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Veolia Sauget Air Permitting

Site-Specific Risk Assessment

At the request of the Illinois Attorney General and the Illinois EPA, U.S. EPA has updated its 2007 site-specific risk assessment for the Veolia facility in Sauget, Illinois. U.S. EPA’s report analyzes potential emissions from the three hazardous waste incinerators that Veolia ES Technical Services, L.L.C. owns and operates in Sauget. The incinerators are regulated under Illinois EPA’s Resource Conservation and Recovery Act (RCRA) permit and U.S. EPA’s 2019 Clean Air Act Title V permit.

The risk assessment demonstrates that compliance with current feed-rate limits in the federal Title V permit should be protective of public health in the area near the facility. U.S. EPA also recommends that Illinois EPA consider including emission limits for mercury and chromium in its RCRA permit.

Veolia, ES Technical Solutions (Veolia), which is located at 7 Mobile Avenue in Sauget, Illinois, stores and burns hazardous waste.   The Clean Air Act requires an 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 hazardous waste incinerators and because it has the capacity to emit large amounts of pollution.

Basic Information about Operating Permit

Permitting Actions

Veolia Sauget Air Permitting – Final Part 71 Permit Renewal

On June 17, 2019, the U.S. EPA issued a final revised Clean Air Act Title V renewal permit for Veolia’s hazardous waste incinerator in Sauget, Ill.  The final permit revises the permit that EPA issued for the Veolia facility on January 18, 2017, consistent with the settlement agreement  it reached with Veolia in March 2018.

The final permit does not change most requirements in the 2008 permit.  However, EPA has added limits on how much arsenic, lead, mercury and other metals Veolia can put into its incinerators – known as the “feedrate limits” – as well as additional monitoring requirements to ensure that Veolia complies with its emissions limits. The 2019 permit also requires Veolia to install and operate mercury emissions controls on two incinerators that previously did not have mercury controls.  Like the 2017 permit, the final 2019 permit continues to include significant improvements to Veolia’s feedstream analysis procedures.

The final permit, EPA’s responses to comments received during the public comment period, and other support documents, are found below.  These documents are also available at www.regulations.gov; Docket ID No. EPA-R05-OAR-2014-0280.

Permit Renewal Documents

Veolia Sauget Air Permitting – Part 71 Permit Renewal Support Documents

Comprehensive Performance Tests Reports

All documents relied upon in the permitting decision-making process can be found at www.regulations.gov; Docket ID No. EPA-R05-OAR-2014-0280.

Veolia Sauget Air Permitting – Historical Documents

Proposed January 2013 Air Permit Reopening

In January 2013 EPA proposed to reopen a Clean Air Act permit for a hazardous waste combusting facility in southern Illinois. U.S. EPA proposed this permit action for Veolia ES Technical Solutions LLC., 7 Mobile Ave., Sauget, Ill., near St. Louis, to modify its Clean Air Act Title V operating permit. The revised permit included “feedrate” 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 proposed permit also included additional requirements for monitoring the waste incinerated by Veolia at the facility.

U.S. EPA 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. EPA held a public hearing on February 19, 2013 and accepted comments on the proposed permit reopening until April 1, 2013.

After taking comment on the draft reopening of Veolia’s permit, because of the timing of EPA’s proposal in relationship to the expiration of Veolia’s existing permit and the regulatory requirement for Veolia to perform compliance testing, EPA decided instead to incorporate revisions into Veolia’s permit at renewal.

All documents associated with the 2013 proposed reopening can be accessed at www.regulations.gov, Docket ID: EPA-R05-OAR-2012-0649.

2008 Initial Part 71 Permit

Veolia (formerly Onyx Environmental Services) submitted to Illinois Environmental Protection Agency (IEPA) on September 7, 1995, an application for a Title V permit for its facility in Sauget, Illinois. IEPA issued a draft Title V permit on June 6, 2003, and the public comment period for the permit ended September 12, 2003. During the public comment period, IEPA received comments on the draft permit. IEPA revised the permit and submitted the proposed permit to EPA on November 6, 2003. EPA did not object to the proposed permit within its 45-day review period, which ended December 21, 2003.

On February 18, 2004, EPA received a petition from the Sierra Club and American Bottom Conservancy requesting that EPA object to issuance of the Veolia Title V permit, pursuant to Section 505(b)(2) of the CAA and 40 C.F.R. § 70.8(d). On February 1, 2005, EPA issued an order granting the petition in part and denying it in part. Pursuant to 40 C.F.R. § 70.8(c), this action started a 90-day period during which IEPA was required to issue a revised Title V permit that addressed the issues raised in the February 1, 2005 order. IEPA did not issue the permit within the 90-day window. The Sierra Club and the American Bottom Conservancy sued EPA, alleging that EPA had a duty to issue the permit following the State of Illinois’ failure to timely issue the revised permit.

On September 29, 2006, EPA announced its intent to issue or deny a federal Title V permit. Veolia submitted a Part 71 permit application to EPA on May 2, 2007. EPA deemed the application administratively complete on June 13, 2007. EPA issued a final Part 71 permit on September 12, 2008.

All documents associated with the 2008 permit can be accessed at www.regulations.gov, Docket ID: EPA-R05-OAR-2008-0235.

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