v>EPA
United States
Environmental Protection
Agency
What can you do?
•	Submit written comments
to U.S. EPA regarding the
draft permit during the
comment period that runs
from Jan. 8 to March 15,
2013. Comments should
include factual grounds and
supporting material or
references.
•	Attend the public hearing
on Feb. 19,2013, at the
Southern Illinois University
Edwardsville - East St.
Louis Higher Education
Campus, Distance Learning
Lab, Room 2083, Building
B, 601 James R. Thompson
Blvd., East St. Louis, from 3
p.m. to 7 p.m. See more
details on the comment
period and meeting on the
back page.
•	Go on a tour. Veolia will
be offering facility tours. To
arrange a tour contact Doug
Harris or Dennis Warchol at
618-271-2804.
•	Review the statement of
basis and draft permit.
The statement of basis
provides more information
and explains the legal and
factual bases for the permit
conditions. The draft Title V
permit includes all of the
requirements the source is
legally obligated to follow.
Only portions of the permit
that are being changed
because of the proposed
action are currently open for
comment during the
comment period. See Page 3
for locations where you can
view these documents.
U.S. EPA Proposes to Reopen
Title V Air Permit
Veolia ES Technical Solutions Air Permit
Sauget, Illinois	January 2013
The U.S. Environmental Protection Agency is proposing to reopen a Clean
Air Act permit for a hazardous waste combusting facility in southern
Illinois. U.S. EPA is undertaking this permit action for Veolia ES
Technical Solutions LLC., 7 Mobile Ave., Sauget, 111., near St. Louis, to
modify its Clean Air Act Title V operating permit. The revised permit
would include ""fcedrate" limits for certain heavy metals. Feedrate limits
are the maximum amount of heavy metals Veolia can feed into the
incinerator combustion unit per hour. The heavy metals include mercury,
arsenic and lead. The permit also would include additional requirements
for monitoring the waste incinerated by Veolia at the facility.
U.S. EPA has based the proposed feedrate limits, which comply with
applicable regulations, on available performance test data. Veolia will
continue operating the combustors following the requirements of their
current permit until a final revised permit is issued. U.S. EPA will not
issue a final permit until after the public has a chance to comment. See the
left-hand box and read Page 3 for information about the public
participation process for this proposed permit.
Background
The Clean Air Act requires certain sources that emit large amounts of air
pollution to obtain an operating permit, also known as a Title V permit,
after the source has begun to operate. This permit is designed to improve
compliance by clarifying what facilities must do to control air pollution.
For this permitting action U.S. EPA is the permitting authority. U.S. EPA
issued the initial Title V permit to Veolia on September 12, 2008. U.S.
EPA is now proposing to reopen the permit to incorporate feedrate limits
and monitoring requirements so that the permit complies with the Clean
Air Act. Only those portions of the permit that US. EPA is proposing to
change are open for public comment at this time. The federal Agency
expects the facility to submit an application for a permit renewal in 2013
and will open the entire permit comment at that time.
Burning hazardous waste
Specially designed incinerators, boilers, and industrial furnaces can burn
hazardous waste. Hazardous waste - which is toxic, flammable, corrosive
or reacts with other materials - can be produced by businesses or
manufacturing operations. Burning hazardous waste is one way to safely
manage it. Burning reduces waste volume by converting solids and liquids
to ash while destroying toxic organic compounds. In addition, disposal of
the ash in a landfill is safer and more efficient than disposal of untreated
hazardous waste. The ash generated from hazardous waste combustion
must be tested, and, if found to be hazardous, must be treated for
remaining toxicity before it is disposed of in a landfill.
Continued on P. 2 ...

