1

Ogulei, David

From: Paddock, Nancy <nancy.paddock@veolia.com>

Sent: Thursday, April 03, 2014 9:24 AM

To: Ogulei, David

Cc: Dennis Warchol

Subject: Re: Title V Request regarding material processing areas and emissions calculations

You should be hearing from Kathy shortly. Sorry for the delay. 

Nancy 

Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115) 

618.271.2128 (fax) 

 

Please note that my e-mail address has changed:

Nancy.Paddock@Veolia.com 

 

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended recipient, please communicate 

with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers. 

On Thu, Apr 3, 2014 at 8:59 AM, Ogulei, David <Ogulei.David@epa.gov> wrote: 

Nancy,

Yes, I received the CTAC package. Thanks!

Kathy Strubberg called me on Tuesday to discuss the reasons why the surface model might be a better model than 

TANKS for estimating emissions from the bulk feed building. I asked Kathy to send me an email on Tuesday 

documenting some of the things she mentioned regarding the unique characteristics of the BF Bldg’s 

operations. She said she would send me an email later that afternoon after running it by Veolia but I haven’t seen 

the email. 
2

As I explained to Kathy on Tuesday, although the estimated VOM/HAP emissions from the BF Bldg are very low, 

we still need a clear and complete explanation of why we are deviating from an established periodic monitoring 

methodology so as to avoid establishing improper precedence. The key here is to expand on your explanation 

below.

David

From: Paddock, Nancy [mailto:nancy.paddock@veolia.com] 

Sent: Thursday, April 03, 2014 8:43 AM 

To: Ogulei, David 

Cc: Dennis Warchol 

Subject: Fwd: Title V Request regarding material processing areas and emissions calculations

 

Good morning David, 

 

Just checking in to see if Kathy Strubberg was able to fully resolve this issue for you. Let me know if there are 

any loose ends to be tied up here. Hopefully you've also received the CTAC package and we can cross that off 

the list. 

 

Thanks and have a good day! 

Nancy

Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115)

618.271.2128 (fax)
3

Please note that my e-mail address has changed:

Nancy.Paddock@Veolia.com

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended recipient, please communicate 

with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers.

 

---------- Forwarded message ---------- 

From: Paddock, Nancy <nancy.paddock@veolia.com> 

Date: Mon, Mar 31, 2014 at 3:12 PM 

Subject: Re: Title V Request regarding material processing areas and emissions calculations 

To: "Ogulei, David" <Ogulei.David@epa.gov> 

Cc: Dennis Warchol <dennis.warchol@veolia.com>, Kathy Strubberg <kathys@syaeng.com> 

Hi David, 

 

Kathy Strubberg will be contacting you tomorrow morning to discuss the differences in detail. In the 

meantime, I'll give you my very simplistic understanding of the matter. TANKS is, of course, a model for 

emissions from tanks, whereas.the evaporative method is a model for spills. Tanks are closed systems which 

produce emissions from vapors displaced during loading operations and temperature changes. Spills have 

surface area directly exposed to the environment. Our processing areas are not closed systems, they have 

surface area directly exposed to the environment. We believe our processing areas are more analogous to spills 

than tanks. Does this help? 

 

Also, Dennis told me you were looking for the CTAC for revisions. I copied all the revisions and Doug signed 

the CTAC once for all of them. They went out Fed Ex today. 

 

Thank you for your patience, David. Have a great day! 

Nancy
4

Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115)

618.271.2128 (fax)

Please note that my e-mail address has changed:

Nancy.Paddock@Veolia.com

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended recipient, please communicate 

with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers.

 

On Mon, Mar 31, 2014 at 8:14 AM, Ogulei, David <Ogulei.David@epa.gov> wrote: 

Hi Nancy,

Good morning! I’m just trying to understand why exactly the surface model is superior to TANKS. TANKS also 

relies on the compound’s vapor pressure to estimate the headspace concentration. Is it possible that TANKS 

could estimate higher emissions than the surface model in some years? What is the fundamental difference 

between the two methods that guarantees that the surface model will always yield higher emissions?

From: Paddock, Nancy [mailto:nancy.paddock@veolia.com] 

Sent: Monday, March 31, 2014 7:33 AM 

To: Ogulei, David 

Cc: Dennis Warchol 

Subject: Re: Title V Request regarding material processing areas and emissions calculations

 

Good morning, David! 
5

 

We used five years worth of TRI data to determine composite VOM and HAP concentration values for use in 

the evaporative equation.. I did not compare five years worth of data. I am working on the 2013 annual 

emissions inventory. Since thru put data for 2013 was handy, I used it to compare TANKS and evaporative 

methods in the small table I sent on March 3, 2014. 

 

I hope this clears things up! 

 

Have a great day! 

Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115)

618.271.2128 (fax)

Please note that my e-mail address has changed:

Nancy.Paddock@Veolia.com

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended recipient, please communicate 

with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers.

 

---------- Forwarded message ---------- 

From: Ogulei, David <Ogulei.David@epa.gov> 

Date: Fri, Mar 28, 2014 at 4:43 PM 

Subject: RE: Title V Request regarding material processing areas and emissions calculations 

To: "Paddock, Nancy" <nancy.paddock@veolia.com> 

Cc: Dennis Warchol <dennis.warchol@veolia.com> 
6

Hi Nancy,

As stated in your email below, the emissions comparison shown in the table below is for one calendar year. Which 

year is this? Do you have emissions data for more than one calendar year that show what the difference in 

emissions between the two methods is? The email says you looked at 5 years of TRI data.

Thanks,

David

From: Paddock, Nancy [mailto:nancy.paddock@veolia.com] 

Sent: Monday, March 03, 2014 1:43 PM 

To: Ogulei, David 

Cc: Dennis Warchol 

Subject: Title V Request regarding material processing areas and emissions calculations

 

Hello David, 

 

Section 2.2(E)(3) of TWI's 2008 Title V permit states that the TANKS program must be used to calculate

emissions from MP1, MP2 and LPR. 

 

Last year, a consultant reviewed our emissions inventory process. The Surface Evaporation Model from EPA 

Guidance EIIP Volume II:Chapter 8 Section 4.1.4. Preferred and Alternative Methods for Estimating Air Emissions from Paint 

and Ink Manufacturing Facilities, March 1998. Equation 8.4-18 was used to calculate emissions from MP1, MP2 and 

LPR. The consultant compiled an average of 5 years of the most recent TRI concentration data to determine 

the concentration of VOC and HAP in the waste, which was then used in the EPA Surface Evaporation Model 

referenced above. 

 

TANKS is based on routine displacement of liquids. The surface evaporation model is based on the volatility 

and ability of a compound to evaporate from the surface of solids and then be picked up by the air in the 

building and carried to the atmosphere. The evaporation method seems to be more appropriate for MP1, MP2 

and LPR; TWI would like to change section 2.2(E)(3) of the upcoming permit (or the equivalent section

thereof) to indicate the Surface Evaporation Model will be used to calculate emissions from these sources. 

 
7

This table compares emissions calculated by both methods for the same calendar year: 

 

TANKS Model Evaporative 

model 

area TPY lb TPY lb 

MP-1 0.06 117 0.21 424 

MP-2 0.02 44 0.11 212 

LABPACK/REPACK 0.03 68 0.04 85 

 

I hope this makes sense. Please let me know if you have questions. 

 

Thank you, 

Nancy

Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115)

618.271.2128 (fax)

Please note that my e-mail address has changed:

Nancy.Paddock@Veolia.com

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended recipient, please communicate 
8

with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers.