### 1 

### Veolia ES Technical Solutions Air Permit
Sauget, Illinois Oct. 201 4 

# Air Permit Renewal Planned

for Hazardous Waste Incinerator

Pu blic hearing scheduled EPA will hold a public hearing from 3 to 7 p.m.

, Wednesday, Dec. 3

, at :

S IU

- Edwardsville

East St. Louis Higher Education Campus

Room 20 02 Building D

601 James R . Thompson Blvd.

If you need special accommodations to attend the hearing

, contact Andrea Morgan at morgan.andrea@epa.gov by Friday, Nov. 21

.



### How to comment

You will have an opportunity to make oral comments at the public hearing. You may also send EPA
written comments on Veolia’s permit renewal until Friday, Dec.

19

. There are several ways to comment ( see Page 4 for details ).



### For more information
You may review the draft permit

and a document called a “Statement of Basis,” which details reasons for the permit changes. Visit one of

these libraries: Central Library , 130 1 Olive St,

St. Louis.

East St

. Louis Library, 5300 State

St

. , East St. Louis. Cahokia Public Library, 140 Cahokia Park Drive, East St Louis.



### Facility tours available

Veolia is offering tours of its Sauget facility. To arrange a tour

, contact Doug Harris

, 618

- 271

- 2804. The U.S. Environmental Protection Agency plans to renew a Clean Air Act operating permit for Veolia ES Technical Solutions LLC . The permit is for a facility at 7 Mobile Ave. in Sauget, Ill inois that stores and burns hazardous waste. EPA is accepting public comments on the renewal ( see box, left ).

In addi tion to emissions limits

, work practice requirements

, and monitoring and recordkeeping requirements found in Veolia’s current permit, the renewed permit would incorporate some changes , including :

 L imits on how much arsenic, lead, mercury and other metals Veolia

can put into its incinerators

– called the “feedrate limits ” or “OPLs”

– ba sed on results of Veolia’s performance tests in October 2013

.

 E nhanced waste analysis procedures to ensure compl iance with the

metal feedrate limits

.

 T emporary (12 months) installation and operation of a special emissions monitoring system on each incinerator to ensure the

feedrate limits are adequate to assure compl iance with applicable

emissions limits

.

 New requirements for emergency generators.

Veolia will continue operating under its current permit until EPA either

renew s the permit or denies the company’s application

.


### Background The Clean Air Act requires a n operating permit

– known as a Title V permit

– for facilities that emit or have the capacity to emit large amounts of air pollution and for certain types of facilities that must comply with specific

federal standards

. Veolia is required to get a Title V permit because it is subject to federal standards for incinerators and bec ause it has the capacity to emit large amounts of pollution

. This permit details the amount of pollution the facility can emit and what it must do to control the pollution. A Title V permit is valid for five years and may be renewed in five

- year increments

.

EPA issued Veolia’s initial permit Sept

. 12, 2008. In January 2013, EPA began a process to revise the 2008 permit , but later chose to simply incorporate the proposed changes into Veolia’s permit renewal.



### Pollutants affected by the permit

Veolia ’s Sauget facility emits a variety of pollutants regulated by EPA

, including :

 C arbon monoxide

.

 N itrogen oxides

.

 S ulfur dioxid e.

 Fine particles, known as particulate matter

.

 Volatile organic compounds.

 M ercury

.

 S emi

- volatile metals such as cadmium and lead.

 L ow

- volatile me tals such as arsenic, beryllium and chromium.

 Dioxins and furans.

 Hydrogen chloride.

### 2 Burning hazardous waste

Hazardous waste

– w hich is toxic, flammable or corrosive and can react with other materials

– can be produced by businesses or manufacturing operations. Burning hazardous waste

, usually in s pecially designed incinerators, boilers and industrial furnaces

, is one way to safely manage it

.

Burning reduces waste volume by converting solids and liquids to ash while destroying toxic or ganic compounds

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

waste. The ash from hazardous waste combustion must

be tested . If it is still hazardous, it must be treated

before it is disposed of in a l andfill. However, the

incineration of waste can result in emissions of hazardous air pollutants into the air

.
Veolia has three hazardous waste combustors: #2, #3, and #4 (#1 was closed in 1992). Veolia receives

hazardous waste in gas, liquid and solid fo rms.

Veolia may store l iquid waste in a tank farm prior to

burn ing it

. C arbon adsorption units are attached to each tank to help control emissions of gases from the tanks

.

Veolia stores b ulk solid wastes in a building prior to combustion. The structure is maintained at negative

pressure to minimize emissions . Before certain types of waste are burned they are re packaged from their original container s into more manageable containers.

Veol ia burns g ase ou s wastes in Combustor #2 only.

Each combustor has a primary and secondary combustion chamber that includes natural gas

- fired auxiliary burners used during startup, shutdown, and

malfunctions

, and for additional heat input. The

combustors ar e also connected to spray dryer absorbers and baghouse s , which help control air pollution.

Combustor #4 also has a tempering chamber and activated carbon injection to further help control air pollution. Veolia is required to monitor continually for

carb on monoxide and hydrogen chloride emissions

.

The combustors are augmented by a lime handling system and an ash handling system. The lime handling
system feeds lime to 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.



### Changes to the permit A Title V permit is an enforceable compilation of al l operating terms, conditions and li mitations that apply to

a n emission s ource

. It is meant to improve compliance This diagram shows the combustion process of Unit # 2. The processes of Units 3 and 4 are slightly differen t, but follow similar principles

.

This diagram shows the Unit 2 combustion process. The combustion processes of Units 3 and 4 are slightly differe nt, but follow similar principle s. 

