2/11/15

Post Comment Period Meeting with Veolia

Attendees: John Mooney (EPA), David Ogulei (EPA), Jane Woolums (EPA), Genevieve Damico (EPA), 

Motria Caudill (EPA), Andrea Morgan (EPA), Ryan R. Kemper (Thompson Coburn), Dennis Warchol 

(Veolia), Greig Siedor (Consultant for Veolia), David Klarich (Veolia), Doug Harris (Veolia), Joe Kellmeyer 

(Thompson Coburn), Jeff Everett (Veolia), Christie Narez (Veolia)

EPA General Comments:

 EPA still sees a CEMS as feasible

 Wants to move forward quickly

 Requests that if we come to an agreement, Veolia agree to not appeal the permit

Activated Carbon Injection

 Veolia is comfortable with activated carbon injection. It is used on unit #4, they know how to 

run it

 Proposes to add it to unit #2 and #3

 Believes that it would benefit Veolia, in terms of reputation as well as air quality

 Veolia does not want the CPT scheduling changed as a result of installing it.

 EPA expressed that it would expect parameter testing as well as testing to determine the ideal 

carbon injection rate. EPA would need to discuss whether the CPT testing would need to be 

changed.

 Veolia believes that no additional testing should be required. It believes since CPT testing 

confirmed compliance without activated carbon injection, it should not be required to test the 

efficiency of the Activated Carbon Injection or test to determine the injection rate. Testing is 

costly and not necessary for compliance.

 Veolia considers additional testing to be a potential deal breaker.

 Veolia requested clarification of who they would need a permit from. EPA responded that it is in 

charge of Title V, IEPA is in charge of NSR.

 IEPA would work on a construction permit in a quick time frame.

 Veolia agrees to submit a construction permit application for the Activated Carbon Injection 

system within the next 2 to 4 weeks. Once the permit is issued, Veolia anticipates installing the 

Activated Carbon Injection system within 180 days.

 EPA suspects that IEPA would issue the construction permit prior to EPA public noticing the Title 

V permit. While it would be cleaner for IEPA to issue the construction permit first, EPA could 

issue the Title V permit after the NSR application was filed.

 EPA expressed that it would be beneficial to submit for Veolia to submit the NSR application 

soon.
 EPA requested that Veolia install the injection site upstream of the SDA as EPA believes the 

control efficiency is increased when upstream of the SDA because it would lead to the removal 

of both elemental and ionic mercury. 

 Veolia thinks that temperature wise it may not be feasible to install the injection site upstream 

of the SDA. Veolia thinks that the carbon would ignite upstream and thinks it would pose a 

safety concern. Veolia will research further, but they believe in most cases where the injection is 

upstream of the SDA are lower temperature environments.

Call with IEPA on permit application: Chris Romaine and Bob Smet

 IEPA believes that an activated carbon injection system would require a permit as it would likely 

increase PM in vents are require changes to carbon handling.

 The application fee if $500.

 IEPA estimates a 30-45 day turn around.

 If Veolia requested expedited review, it could be finished in 20-25 days, but would increase the 

fee.

 IEPA would perform enhanced outreach. It would not hold a public hearing but would send 

information about the project to an interested parties list

 Bob Smet is the IEPA contact.

Feedstream Analysis Plan

 Veolia believes that it has greatly enhanced its FAP due to what it has learned from 

communications with NEIC, EPA, industry, customers, etc. 

 Veolia has increased the number of its technicians and equipment.

 Veolia believes it has correctly characterized its emissions or even overestimates them.

 Veolia agrees with most of the proposed revisions in the enhanced FAP, but has a few concerns.

 They believe that the exemptions are there for a reason

o They should not be required to sample and analyze explosives due to potential risks

 They will rely on generator and process s knowledge. Veolia believes it 

estimates these emissions conservatively.

o Veolia requests an exemption from sampling narcotics- they don’t want staff handling 

them or them to be opened.

o They want an exemption for items (such as batteries) that are easily identifiable 

 In general they have concerns about the language that states that if metals are present sampling 

must be performed. They want to add exemptions for visually identifiable wastes on a case by 

case basis.

 They would be comfortable with a plan that utilizes some of the concepts of the Ohio WAPS

 Veolia is not analyzing everything every time because some metal bearing wastes are consistent 

in content. They prefer to minimize unnecessary sampling because every time something is 

analyzed hazardous waste is generated, and there are additional resource management 

concerns.

 EPA reminded everyone to keep in mind the different goals of the FAP and WAP.
Fenceline Monitoring

 EPA stated its goal is to look at what the community is experiencing from Veolia’s facility.

