1 **Ogulei, David**

**From: Kathy Strubberg [kathys@syaeng.com]** 
**Sent: Thursday, April 03, 2014 9:28 AM** 
**To: Ogulei, David** 
**Cc: 'Paddock, Nancy'; 'Dennis Warchol'**  **Subject: Veolia Response** 

**Importance: High** 

**David,**

**I apologize for not getting this to you sooner. There was a mixup as I thought Veolia was sending t**  **his response directly to you and they thought I was sen**  **ding it. Anyway, here is Veolia’s response to your**  **question.**

**As we discussed in our phone conversation, Veolia r equests the ability to change the methodology** 
**used to calculate volatile emissions from the follo wing emission units:** 

**Emission Unit Description** 

**MP-1 Material Processing Area** 

**MP-2 Material Processing Area**  **Lab Pack Repack Batch Material Processing Area**  **Bulk Feed Building Bulk Solid Waste Storage** 

**The current Part 71 permit requires the use of the most recent version of the TANKS program to**  **calculate VOM/HAP emissions from the MP-1, MP-2 and Lab Pack Repack emission units [Permit**  **Condition 2.2(E)(3). Although the permit doesn’t c ontain a similar condition for the Bulk Feed**  **Building, the proposed new methodology differs from that used in the permit application.** 

**Veolia believes that a more appropriate calculation methodology is the Surface Evaporation Model as**  **found in the EPA’s EIIP Volume II: Chapter 8 Sectio n 4.1.4, “Preferred and Alternative Methods of**  **Estimating Air Emissions from Paint and Ink Manufac turing Facilities”, February 2005. This model**  **calculation is more appropriate than the TANKS mode l for the following reasons.** 

**1. MP-1, MP-2 and the Lab Pack Repack units are waste**  **storage and processing buildings utilized**
**for containers. Containers are received into the b uildings and held there prior to processing either**  **within the building or directly to the incinerator feeds. The stored containers are closed with a lid**  **or cover which allows no volatiles to escape the conta**  **iner during storage. Containers are only opened to sample and process the contents. The processing**  **consists of placing the waste from a container either into open troughs through which the waste mo**  **ves through sizing activities and is repacked into feed containers; or directly into feed containers.**  **The waste in the trough is open to the atmosphere o f**  **the building. As such constituents in the waste volatilize into t**  **he building atmosphere and are emitted through the building exhaust.** 

**2. The surface evaporation model estimates the amount**  **of constituents volatized based on the volatility of the different waste constituents and**  **the air flow across the exposed surface of the wast e.**  **It is a conservative estimate as the calculations a ssumes that the air flow will be saturated with**  **organic compounds where in reality, this is not the case.** 2 **This summarizes the reasons why the Surface Evapora tion Model produces more representative**  **emission estimations than the TANKS program for the MP-1, MP-2, Lab Pack Repack and Bulk Feed**  **Building emission units at the plant.**

**Please call me if you need anything further regardi ng this matter.** 

**Regards, Kathy** 

**Kathy Strubberg Principal Engineer**  **Schreiber, Yonley & Associates**
**16252 Westwoods Business Park Drive Ellisville, MO 63021**  **Cell: (314) 607-9753 Work: (636) 256-5641**  **kathys@syaeng.com**