Electronic Filing -Received, Clerk's Office, January 24, 2011 

* ****AS 2011-001 * * * * * IEPA ATTACHMENT NO 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER OF: 

PETITION OF GREIF PACKAGING, LLC AS ____ _ 

FOR AN ADJUSTED STANDARD FROM 

35 ILL ADM. CODE PART2I8 

SUBPART IT 

) 

) 

) 

) 

) 

) 

(Adjusted Standard- Air) 

NOTICE OF ELECfRONIC FILING 

TO: 

·-

---~Jehn-Therriault,-Gler-k------------Divisien-ef-begal-Geunsel--------

Illinois Pollution Control Board Illinois Environmental Protection Agency 

James R. Thompson Center I 021 North Grand Avenue East 

I 00 West Randolph Street, Suite 11-500 P.O. Box 19276 

Chicago, IL 60601 Springfield, IL 62794-9276 

PLEASE TAKE NOTICE that I have today electronically filed with the Office of the 

Clerk of the Illinois Pollution Control Board, Petitioner's NOTICE OF ELECTRONIC 

FILING, NOTICE OF APPEARANCE, PETITION FOR AN ADJUSTED STANDARD 

and CERTIFICATE OF SERVICE, copies of which are attached herewith served upon you. 

Date: January 24, 20 II 

Thomas W. Dimond 

Susan Charles 

ICE MILLER LLP 

200 West Madison Street 

Suite 3500 

Chicago, Illinois 60606 

Respectfully submitted, 

ICE MILLER, LLP 

By: /s/ Susan Charles 

One of its Attorneys 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * *AS 2011-001 * * * * * 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER OF: 

PETITJON OF GREIF PACKAGING, LLC 

FOR AN ADJUSTED ST At"\IDARD FROM 

35 ILL ADM. CODE PART 218 

SUBPART IT 

) 

) 

) 

) 

) 

) 

AS ___ _ 

(Adjusted Standard- Air) 

NOTICE OF APPEARANCE 

PLEASE TAKE NOTICE THAT, pursuant to 35 Ill. Adm. Code Section 101.400(A)(4), 

-----lthe-law-firm-<:Jf-ICE-MIL.L.ER,--LLP-hereby-fil~-its-Appear-anoo-in-this-proGeGding-on-behalfof--·- · ·· ··-- -· 

petitioner, GR1EF PACKAGING, LLC. 

Date: January 24, 2011 

Thomas W. Dimond 

Susan Charles 

ICE MlLLER LLP 

200 West Madison Street 

Suite 3500 

Chicago, Jllinois 60606 

Respectfully submitted, 

ICE MILLER, LLP 

By: lsi Susan Charles 

One of its Attorneys 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

CERTIFICATE OF SERVICE 

I, the undersigned, certify that on this 24th day of January, 2011, I have served 

electronically the attached NOTICE OF ELECTRONIC FILING, NOTICE OF APPEARANCE, 

and PETITION FOR AN ADJUSTED STANDARD upon the following person: 

John Therriault, Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

I 00 West Randolph Street, Suite 11-500 

Chicago, IL 6060 I 

I 

.I 

! 

' 

-----------------------------------··-

and by U.S. Mail, first class postage prepaid, to the following persons: 

Division of Legal Counsel 

Illinois Environmental Protection Agency 

1021 North Grand Avenue Em;t 

P.O. Box 19276 

Springfield, IL 62794-9276 

/s/ Susan Charles 

Susan Charles 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS2011-001 ***** 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MA TIER OF: 

PETITION OF GREIF, INC. AND 

GREIF PACKAGING, LLC 

FOR At~ ADJUSTED STANDARD FROM 

35 ILL ADM. CODE PART 218 

SUBPARTTT 

) 

) 

) 

) 

) 

) 

) 

AS ___ _ 

(Adjusted Standard- Air) 

PETITION FOR AN ADJUSTED STANDARD -------=:::::::::::===::::::::::::==========-----··--·---, 

GREIF, INC. and GREIF PACKAGING LLC ("Greif''), through its counsel and pursuant 

to 35 Ill. Adm. Code§ I 04.400, et seq., submits this Petition for an Adjusted Standard 

("Petition") to the Illinois Pollution Control Board ("Board"); seeking an adjusted standard from 

35 Ill. Adm. Code§ 218.986(a) as it applies to control requirements for emissions of volatile 

organic material ("VOM") at Greif's Naperville, Illinois fiber drum manufacturing facility. 