 Suggested sites for the monitors were the North and South ends of the facility

 EPA suggests permanently installing the monitors

 Veolia suggests installing them for a year.

 Veolia wants to know if the multimetal XACT had been used at other locations.

 EPA would like the data to be displayed on a public website and envisions that Veolia would 

maintain monitors and meteorological monitors and that Veolia would submit a QA/QC plan 

for monitoring.

 Veolia expressed concerns about doing business with Cooper, is unsure if other machines 

and manufacturers exist.

 EPA would like monitoring to occur on a continuous/semi-continuous basis. At a minimum 

EPA requests monitoring for mercury, lead, chromium, cadmium, arsenic, and if possible, 

beryllium. 

 Veolia expressed concerns about the height of its stacks and the capability to monitor at the 

fenceline.

 Veolia requests to remove ambient air quality monitoring from the Title V permit and 

include it as a joint venture. Veolia envisions providing funding and inviting outside 

interested parties.

 Veolia requested to approach potential constituents together with EPA- EPA said we weren’t 

sure if that would be possible.

 Veolia suggested making an educational component to the monitor and would like to 

involve Washington University or Southern Illinois University of Edwardsville in the 

monitoring.

FAP discussion between David Ogulei (EPA), Andrea Morgan (EPA), Genevieve Damico (EPA), Dave 

Klarich (Veolia) Dennis Warchol (Veolia), and Christie Narez (Veolia)

Exemption Concerns

 Veolia would like to take out the “if it has metals it should be sampled language” as it applies to 

exemptions

 If it is not on the exempt list and may contain metals it is tested.

 Veolia would like to add “visually identifiable” to the exemption list

 EPA expressed concern as to what visually identifiable means.

 Veolia stated that the WAP lists out which items are considered “visually identifiable”

 Veolia documents how the characterization for exempted items is determined. For visually 

identifiable items they consider where it is from.

 Data from generators is certified every 2 years or if they discovers something is non-conforming.
 When characterizing, Veolia uses the maximum value from internal knowledge or 

profile/generator knowledge in order to be conservative.

 EPA discussed using an averaging method similar to what is used in Ohio for visually identifiable 

and similar feedstreams. To do something like that, Veolia would need to submit a proposal with 

examples as to why an exemption was needed/warranted.

 Veolia charges facilities extra to deal with waste containing mercury. They consider themselves 

to have an economic advantage to properly characterizing the mercury content.

 Due to its ATF permit, Veolia is required to justify how much metal is included in explosives.

 Veolia cites that there are cases in which it makes sense to batch exempted items- such as 

sometimes they receive centrum vitamins and they come in boxes of just pills as well as pills in 

bottles. 

 EPA requested that Veolia provide examples of which exempt materials could be batched. 

 Veolia uses the detection limit of 0.04. 

 Veolia feels that it has been getting “mixed signals” with regards to how to handle non-detects. 

During the CPT Veolia was required to use 0 for non-detects.

 The NOC feedrate limits are based on zeros for non-detects.

 EPA may need to recalculate the feedrate off of this information.

 Veolia does not want to over report TRI due to non-detect values.

 Veolia would like a procedure developed to be able to add feedstreams to the exempt list. 

Veolia would like to be able to have the technical manager to have discretion to add certain 

types of feedstreams. EPA agreed to work with Veolia on developing a means to respond to 

requests to add certain items quickly. 

Fenceline Monitoring discussion with Motria Caudill and group

 Motria reviewed her background and qualifications

 Veolia expressed concern that the coal and gravel dust would “clog” the filter.

o Motria suggested running it at faster intervals

 Veolia expressed concerns about the public’s view of data and that it would prefer to not have 

the data on its website.

 Veolia suggested joining in a joint venture with USEPA and providing funding for a 2nd XACT.

o EPA expressed concern that would be considered a gift to the government and not be 

ethically appropriate or something that we could accept.

 Veolia wants details from EPA in writing describing what we expect Veolia with the fenceline 

monitor.

 Motria presented the idea of a fenceline filter monitor rather than an XACT.

 Veolia would like to invite Washington University and Sierra Club to discussions and is willing to 

host meetings to discuss monitoring with interested parties.

 Veolia will begin activated carbon injection permitting and responding to FAP questions.

 Depending on what we propose as principle parts of the monitoring Veolia may be able to agree 

to it

 Veolia would like to involve other Sauget industries in the modeling discussions.

 Veolia would be willing to donate to Washington University to operate fenceline monitors

 Veolia only sees the monitors being onsite for a year.