## Technical Information and details on EPA’s Planned Veolia Permit Renewal

### 3 by making clear the Clean Air Act requirements with

which the facility must comply

. The permitting authority ensures requirements that apply to the facility are included and that there is enough monitoring and recordkeeping required to verify that the source is in compliance with permit requirements

. EPA, the Title V permitting authority for the Sauget facility, is prop osing

to mak e changes to and renew Veolia ’s existing p ermit

.

P roposed changes to Veolia’s monitoring requirements

will verify the facility is complying with the feedrate

limits and that the limits will assure compliance with

the Clean Air Act ( see “Monitoring,” below )

.

EPA also remove d some requirements that no longer apply. For example, an emission limit previously included in the permit to meet federal standards for the

boiler is no longer applicable because EPA has promulgated new federal stand ards that apply to the

boiler. EPA is therefore replacing that emissions limit

with the new federal standards for boilers.



### Setting the limits Veolia’s permit includes emission limits established by

the following regulations or permits :

 National Emission Standards for H azardous Air

Pollutants , or NESHAPs , which are s tandards promulgated under Section 112 of the C lean Air

Act and promulgated un der 40 C.F.R. Parts 61 and

63

. Veolia is subject to the NESHAP for hazardous waste combustors, 40 C.F.R. Part 63, Subpart EEE

.

 New Source Performance Standards , which are

emission s tandards promulgated under the authority

of Section 111 of the C lean Air Act and promulgated under 40 C.F.R. Part 60

.

 The Illinois S tate Implementation Plan, state regulations found at Tit le 35 of the Illinois

Administrative Code , which are approved and made federally enforceable by EPA and codified at 40 C.F.R. § 52.720.

 Construction and operating permits issued by the

Illinois E PA

.

Most requirements in the current permit will not change

i n the renewal . However, EPA i s adding feedrate limits

for certain heavy metal s and updating other operating parameter limits as required by federal regulations for

hazardous waste combustors. The se limits were established using the results of Veolia’s Oct ober 2013 comprehensive performance tests , and Veolia already is required to comply with the limits under the NESHAP

for hazardous waste combustors , the “HWC MACT.”



### Monitoring In the proposed revisions to the Title V permit, EPA is augmenting Veolia’s feedstream analysis procedures to ensure compliance with the metal feedrate limits. The proposed enhanced waste analysis pro cedures would require Veolia to:

 S ample and analyze each feedstream accepted for incineration unless spec ifically exempted

.

 S ample and analyze all b atched, treated, blended,

mixed or otherwise altered waste for mercury and

other metals in its final form as feed for incineration prior to incineration

, or perform a mass balance

calculation to determine concentrations in the fin al

b atched, treated, blended, mixed or otherwise altered

waste

.

 Not batch, treat, blend, mix or otherwise alter feedstreams which are exempt from sampling unless Veolia samples and analyzes the otherwise exempt

feedstream

.

 D ocument the concentration of mer cury, LVM and SVM in any fuel other than natural gas, including used oil, diesel and alternative fuels fed into the incinerators by either obtaining analytical results from each fuel supplier or conducting representative sampling of each fuel supply and an alyzing such samples using appropriate quality assurance/quality control procedures and test methods. Veolia would follow this procedure at least onc e per year for each fuel supply.

 D ocument concentrations that fall below the

detection limit in non

- exempt feedstreams as equal

to the detection limit

.

 M aintain records of all required feedstream analyses for five years.

EPA also propos es re quir ing Veolia to temporarily install and operate a continuous emissions monitoring
system , or CEMS, on each of its three combustion units. Veolia will operate the CEMS s as paramet r ic monitoring

system s to assess whether the operating parameter limit s for specific metals are adequate to ensure compliance

with federal rules. A s parametric monitoring system s, the CEMS s will ve rify the adequacy of the feedrate

limits

. The systems will test the air emitted during incineration to determine the amount of mercury, semi

volatile metals

, low

- volatile metals and other metals

emitted , and report results approximately once every 15 minutes. The test results will help Veolia and EPA ensure the feedrate limits are adequate to ensure that the facility can comply with the HWC MACT emissions

li mits for mercury, semi

- volatile metals and low

- volatile

metals when comply ing with its metals f eedrate limits

.

EPA will require Veolia to operate the CEMSs for no

less than 12 consecutive months or until EPA has enough information to determine if the proposed feedrate limits are adequate to ensure V eolia complies

with the Clean Air Act.

Once EPA has collected sufficien t information

, EPA will no longer require Veolia to use multi

- metal CEMSs.

### 4 Public comments encouraged The public comment period expires on Friday, Dec. 19

. All written comments mus t be postmarked or emailed no later than Friday, Dec 19

. EPA will consider a ll comments before making a final decision on the permit renewal

. If you submit a written comment, include your name and address and all reasonable r eferences, factual grounds and supporting material. Be sure to note whether you would like to receive notification of EPA ’s final decision and its

responses to comments

.

There are several ways to submit written c omments :

By visiting www. regulations

. gov

– put Docket ID No. EPA

- R05

- OAR

- 2014

- 0280 in the search box.

By m ail to : By e mail to : George Czerniak John Mooney U.S. EPA Region 5 (A

- 18J) mooney.john@epa.gov

77 W. Jackson Blvd. Chicago, IL 60604



### Public h earing details

At the Dec. 3 public hearing you may submit a written statement or make an oral statement. There will be a signup sheet at the entrance for those who wish to present oral testimony. Presentations will be given on a first

- come

- first

served basis. A court reporter will record al l oral statements.

E ach speaker will be limited to five to ten minutes depending on the number of presenters. The EPA representative may ask clarifying questions during the oral presentations but will not respond to the comments at that time.