I. INTRODUCTION AND SUMMARY OF PROPOSED ADJUSTED STANDARD 

Greif operates a fiber (paper) drum container manufacturing facility in Naperville, 

DuPage County, Illinois. In general, fiber drums are produced by cutting fiber material to the 

appropriate length, forming the material into a cylinder and attaching a top and bottom to the 

cylinder. Some of the fiber drums require the addition of a polyethylene drum liner to meet 

customer specifications, particularly for storage and transport offood-grade products. Greif 

conducts quality control ("QC") testing ofthc liners of these drums by spraying a QC test fluid (a 

denatured alcohol product, which is a VOM) into the interior of the drums at the QC spray 

station. The drums then are conveyed 45 feet to the QC inspection station where the interior of 

the drwn is visually inspected for pinholes. If pinholes are present, the ethanol causes a brown 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

spot to appear, enabling the line inspector to detect the pinhole. The drum is then conveyed 120 

feet to a drying oven where most of the remaining test fluid is evaporated. After leaving the 

drying oven any remaining fluid is vacuumed fi·om the drum and then the drum is wiped dry. 

YOM is emitted throughout the QC Test Process as well as in the paint drying oven. Emissions 

ofVOM are calculated based on the mass ofVOMs used assuming that all usage is emitted to 

the atmosphere. 

Air emissions ofVOM and hazardous air pollutants ("HAPs") at Greifs Naperville 

---~faGility-ar(}-SubjsGt-to-Federaliy-Bnforeeable-State·Gperating-Permit-No:-9'707'044-(.1!f-ESE>Pl!.),..t.---·--- ·-

Condition 3 of the FESOP limits YOM emissions from the QC Test Process (which includes the 

paint drying oven) to 22.8 tons per year ("tpy"). Condition 3 also includes emission unit specific 

limits on YOM emissions from the remainder of the plant (which includes a paint spray booth, a 

caulk applicator, water based ink printing and the Weather Pak Winder). The aggregate of these 

limits is 1.4 tpy. The FESOP limits HAP emissions to I 0 tpy for any single HAP or 25 tpy for 

any combination of such HAPs. Greif reported 2009 emissions from its Naperville facility of7.7 

tons ofVOM (plant-wide) and total combined HAPs of 1.3 tons. 

On July 5, 2007, the Jllinois Environmental Protection Agency ("Agency") issued 

Violation Notice A-2007 -00132 ("Violation Notice") to Greif alleging, in relevant part, that the 

Naperville facility exceeded condition 3 of the FESOP, relating to YOM emissions. Greif 

reported emissions from the QC Test Process in 2006, 2007, 2008 and 2009 of35.2, 46.7, 19.1 

and 7.7 tons, respectively. The Agency alleges that Greil's VOM emissions now are subject to 

the 81 percent capture and control requirements of 35 Ill. Adm. Code Part 218, Subpart TT, 

Section 218.986(a), because emissions in 2006 and 2007 exceeded the 25 tpy applicability 

1 In 2006, the FESOP was issued to Greif Bros. Corporation, which had changed its name to Greif, Inc. Greif, Inc. 

has transferred ownership and operation of the Naperville plant to its wholly owned subsidiary, Greif Packaging 

LLC. When the FESOP is renewed, it will also be transferred into the name of Greif Packaging LLC. 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

threshold and because Subpart TT is a "once in- always in" regulation. See 35 Ill. Adm. Code 

Section 218.980 (a)-(c). 

The Board promulgated 35 ill. Adm. Code Part 218 to implement reasonably available 

control technology ("RACT") for sources ofVOM emissions within certain areas of Illinois. See 

In the Matter of Reasonably Available Control Technology for Major Sources Emitting Volatile 

Organic Materials in the Chicago Ozone Nonatlainment Area: 25 Tons, R93-14, Final Order 

(January 6, 1994). Section 218.986 provides, in relevant part: 

Every owner or operator of an emission unit subject to [Subpart TT] shall comply 

with the requirements of subsection (a), (b), (c), (d), or (e) below. 

a) Emission capture and control equipment which achieves an 

overall reduction in uncontrolled YOM emissions of at 

least 81 percent from each emission unit .... 

Greif conducted a RACT Study to evaluate whether various emission control options for 

the QC Test Process satisfy RACT control requirements in Section 218.986(a). See Exhibif A, 

Reasonably Available Control Technology Study, dated August 2010, prepared for Greif by 

Thomas C. Ponder, Jr., PE ("RACT Study"). Gteif submitted the RACT Study to the Agency on 

September 16, 2010. The RACT Study evaluated three capture and control systems: capture 

plus recuperative thermal oxidizers, capture plus carbon adsorbers and capture plus biofilters and 

material substitution. The RACT Study concludes that each option could achieve at least 81 

percent capture and control ofVOM emissions as required under Section 218.986(a), but only at 

a cost per ton ofVOM emissions controlled of between $11,667- $17,672. These costs exceed 

what the Board typically has considered reasonable in adopting RACT regulations. See infra at 

Section II(H)(l )(d). 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

The RACT Study also evaluated the technical feasibility and economic reasonableness of 

two material substitution options: mixing the QC test fluid with acetone or water. Material 

substitution using acetone was found to be technically infeasible because of product quality 

concerns related to the effect of acetone on the product. Acetone in the QC test fluid causes the 

gasket material that seals the drum bottom to the side walls to dissolve, which is unacceptable. 

