### RE: Veolia Environmental Services Veolia Environmental Services Veolia Environmental Services ( fka Onyx fka Onyx fka Onyx) Significant Modification

Significant Modification Significant Modification - Reed, Michael Michael Michael to: David Ogulei 08/08/2012 12:54 PM
Cc: "Belogorsky, Anatoly ", Danny Marcus, Genevieve Damico, Jane Woolums History: This message has been forwarded.



### Thanks David. I am not necessarily concerned with the EJ Plan except for awareness of the activities that would take place.

What I am more concerned with are the actual limits that USEPA Region V will be allowing Veolia to operate under for Heavy Metals. I believe that our BOL staff is also a little concerned for what these modifications are in this permit and whether they are acceptable and consistent.

You may not be aware, but Illinois EPA still has a pending enforcement action before the IAGO regarding violations of Hg feed rates, semi-volatiles and I believe HCl/Aresenic also. The Illinois EPA, before USEPA took over the permit had Veolia do testing with extremely tight oversight and Veolia could not demonstrate compliance at any higher extrapolated values or even at the actual feed rates they were putting in the system.

I am just a bit alarmed at what we might be allowing given the sensitivity of the area.

Michael T. Reed, CAAPP Unit Manager Illinois Environmental Protection Agency BOA/DAPC/Permit Section 1021 N. Grand Ave East Springfield, Illinois 62794 Michael.Reed@illinois.gov Office: 217.782.4651 | Fax 217.524.5023 E-MAIL CONFIDENTIALITY NOTICE: This electronic mail message, including any attachments, is for the intended recipient(s) only. This e-mail and any attachments might contain information that is confidential, legally privileged or otherwise protected or exempt from disclosure under applicable law. If you are not a named recipient, or if you are named but believe that you received this e -mail in error, please notify the sender immediately by telephone or return e -mail and promptly delete this e-mail and any attachments and copies thereof from your system. If you are not the intended recipient, please be aware that any copying, distribution, dissemination, disclosure or other use of this e-mail and any attachments is unauthorized and prohibited. Your receipt of this message is not intended to waive any applicable privilege or claim of confidentiality , and any prohibited or unauthorized disclosure is not binding on the sender or the Illinois Environmental Protection Agency . Thank you for your cooperation.
From: David Ogulei [mailto:Ogulei.David@epamail.epa.gov] Sent: Wednesday, August 08, 2012 12:38 PM To: Reed, Michael Cc: Belogorsky, Anatoly ; Danny Marcus; Genevieve Damico; Jane Woolums Subject: Re: Veolia Environmental Services (fka Onyx) Significant Modification -

Here is where things stand with respect to your 7 questions below:1. EPA received an updated application from Veolia on March 2, 2010. EPA will make the updated

application, as well as any supplemental information, available to the public and Illinois EPA as part of the permit record.

2. EPA is still preparing a draft permit and statement of basis for this permit action. We will inform you when these documents are available for review .

3. A public repository has not yet been established . EPA will establish a public repository and communicate its location to the public and Illinois EPA once a draft permit is issued for public comment.
4. The public notice date has not yet been determined. The public notice will state the end the public comment period.

5. Although it is likely that EPA will share a preliminary draft permit with Illinois EPA before seeking public comment, that decision has not yet been made.
6. In general, we intend to follow the guidance documented in "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 (June 26, 2012). However, we are still finalizing an EJ plan that is specific to this permit action.

7. Illinois EPA has been involved in discussions on an EJ plan for this permit action. More discussions might occur, as necessary, once EPA proposes a preliminary draft permit.

Please contact me with any questions.

David Ogulei U.S. Environmental Protection Agency Region 5 | Air & Radiation Division | A -18J 77 West Jackson Blvd. | Chicago, Illinois 60604 Phone: (312) 353-0987 | Fax: (312) 692-2080 Ogulei.David@epa.gov

"Reed, Michael" ---08/08/2012 11:51:16 AM ---Is it possible to get an update on the above permitting action? 1. Is there an application or an

From: "Reed, Michael" <Michael.Reed@Illinois.gov> To: Genevieve Damico/R5/USEPA/US@EPA, "Belogorsky, Anatoly "
< Anatoly .Belogorsky@Illinois.gov>, Cc: David Ogulei/R5/USEPA/US@EPA, Danny Marcus/R5/USEPA/US@EPA Date: 08/08/2012 11:51 AM Subject: Veolia Environmental Services (fka Onyx) Significant Modification -

Is it possible to get an update on the above permitting action? 1. Is there an application or any updates/supplements to this application?

2. Is there a draft permit/statement of basis that has been prepared?

3. Is there a public repository that contains all the documentation in the permitrecord that was relied on ? If so
, is it electronic and where would I find that repository?

4. What is the date when Public Notice will begin and when is the Public Comment period?

5. Will the Illinois EPA see a preliminary draft before Notice for review ?

6. What are the planned EJ activities for this permit?

7. Has there been any outreach with Illinois EPA ( Air , Water and Land) regarding sufficiency of any limits and compliance status of the source?

Thanks.