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 this 

response directly to you and they thought I was sending it. Anyway, here is Veolia’s response to your 

question. 

As we discussed in our phone conversation, Veolia requests the ability to change the methodology 

used to calculate volatile emissions from the following 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 contain 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 Section 4.1.4, “Preferred and Alternative Methods of 

Estimating Air Emissions from Paint and Ink Manufacturing Facilities”, February 2005. This model 

calculation is more appropriate than the TANKS model 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 buildings 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 container 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 moves 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 the 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 calculations assumes that the air flow will be saturated 

with organic compounds where in reality, this is not the case.

This summarizes the reasons why the Surface Evaporation 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 regarding 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