed and operating within 2 days. 

2 8

 http://cooperenvironmental.com/wp-content/uploads/2010/01/QAG-820-Data-Sheet.pdf 

2 9

 Yanca et al. (2006). 

3 0

 Lambert, R., and Foster, M . (2011). As part of Eli Lily's experience with the multi-metals CEMS, Eli Lilly in 

conjunction with EPA prepared a number of technical documents that are now posted on the OAQPS methods web 

site as Other Test Methods. See http://www.epa.gov/ttn/emc/prelim.hrml 

3 1

 The U.S. Army has also successfully installed and evaluated a multi-metals CEMS on one of its hazardous waste 

incinerators. Hay et al. (2005). EPA also understands that the U.S. Department of Defense has purchased three 

XactTM units for use at army munitions incinerators. Finally, multi-metals CEMS are an accepted option for metals 

emission compliance in the utility mercury and air toxics (MATS) rule that was recently promulgated by EPA. 

20 

V ES 001671 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

EPA's Emissions Measurement Center (EMC) located within the Office of Air Quality Planning 

and Standards (OAQPS) has also recently evaluated the use of the multi-metals CEM S 

technology for ambient fenceline multi-metals monitoring for compliance determination, 

ambient health exposure studies, and for locating and evaluating unknown sources of metals 

emissions. In 2010-2011, EM C deployed the XactTM 625 fenceline multi-metals monitor at two 

sites in Ohio in coordination with EP A Region 5, EP A Office of Research and Development 

(ORD) and Ohio EPA . The XactTM 625 reports hourly ambient air metals concentrations in near 

real-time, which allows for faster data acquisition and decision making over conventional filterbased monitoring methods. EPA's Ohio studies show excellent comparability between the 

XactTM 625 and conventional, filter-based, metals monitoring methods. 

Several additional multi-metals CEM S are under development, including several efforts focused 

on laser-based atomic emission spectroscopy (AES), microwave AE S and spark-based AES. 3 2 

However, EP A is not aware that any of these other technologies are currently commercially 

available. 

(d) Proposed Multi-Metals CEMS Requirements 

Veolia's waste streams are heterogeneous (i.e., the composition of the waste is variable within 

each waste stream). Also, some wastes burned by Veolia have unknown composition because 

their composition profiles have not been provided by the respective waste generator, hi many 

cases, Veolia relies on waste composition analyses supplied by the individual waste generators 

but these analyses may not be accurate. Moreover, perfonnance testing that is conducted 

periodically by Veolia provides only a snapshot of emissions and does not necessarily represent 

actual emissions performance with respect to all waste streams burned by Veolia throughout the 

year. The use of a multi-metals CEM S is the only sure way to verify that Veolia's feedstream 

analysis procedures and the proposed feedrate limits are sufficient to assure continuous 

compliance with the HW C MAC T limits. 

To assure compliance with the HW C MAC T while operating at or below the permit's feedrate 

limits, EP A is proposing that Veolia install and operate a multi-metals CEM S on Combustion 

Unit 3 for a period of at least 12 months. EP A is proposing Combustion Unit 3 because, based 

on EPA's proposed feedrate limits, EP A estimates that Combustion Unit 3 has the highest 

potential emissions of mercury, SV M or LV M of any of the combustion units (Table 2). 3 3 

During the temporary 12-month period, Veolia would continue to monitor feedrate limits using 

the procedures in their feedstream analysis plan and the enhanced feedstream analysis procedures 

proposed in the revised permit. In addition, during the 12-month period when the multi-metals 

CEM S is being operated, Veolia would be required to comply with the feedrate hmits for 

3 2

 French, N.B., and Priebe, S.J. (1999) 

3 3

 Unit 3 is nearly identical to Unit 2, by design; therefore, the CEMS data from Unit 3 can be used to deduce the 

emissions performance of Unit 2 without making significant assumptions. Unit 4 uses an activated carbon injection 

system to control mercury emissions, which makes it more difficult to extrapolate emissions data from Unit 4 to 

other uncontrolled units. 

21 

V ES 001672 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

mercury, LV M or SV M for Unit 3. This would allow Veolia to demonstrate to EP A that the 

feedrate limits are sufficiently stringent to assure compliance with the metals emissions limits. 