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MAIN STACK-
DIRECT INJECT
	p-	FUELS/LIQUID WASTE FLOW
			COMBUSTION AIR FLOW
	p.	STACK GAS FLOW
CCCCCO-	ASH FLOW
>0000-	SOLID WASTE FLOW
\\\>-	lime slurry flow
PRIMARY
FUEL
DRY SCRUBBER
SOUDS ( OSS )
END DUMP
LIME
preparation
SYSTEM
SPECIALTY
FEEOER
DRY SCRUBBER
SOLIDS ( OSS )
END DUMP
BAGHOUSE
LOW
BTU
LIQUIDS
INCINERATOR
UPPER
CHAMBER
INCINERATOR
LOV£R
CHAMBER
SPRAY
DRY
ABSORBER
SLOWER
SOLIDS
HIGH
BTU
LIQUIDS
This diagram shows the combustion process of Unit § 2. The combustion processes of Units 3 and 4 are slightly different, but
follow similar principals.
Veolia has three hazardous waste combustors: #2, #3,
and #4 (#1 was closed in 1992). Veolia receives
hazardous waste in both liquid and solid forms. Liquid
waste may be stored in a tank farm prior to being
burned. Gases occasionally escape from the tanks, and
carbon adsorption units are attached to each tank to
help control these emissions. Bulk solid wastes are
stored in four pits in a building prior to combustion.
The structure is maintained at negative pressure so
emissions don't escape. Before the waste is burned it is
packaged into more manageable containers and any
liquids are absorbed.
Each combustor has a primary and secondary
combustion chamber that includes natural gas-fired
auxiliary burners used during startup, shutdown,
malfunctions and for additional heat input. The
combustors are also connected to spray dryer absorbers
and a baghouse, which help to control air pollution.
Combustor #4 also has a tempering chamber and
activated carbon injection to further help control air
pollution. Emissions are constantly monitored for
carbon monoxide and hydrogen chloride.
The combustors are supported by a lime handling
system and an ash handling system. The lime handling
system supports 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.
Pollutants affected by the permit
The proposed permit action sets feedrate limits for
mercury, semi-volatile metals such as cadmium and
lead, and low-volatile metals such as arsenic, beryllium,
and chromium. Volatility is a measure of how readily a
substance changes from a solid or liquid to a vapor.
These pollutants have known negative health effects.
U.S. EPA is setting feedrate limits in this action that
comply with applicable federal regulations. More detail
about each of these pollutants can be found in the
statement of basis. Information on how to review the
statement of basis is found on the last page of this fact
sheet.
Setting the limits
The heavy metal feedrate limits were established using
the results of comprehensive performance tests Veolia
performed in August and September 2008. U.S. EPA is
proposing to incorporate into Veolia's Title V permit
the mercury feedrate limits used by the company during
its 2008 testing. For the other heavy metals, the federal
Agency is proposing slightly higher feedrate limits than
the ones used in the 2008 tests. These higher feedrates
are allowed under federal regulations.
Monitoring
In the proposed revisions to the Title V pennit, Veolia
will be required to install and operate a multi-metals
continuous emissions monitoring system (CEMS) on
one of its combustion units (Unit #3) for at least one

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year. A multi-metals CEMS tests the air emitted during
the incineration process to determine the amount of
mercury, semi-volatile metals and low-volatile metals
emissions, and reports the results approximately once
every fifteen minutes. The test results will help U.S.
EPA ensure the feedrate limits are adequate to protect
air quality. After a year of running the CEMS, U.S.
EPA believes we will have enough information to
determine if the feedrate limits we are currently
proposing are adequate to ensure that Veolia complies
with the requirements of the Clean Air Act. Once U.S.
EPA has collected sufficient data, Veolia will no longer
be required to use the multi-metals CEMS.
Public participation
You can participate in the decision-making process on
the permit by submitting comments during the public
comment period that runs from Jan. 8 to March 15,
2013 or at the Feb. 19 public hearing in East St. Louis
(see front page box).
All written comments must be postmarked or emailed
no later than March 15, 2013. U.S. EPA will consider
all written and oral comments received within the
public comment period will be considered before
making a final decision on the proposed action. U.S.
EPA will consider written statements and supporting
information submitted during the comment period with
the same weight as any oral comments and supporting
information presented at the public hearing. Your
comments should include your name and address and
all reasonable references, factual grounds, and
supporting material. Be sure to note whether you would
like to receive notification of U.S. EPA's final decision
regarding the permit and its responses to comments
submitted during the public comment period.
Comments can be submitted:
•	Via the Internet at the www.regulations.gov/
website at Docket ID No. U.S. EPA-R05-
OAR-2012-0649 or at
www.epa.gov/region5/newsevents/ and look
in the "public comment" section.
•	Mail to George Czerniak, U.S. EPA, 77 W.
Jackson Blvd. (A-18J), Chicago, IL 60604.
•	Email to John Mooney at
moone v. i ohn@epa. gov.
At the Feb. 19 public hearing you will be invited to
present any comments or concerns you have about the
proposed changes. U.S. EPA is required to consider all
comments and respond to all relevant comments. A
signup sheet will be available at the public hearing for
those who are interested in presenting oral testimony
and spots will be available to present on a first-
come/first-serve basis.
Each speaker will be limited to 5 to 10 minutes
depending on the number of presenters. The U.S. EPA
representative may ask clarifying questions during the
oral presentations but will not respond to the comments
at that time. If you require translation services or
special accommodations for the public hearing contact
U.S. EPA's Andrea Morgan at
morgan.andrea@epa.gov by February 5, 2013.
View the documents
The draft permit and another document called a
statement of basis, which explains the bases for the
proposed revisions to the permit, can be reviewed at:
•	The www.regulations.gov/ website at Docket
ID No. U.S. EPA-R05-OAR-2012-0649 or at
www.epa.gov/region5/newsevents/ and look
in the "public comment" section.
•	Central Library, 1301 Olive St, St. Louis, MO
63103.
•	East St Louis Library, 5300 State St., East St
Louis, IL 62203.
•	Cahokia Public Library, 140 Cahokia Park
Drive, East St Louis, IL 62206
3

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