217/782-2113

June 16, 1998

Village of South Elgin

Department of Public Works

Attn: Matt E. Overeem, Director

735 N. Martin Drive

South Elgin, Illinois 60177

Re: Multifilm Packaging Corp. (I.D. No.: 089438AFL, Application:
95090252)

Dear Mr. Overeem:

Thank you for your letter and inquiry regarding Multifilm Packaging
Corp. (Multifilm) located in Elgin, Illinois.

The Illinois EPA has reviewed your letter dated June 10, 1998. In
response to your inquiry:

1\. What is the failsafe mechanism/control devices or procedures should
the catalytic oxidizer fail?

A: Multifilm is required to operate their catalytic oxidizer at all
times their flexographic printing presses are operating. Should the
catalytic oxidizer fail or the supply of natural gas be disrupted,
Multifilm is required to immediately shut down their flexographic
printing presses.

2\. Will the presses stop/shut down in the event of monitoring
equipment, catalytic oxidizer failure, i.e., natural gas disruption?

A: Should the catalytic oxidizer fail or the supply of natural gas be
disrupted, Multifilm is required to immediately shut down their
flexographic printing presses. Additionally, the monitoring equipment
for the catalytic oxidizer is required to be operated at all times the
catalytic oxidizer is in use.

3\. Are MSDS sheets available for the VOM?

A: The application does not contain copies of the Material Safety Data
Sheets (MSDS) for the inks, coatings and solvents used by Multifilm.
However, the permit application contains information on the composition
of the inks, coatings and solvents used by Multifilm. This information
can be found on the \"SUPPLEMENTAL FORM PRINTING AND PUBLISHING\"
(302-CAAPP) forms, which were part of Multifilm\'s Title V permit
application. MSDS sheets for the solvents in the inks should be
available through the Department of Public Health. A copy of
Multifilm\'s Title V permit application is available for public
inspection at the Illinois EPA\'s Regional Office located at 1701 First
Avenue in Maywood, Illinois (ph. #708/338-7900).

4\. Are there any precautionary notices the Village should publish, or
the applicant, to seniors, asthmatic or any other persons at risk?

A: In the event of any air pollution advisory or an episode in any
portion of the State of Illinois, the Illinois EPA will declare either
an advisory, an alert, or an emergency and will notify concerned
personnel of federal, local and other state agencies. The Illinois EPA
also notifies the public by radio, television, and other means of rapid
communication. The Village of South Elgin may be required to file with
the Illinois EPA an episode action plan designed to reduce air
contaminants during alerts or emergencies. The criteria for such plans
is outlined in 35 Ill. Adm. Code Part 244, Subpart C.

5\. 105 tons of VOM per year may be permissible, but it sounds like a
lot - what is the initial volume released before control devices?

A: For the purposes of the type of printing used at Multifilm Packaging,
seventy-five percent of the weight of the ink and one hundred percent of
the weight of the solvent used at the facility is emitted as volatile
organic material (VOM). No VOM is released to the atmosphere before the
control device. Multifilm employs a capture device which meets the
criteria for permanent total enclosure. In other words, Multifilm has
demonstrated that 100% of their VOM emissions are captured from their
flexographic printing presses and directs the emissions to the catalytic
oxidizer, which destroys over 95% of the VOM emitted from the presses.
The company's catalytic oxidizer has a better destruction rate than is
required and the facility's actual emissions, therefore, will be lower
than the permitted level.

Thank you again for your concern in this matter. If you have any
additional questions concerning Multifilm Packaging, please contact
Robert Bernoteit at 217/782-2113.

Sincerely,

Donald E. Sutton, P.E.

Manager, Permit Section

Division of Air Pollution Control

DES:RWB

cc: B. Frost

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