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 a reas and emissions calculations** 

You should be hearing from Kathy shortly. Sorry fo r 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

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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 mo del than TANKS for estimating emissions from the bulk feed b uilding. I asked Kathy to send me an email on Tues day documenting some of the things she mentioned regard ing the unique characteristics of the BF Bldg’s operations. She said she would send me an email la ter that afternoon after running it by Veolia but I haven’t seen the email.2 As I explained to Kathy on Tuesday, although the es timated VOM/HAP emissions from the BF Bldg are very low, we still need a clear and complete explanation of w hy we are deviating from an established periodic mo nitoring methodology so as to avoid establishing improper pr ecedence. The key here is to expand on your explan ation 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 Solutio ns, L.L.C. is for the sole use of the intended recipient(s) and may contain confidential and privi leged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you a re not the intended recipient, please communicate with the sender by reply e-mail and destroy all cop ies 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 pro cessing 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 mor ning to discuss the differences in detail. In th e meantime, I'll give you my very simplistic understa nding of the matter. TANKS is, of course, a model for emissions from tanks, whereas.the evaporative metho d is a model for spills. Tanks are closed systems which produce emissions from vapors displaced during load ing operations and temperature changes. Spills hav e surface area directly exposed to the environment. Our processing areas are not closed systems, they h ave 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 E x today.

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

Nancy4 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 Solutio ns, L.L.C. is for the sole use of the intended recipient(s) and may contain confidential and privi leged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you a re not the intended recipient, please communicate with the sender by reply e-mail and destroy all cop ies 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 ex actly the surface model is superior to TANKS. TANK S 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 mo del in some years? What is the fundamental differe nce between the two methods that guarantees that the su rface 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 c omposite VOM and HAP concentration values for use i n the evaporative equation.. I did not compare five years worth of data. I am working on the 2013 annu al emissions inventory. Since thru put data for 2013 was handy, I used it to compare TANKS and evaporati ve 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 Solutio ns, L.L.C. is for the sole use of the intended recipient(s) and may contain confidential and privi leged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you a re not the intended recipient, please communicate with the sender by reply e-mail and destroy all cop ies 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 pro cessing 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 compar ison shown in the table below is for one calendar y ear. Which year is this? Do you have emissions data for more than one calendar year that show what the differenc e in emissions between the two methods is? The email say s 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 area s and emissions calculations

Hello David,

Section 2.2(E)(3) of TWI's 2008 Title V permit stat es that the TANKS program must be used to calculate emissions from MP1, MP2 and LPR.

Last year, a consultant reviewed our emissions inve ntory process. The **Surface Evaporation Model from EPA Guidance EIIP Volume II:Chapter 8 Section 4.1.4.**  **Preferred and Alternative Methods for Estimating Ai r Emissions from Paint**  **and Ink Manufacturing Facilities, March 1998. Equa tion 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 deter mine the concentration of VOC and HAP in the waste, whic h was then used in the EPA Surface Evaporation Mode l referenced above.

TANKS is based on routine displacement of liquids. The surface evaporation model is based on the vola tility and ability of a compound to evaporate from the su rface of solids and then be picked up by the air in the building and carried to the atmosphere. The evapor ation 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 sour ces.7 This table compares emissions calculated by both me thods 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 Solutio ns, L.L.C. is for the sole use of the intended recipient(s) and may contain confidential and privi leged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you a re not the intended recipient, please communicate8 with the sender by reply e-mail and destroy all cop ies of the original message and delete it from all computers.