At the end of the 12 month period, Veolia could petition EP A to continue to utilize the multimetals CEM S as the primary means of compliance in lieu of complying with the feedrate limits. 

If operation ofthe multi-metals CEM S reveals that any of the feedrate limits included in Veolia's 

permit must be made more stringent in order to assure compliance with the applicable emissions 

limits, EP A would reopen the permit, pursuant to 40 C.F.R. § 71.7(f), to either revise the affected 

feedrate limits or require permanent operation of the multi-metals CEMS . On the other hand, if 

operation of the multi-metals CEM S reveals that any of the feedrate limits included in the permit 

are more stringent than necessary to assure compliance with the applicable emissions limits, 

Veolia could petition EP A to utilize the results of historical comprehensive performance tests, 

feedstream analysis, and CEM S data to establish higher feedrate limits for the affected 

incineration units provided the CEM S data demonstrate that compliance would be assured at the 

higher feedrate limits regardless ofthe waste burned. 

(E) Streamlining 

Pursuant to 40 C.F.R. § 71.6(a)(3)(i)(A), if two or more applicable requirements regulate 

emissions of the same pollutant from the same emissions unit, EP A may allow a permittee to 

comply with a streamlined set of monitoring or testing provisions, provided that the specified 

monitoring or testing is adequate to assure compliance at least to the same extent as the 

monitoring or testing applicable requirements that are not included in the permit as the result of 

the streamlining. In the initial pennit, EP A streamlined requirements in Conditions 2.1(C)(7)(g) 

and 2.1(C)(12). 

No additional streamlining was performed as part ofthe cunent permitting action. 

5.0. ENVIRONMENTA L JUSTICE 

In 2011, EP A published Plan EJ 2014, EPA's roadmap for integrating environmental justice (EJ) 

into its programs, policies and activities. Plan EJ 2014 has three objectives: 1) Protect health and 

the environment in overburdened communities; 2) Empower communities to take action to 

improve their health and environment; and 3) Establish partnerships with local, state, tribal, and 

federal governments and organizations to achieve healthy and sustainable communities. 3 4 One 

focus area of Plan E J 2014 is "Considering Environmental Justice in Pennitting." 3 5 EPA's goal 

is to enable overburdened communities to have full and meaningful access to the permitting 

process and to develop permits that address E J issues to the greatest extent practicable under 

existing environmental laws. Overburdened communities are communities that potentially 

See Plan EJ 2014: Considering Environmental Justice in Permitting - Implementation Plan. Available at: 

http://www.epa.gov/compliance/e^^ l-09.pdf, See also "EPA 

Activities To Promote Environmental Justice in the Permit Application Process", Notice of Availability of 

Proposed Regional Actions to Promote Public Participation in the Permitting Process and Draft Best Practices for 

Permit Applicants Seeking EPA-Issued Permits; Request for Comments, 77 Fed. Reg. 38052. 

22 

V ES 001673 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

experience disproportionate environmental harms and risk as a result of cumulative impacts or 

greater vulnerability to environmental hazards. 3 6 

Veolia is located in an EJ area in East St. Louis and is of significant public interest. Two-thirds 

of all persons living within three miles of Veolia (65.8%) are minorities, and one-third (32.7%) 

live below the federal poverty level. 3 7 Table 4 compares the race distribution in the vicinity of 

Veolia to the state and national distributions. Figure 1 shows the breakdown of household 

income within three miles of Veolia, based on 2000 U.S. census data. A s shown in Figure 1, 

about one-half of all households within three miles of Veolia have annual household income of 

$50,000 or less. 

Table 4. Race Distribution Within 3 Miles of Veolia. 

Race 

Percent of total 

population within 3 

miles 

Illinois U.S. 

White 35.1% 73.5% 75.1% 

African-American 60.3% 15.0% 12.3% 

Asian/ Pacific Islander 1.3% 3.4% 3.7% 

American Indian 0.4% 0.2% 0.9% 

Other race 0.8% 5.8% 5.5% 

Multiracial 2.1% 2.0% 2.4% 

*Statistics represent residential population, by 2000 Census Block Group, from EJView: 

http://epamapl4.epa.gov/eimap/entry.html. 

