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Notes from Meeting with Veolia on Pre-draft of Title V Renewal

September 30, 2014

9:30am

Attendees:

EPA: Genevieve Damico, Andrea Morgan, David Ogulei, and Jane Woolums

Veolia: Jeff Everett, Doug Harris, Joe Kellmeyer, Ryan Kemper, David Klarich, Greg Siedor and Dennis 

Warchol

Veolia’s Comments on the Fact Sheet

- Add an ‘s’ to ‘baghouse’

- Veolia provided a list of their suggested revisions to the fact sheet, and stated that the majority 

were self-explanatory and there was no need to walk through them at the meeting.

- One concern highlighted was the phrase, “emit large amounts of pollution” in terms of Title V 

applicability. Veolia does not believe it emits large amounts of pollution and is subject to Title V 

because it is subject to a MACT.

Comments on the Statement of Basis (SOB)

- Veolia is concerned by language that implies that incinerators 2 and 3 are similar. They note that 

they are distinct units and burn different types of materials. Additionally, there is a vertical duct 

on unit 2 that results in a different cyclonic flow.

- Veolia also stated that there were some minor errors present in the SOB (ie. misrepresentation 

of the size of a tank, and NEIC acronym was incorrectly defined)

- Veolia will make comments during the public comment period

- Veolia has concerns as to the fact that the inadequate FAP was used as justification for the 

CEMS and then both revisions to the FAP and CEMS were required in the permit. They find this 

link to be unclear and believe that the inadequate FAP should only be used to justify and 

enhanced FAP or the CEMS, not both.

Comments on Title V Permit

The requirement for a CEMS

o Veolia notes that to their knowledge no facility in the US or world is currently operating 

a multi-metals CEMS.

o Veolia notes that they have received affidavits from operators who had used a multimetal CEMS and states they do not work.

o Veolia expressed concerns that the requirement to operate a CEMS would render the 

facility non-viable against its competitors.

o Veolia suggests that the issues EPA identified with the FAP are not unique to Veolia and

the justification EPA uses to require a multi-metal CEMS applies to all hazardous waste 
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incinerators. Therefore, all HWC should be required to operate a multi-metal CEMS 

through a MACT revision.

o Doug Harris states that he would be unable to sign a compliance certification for the 

facility if multi-metal CEMS were required because he does not believe the instrument 

works.

o Veolia expressed concerns about lack of a competitive market for CEMS and its ethical 

concerns regarding the fact that they believe it is essentially a sole-source contract.

o Veolia expressed safety concerns when deviations occur

 Waste may begin to react if it is not burned to completion

 Veolia burns some controlled substances that they are not allowed to store, 

they would violate those rules if they were to have to stop incinerating due to a 

deviation.

 If a deviation occurred while something in the blending tank was being burned, 

Veolia states that the tank farm would essentially be shut down since it would 

no longer be able to feed to another incinerator and would prevent other tanks 

from being emptied.

 Veolia believes most tanks contain at least some amount of heavy 

metals.

 The standard is 12 hours, Veolia disagrees with a deviation being determined 

after 15 minutes of data and expressed averaging time concern.

o Veolia believes that deviation could be defined more clearly in the permit.

o Additionally Veolia is concerned that 3 CEMS are proposed in the renewal rather than 

the 1 CEMS proposed in the reopening.

o Veolia indicates that on average, they have scheduled shutdowns once every 6-9 

months and the shutdowns last for 7-9 days. However, the other two incinerators are 

operational whenever the one is shutdown.

The FAP

o Veolia requested to have the technical staff meet separately to discuss the FAP

 They believe they have an improved feedstream analysis

 Will schedule a meeting with Veolia to discuss

o Veolia currently has 2 ICP’s (and has a third on order) and 4 Indirect Mercury Analyzers.

o Veolia stated that the NEIC report was informative and they have made changes as a 

result

o They no longer along generators to use a standard profile for waste that contains heavy 

metals.

The NOx, SO2, Opacity, and VOM testing during CPT

- Veolia has no objection to doing initial baseline testing

- Veolia would prefer this be a one-time test at a separate time from the CPT test, 

suggested during confirmatory testing for difuran

- Veolia would be willing to replicate the parameter of the CPT testing for the other 

testing

- Doug Harris stated that he does not believe that the NOx, SO2, Opacity, and VOM testing 

would threaten the viability of Veolia.
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Hospital Medical Infectious Waste

- Veolia does not burn hospital medical infectious waste and does not anticipate burning 

it since it is not cost effective. However, they do have an IL permit that would allow 

them to burn it, they just currently choose not to.

- They would like the prohibition to burn hospital medical infectious waste removed from 

their permit in case they change their mind and would like to burn it in the future.

- EPA explained that prohibition was added to the permit so they would have a nonapplicability determination and shield. The provision could be removed but Veolia 

would then lose it shield. Additionally, Veolia could always apply for a revision to burn it 

should they decide to burn it in the future.

- Veolia stated that they would need to discuss the matter further internally.