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 a reas and emissions calculations** 

Yes, David, old habits die hard. We've been throug h many name changes but TWI was the original. I am in fact, referring to Veolia in my original e-mail mes sage.

Please let me know if you need additional informati on 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 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 3, 2014 at 4:28 PM, Ogulei, David < Ogulei.David@epa.gov > wrote:

Nancy,

The email below refers to “TWI” in multiple locatio ns. I’m assuming you are referring to Veolia’s per mit and estimated emissions. If this request indeed pertai ns 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 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.

This table compares emissions calculated by both me thods 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 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.4