1

Ogulei, David

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

Sent: Tuesday, March 04, 2014 6:28 AM

To: Ogulei, David

Cc: Dennis Warchol

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

Yes, David, old habits die hard. We've been through many name changes but TWI was the original. I am in 

fact, referring to Veolia in my original e-mail message. 

Please let me know if you need additional information regarding this request. 

Thanks and have a great 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) 

 

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 3, 2014 at 4:28 PM, Ogulei, David <Ogulei.David@epa.gov> wrote: 

Nancy,

The email below refers to “TWI” in multiple locations. I’m assuming you are referring to Veolia’s permit and 

estimated emissions. If this request indeed pertains to Veolia, we will review the request as part of the renewal 

permit application.

Thank you.
2

David Ogulei

U.S. Environmental Protection Agency

Region 5 | Air & Radiation Division | A-18J 

77 West Jackson Blvd. | Chicago, Illinois 60604 

Phone: (312) 353-0987 | Fax: (312) 692-2080

Ogulei.David@epa.gov

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. 

 

This table compares emissions calculated by both methods for the same calendar year: 
3

 

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 

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

computers.
4