8% 

t 

29% 

34% 

iLes s tha n $15,000 

• $15, 000 - $25, 000 

11$25, 000 - $50, 000 

ll$50, 000 - $75, 000 

"Greate r tha n $75,000 

Figure 1. Income of households within 3 miles of Veolia. 

3 6

 77 Fed. Reg. 38052. 

3 7

 U.S. Census 2000 data, by Block Group. Available through EPA's EJView: 

hUp.V/'epamap i 4.epa.gov/eimap/entrv.html 

23 

V ES 001674 
Veolia Environmental Services Statement of Basis 

Permit No. V-IL-1716300103-08-01 Significant Modification 

To assure compliance with the HW C MAC T requirements, EP A has proposed permit limits that 

are lower than the limits proposed by the applicant. EPA's proposed permit limits will protect 

the air quahty around Veolia, which wil l benefit the entire community. 

To ensure compliance with mercury feedrate limits, EP A has included in the Title V permit 

enhanced monitoring requirements for mercury. The enhanced mercury monitoring 

requirements are based on site-specific conditions at the Veolia facility and in the surrounding 

community. Previous site-specific dispersion modeling and risk assessment, conducted by EP A 

for purposes of RCR A permitting, showed that mercury emissions from the Veolia facility could 

result in deposition of mercury in and around lakes used for fishing downwind of the facility. 3 8 

The proposed enhanced mercury monitoring requirements will help protect human health and the 

environment from the consequences of mercury emissions by providing further assurance that 

the permitted mercury limits will not be exceeded. 

Due to the facility's location in an EJ area, EP A believes it is important to provide enhanced 

public participation opportunities to overburdened communities near Veolia. The specific public 

participation opportunities for this permitting action are described in a focus sheet accompanying 

this Statement of Basis (see Docket ID EPA-R05-OAR-2012-0649). We believe that more 

transparency and dialogue can lead to better permit outcomes for the community as well as 

permit applicants. 

3 8

 A copy ofthe risk assessment is available at: http://www.epa.state.il.us/publie-notices/2008/genCTalnotices.html#veolia 

24 

V ES 001675 
vvEPA 

United States 

Environmental Protection 

Agency 

Wha t ca n yo u do ? 

• Submit nriucn commi-nts 

to U.S. liPA regarding the 

draft permit during the 

comment period that runs 

for 45 days from lo 

. Comments should 

include factual grounds and 

supporting material or 

references. 

• Attend the public hearing 

on Feb. 19, 2013, al the 

Southern Illinois Unhersily 

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 backpage. 

• 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 mformation 

and explains the legal and 

factual basis for the pennit 

conditions. The draft Title V 

permit includes all of the 

requirements the source is 

legally obligated lo follow. 

Only portions ofthe permit 

lhut are being changed 

because ofthe proposed 

aclion are currently open for 

comment during the 

comment period. See Page 3 

for locations where you can 

view these documents. 

U.S. EPA Proposes to Revise 

Title V Air Permit 

Veoli a Environmenta l Service s Ai r Permi t 

Sauget, Illinois January 2013 

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 3 for information 

about the pubhc participation process for this proposed permit. 

Backgroun d 

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 

Siena 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. 

Burnin g hazardou s wast e 

Specially designed incinerators, boilers, and industrial furnaces can bum 

hazardous waste. Hazardous waste - which is toxic, flammable, conosive 

ur 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 

lo 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 

VES 001676 
FUELS/LIQUID WASTE FLOW 

COMBUSTION AIR FLOW 

STACK GAS FLOW 

ASH FLOW 

SOUD WASTE FLOW 

UWE SLURRY FLOW 

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

follow similar principals. 

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 affecte d b y 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 hmits 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 mercuiy because the requested limits 

V ES 001677 
could result in violations of other applicable federal 

requirements and sufficient information was not 

provided to detennine 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 apphcation, 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. 

Monitorin g 

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. 

Publi c participation 

You can participate in the decision-making process on 

the permit by submitting statements during the public 

comment period XX X to XXX X or at the public 

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

A l l 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 

cornment 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/iiewseyeiits/ 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 

pubhc 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 o gut eh da vi d(S> epa. go v. 

Vie w 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.regalations.gov/_website at Docket 

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

wvvvv.epa.gov/regron5/MewseTCiits/ 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 

3 

V ES 001678