1 Ogulei, David

From: **Kathy Strubberg <kathys@syaeng.com>** Sent: **Thursday, April 03, 2014 9:42 AM** To: **Ogulei, David** Cc: **'Paddock, Nancy'; 'Dennis Warchol'** Subject: **RE: Veolia Response**

**Your welcome!**

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**

**From:** Ogulei, David [mailto:Ogulei.David@epa.gov] **Sent:** Thursday, April 03, 2014 9:40 AM **To:** Kathy Strubberg **Cc:** 'Paddock, Nancy'; 'Dennis Warchol' **Subject:** RE: Veolia Response

No problem. This explanation should do it. Thank you.

**From:** Kathy Strubberg [ mailto: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** 2 **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**  **of 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 waste. It is a conservative estimate as the calcul**  **ations assumes that the air flow will be saturated with organic compounds where in reality, this is no**  **t the case.**

**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**