Modification to the 2019 Title V Permit
On February 22, 2021, Veolia submitted an application to modify the 2019 permit through the minor modification process found at 40 CFR 71.7(e). EPA is reviewing the permit application.
The company has requested two revisions to the 2019 permit:
- Revise certain Operating Parameter Limits (OPLs) based on the results of stack testing conducted in 2018.
The federal emission standards that apply to Veolia (40 CFR Part 63, Subpart EEE) require the facility to establish and comply with operational limits (termed OPLs) that are representative of operating levels achieved during the most recent compliance stack test. The OPLs include limits on the maximum amounts of certain heavy metals and total hazardous waste that the facility can feed into each incinerator, parametric ranges for control equipment, among other things. Compliance stack tests, from which the OPLs are established, must be conducted every 5 years. Veolia conducted its most recent stack test in October 2018.
To ensure the OPLs do not impede normal day-to-day operations, sources generally take measures to operate during compliance testing under conditions that are among the most challenging for emissions of the range of normal operations. For example, sources often feed ash, metals, and chlorine during compliance testing at substantially higher than normal levels (e.g., by spiking the feedstream) to maximize the feed concentration, and they often detune the air pollution control equipment to establish operating limits on the control equipment that provide operating flexibility. The emission levels achieved during compliance tests are intended to be the highest emission levels a source emits under reasonably anticipatable circumstances. By designing its stack test to generate emissions under conditions that are among the most challenging for emissions of the range of normal operations, a source can establish OPLs that account for variability in operations (e.g., composition and feedrate of feedstreams, as well as variability of pollution control equipment efficiency) and that do not impede normal operations. Complying with the OPLs therefore helps assure compliance with federal emission standards during periods between the compliance stack tests.
- Revise the Feedstream Analysis Plan (FAP). Veolia is requesting to incorporate into the 2019 permit a new FAP dated December 2020 as an enforceable portion of the permit. This plan contains the procedures the company will follow to sample and analyze the waste it burns.
Under 40 CFR Part 63, Subpart EEE, to demonstrate compliance with certain emissions limits, such as limits for mercury, arsenic, lead and others, Veolia must either comply with OPLs as discussed above, or it may petition EPA to approve the installation and continuous operation of emission monitoring systems to directly measure and document compliance with those emissions limits. Veolia has not petitioned EPA to install and operate continuous emissions monitors for those metals. Therefore, Veolia must analyze each feedstream prior to feeding the material into any of its incinerators and document the amount of those pollutants present in the feedstream. The procedures for the required analyses must be documented in a FAP that is sufficient to document compliance with the applicable OPLs.
In the 2019 permit, EPA prescribed specific procedures for sampling and analysis of feedstreams for certain heavy metals. The 2019 permit required Veolia to submit to EPA a revised FAP that incorporated into the plan the feedstream analysis procedures contained in the 2019 permit. The new FAP must update the 2008 FAP and incorporate the minimum procedures specified in the 2019 permit. EPA approved Veolia’s revised FAP on January 13, 2021.
Relevant Documents: