'NORTH AMERICA 

January 6, 2009 

Via FedEx 

Ms. Cheryl L. Newton, Acting Director 

Air and Radiation Division 

United States Environmental Protection Agency 

Region 5 

77 W. Jackson Blvd. 

Chicago, IL 60604-3590 

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

Title V Permit #: V-IL-1716300103-08-01 

Significant Modification 

Ms Newton, 

Veolia ES Technical Solutions, L.L.C. (Veolia), hereby submits for your review a 

Significant Modification to the Part 71 Permit Number V-IL-1716300103-08-01. 

This Significant Modification requests that the revised OPL's calculated from 

performance testing in August and September, 2008 be incorporated into 

Veolia's Part 71 permit. 

On October 10, 2008, Veolia submitted a number of documents to the Agency 

that included the testing results, the Notification of Compliance and a Significant 

Modification request. This modification requested that revised OPL's for 

mercury, SVM and LVM that were demonstrated during the above referenced 

testing be incorporated into the Part 71 permit. Since that submittal Veolia has 

discovered that its metal feed rate calculations did not account for the moisture 

content of the solid waste. As a result, Veolia has recalculated the OPL's for 

mercury, SVM and LVM. The attachment defines these changes. 

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

prepared under my direction or supervision in accordance with a system 

designed to assure that qualified personnel properly gather and evaluate the 

Veofia ES Technical SoSutionSj L.L.C. 

7 Mobile Avenue, Sauget, IL 62201 

tel: 618 271 2804 - fax: 618 271 2128 

www.VeoliaES.com 
Ms. Newton 

January 6, 2009 

Page 2 

information submitted. Based on my inquiry of the person or persons who 

manage the system, or those persons directly responsible for gathering the 

information, the information submitted, is to the best of my knowledge and belief, 

true, accurate, and complete. I am aware that there are significant penalties for 

submitting false information, including the possibility of fine and imprisonment for 

knowing violations. 

Upon review of this submittal, should the Agency have a need for additional 

information or questions, please contact Dennis Warchol at (618) 271-2804 or via 

e-mail at dwarchol@onvxes.com or me at (618) 271 -2804 or via e-mail at 

dharris @ onyxes.com.. 

Sincerely, 

Veolja ES technical Solutions, L.L.C. 

Doug Harris 

General Manager 

Att. 

cc: Genevieve Damico, USEPA 

USEPA File 
Veolia ES Technical Solutions, L.L.C. 

Significant Modification to Part 71 Permit 

Title V Permit #: V-IL-1716300103-08-01 

Pursuant to 40 CFR 71.7(e)(3), Veolia ES Technical Solutions, L.L.C. is 

submitting a significant modification to our Part 71 Permit number V-IL1716300103-08-01. The following pages detail the requested modification, 

supporting information and justification for the modification. The requested 

modification is as follows: 

• Section 2.1 (C)(2) Operating Parameter Limits for Units 2, 3 and 4 

Mercury, SVM and LVM 

Modification of operating parameter limit (OPL's) table in Section 2.1 (C)(2). 

Pursuant to the Request to Provide Information Pursuant to the Clean Air Act 

dated June 5, 2008 and subsequently revised on September 12, 2008, attached 

is a revised Operating Parameter Limit (OPL's) table that reflects the mercury, 

SVM and LVM OPL's defined in 40 CFR 63.1209. 

The OPL's were modified from the original significant modification submitted on 

October 10, 2008 to account for moisture content in the solid feeds. 

Veolia has extrapolated metal feedrate limits for mercury, SVM and LVM. These 

feedrates were extrapolated using the protocol provided by USEPA (data sheets 

provided). However, based on the extremely high System Removal Efficiencies 

(SRE's) achieved during this testing, Veolia has lowered the extrapolated metal 

feedrates for SVM and LVM at Unit 4 to account for historical metal feedrate data 

as defined in 40 CFR 1209(n)(2)(ii)(B)(2). Veolia has also lowered the 

extrapolated metal feedrates for SVM and LVM at Unit 2 to match those values at 

Unit 3 and again taking into account historical metal feedrate data as defined in 

40 CFR 1209 (n)(2)(ii)(B)(2). 

In order for extrapolation to be utilized, Veolia conducted these performance 

tests using metal feedrates as defined in 40 CFR 1207 (f)(1)(x)(B), that were 

greater than "the historical of normal metals feedrates" fed to the units over the 

last four years. Veolia has provided to the Agency feedrate data for SVM, LVM 

and Mercury since July 1, 2004 to justify the above requirement. As is detailed, 

the metals fed to the incinerators during the performance test were higher than 

the historical range of normal metal feeds over the last four years. 

As stated above, Veolia's extrapolated metal feedrates defined in the attached 

table used the extrapolated method defined in the Performance Test Plan as 
required by 40 CFR 1207 (f)(1)(x) (A) and given to Veolia by USEPA Region 5 as 

an approved method, but also took into account historical metal feedrates for 

each unit in setting these extrapolated values, again as required by 40 CFR 1209 

(n)(2)(ii)(B)(2). Veolia is requesting approval of these extrapolated feedrates not 

only because it followed the requirements ofthe Regulations but it has been the 

Agency's practice of permitting extrapolation with other Region 5 incinerators 

who in some cases were not required to follow 40 CFR 1207 (f)(1)(x) or 40 CFR 

1209 (n)(2)(ii)(B)(2). Veolia has reviewed CPT plans (Project Number 07136-

029-100 and Project Number 010302) from two other Region 5 incinerators and 

have found that both were allowed to extrapolate but did not provide all the 

information required in 40 CFR 1207 (f)(1)(x). It is also noted that in recent 

comments by the USEPA, Region 5 dated April 2, 2008 and signed by William 

MacDowell on one of these incinerator's CPT plans that the Agency 

acknowledges that the requirements for extrapolation were not raised in the 

approved 2003 plan and subsequent results that included extrapolation and 

"want to correct this oversight for the 2008 CPT." Veolia only details this to 

establish that a consistent pattern has not been used to approve or deny 

extrapolation but requests that Veolia's extrapolation be approved based on the 

merits of the test results and that the requirements for extrapolation have been 

complied with as defined in the MACT regulation. 
Section 2.1(C)(2) 

Permittee must operate Units 2, 3, and 4 under these operating parameter limits 

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

Operating Parameters Unit #2 Unit #3 Unit #4 AWFCO 

Total Feedrate of mercury 0.013 0.013 0.22 12-hour rolling 

lbs/hr averages 

Total Feedrate of semi- 459 459 500 12-hour rolling 

volatile metals lbs/hr average limits 

Total feedrate of low 393 393 500 12-hour rolling 

volatile metals lbs/hr average limits