However, material substitution using a test fluid composed of 45 percent denatured alcohol and 

55 percent water achieves a 55 percent reduction in YOM emissions and results in an overall cost 

-------,.ledm:tiun4Jre-RA.:eT-studyC'O'!Kluoes than:lie material subsrirutwn option using 45 percent 

denatured alcohol and 55 percent water constitutes RACT for Grief's Naperville facility. Based 

on the RACT Study and the analysis of adjusted standard requirements as set forth herein, Greif 

has satisfied the conditions for issuing an adjusted standard from the 81 percent capture and 

control requirement of Section 218.986(a). 

II. 35 ILL. ADM. Code Section 104.406: Petition for Adjusted Standard 

The procedural requirements for submission of an adjusted standard petition to the Board 

are found at 35 Ill. Adtn. Code Part 104, Regulatory Relief Mechanisms, Subpart D. Sections 

I 04.406(a)- Q) of Subpart D specify the information that must be included in any adjusted 

standar~ petition. The requisite headings and corresponding information required under Subpart 

D are set forth below. 

A. Standard From Which Reliefls Sought- Section I 04.406(a) 

Greif seeks an adjusted standard from the requirements of35 Til. Adm. Code Part 218, 

Subpart TT, Section 218.986(a), Control Requirements, which sets emission reduction 

requirements for sources ofVOM emissions not regulated under other subparts of Part 218. 

Section 218.986 became effective January 6, 1994. RACT for Chicago Ozone, R93-l4. Pursuant 

4 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

to Section 218.980(b)(1), the applicability threshold for Subpart IT is the potential to emit 25 

tpy of YOM, in the aggregate, from emission units at a source other than those specifically 

excluded from Subpart IT. The control requirement~ for qualifying emission units at sources 

subject to Subpart TI' are set forth in Section 218.986. Section 218.986 provides, in relevant 

part: 

Every owner or operator of an emission unit subject to [Subpart IT] shall comply 

with the requirements of subsection (a), (b), (c), (d), or (e) below. 

a) Emission capture and control equipment which achieves an 

overall reduction in uncontrolled YOM emissions of at 

least 81 percent from each emission unit .... 

Greif seeks an adjusted standard from the 81 percent capture and control requirement of Section 

218.986(a) as it applies to Grief's Naperville facility. The facility is not seeking an adjusted 

standard from Section 218.986(b)- (e)? 

As Greif will demonstrate, achieving captme and control of at least 81 percent of YOM 

emissions from its QC Test Process is not economically reasonable as applied to Greif, could 

increase emissions of other pollutants and may pose increased health and safety risks. Other 

alternative control strategies are technically infeasible because of negative impacts on product 

quality. Instead, Grief proposes to dilute the QC test fluid from 100 percent denatured alcohol to 

45 percent denature~ alcohol and 55 percent water. Modification of the QC test fluid will reduce 

YOM emissions from Greifs QC Test Process by 55 percent- to an armual emission level that is 

below the applicability threshold of Subpart TT. 

2 Subsections (h)- (e) are not applicable lo the QC Test Process at Naperville and thus are not included in this 

Petition. See 35 IlL Adm. Code Section 218.986(b)- (e) (applicable to: coating lines (subsection (b)), submission 

of an equivalent alternative control plan (subsection (c)), non-contact process cooling water (subsection (d)) and 

specific control measures applicable to leaks from components subject to the control requirements of Subpart IT 

(subsection (e))). 

5 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * ***AS 2011-001 * * * * * 

Greif will not require an adjusted standard from Section 218.108, "Exemptions, 

Variations, and Alternative Means ofConh·ol or Compliance Detenninations" for the adjusted 

standard from Section 218.986(a) to become effective at the state level. Section 218.108 

provides: 

Notwithstanding the provisions of any other Sections of this Part: 

a) Any exemptions, variations or alternatives adopted by the 

Board pursuant to Scctio!l 28, 28.1 or 3 5 of the Act to the 

control requirements, emission limitations, or test methods 

------------set-forth-in-this-Part-shalJ-be-effcctive-only-wiTen--approvellt-------

by the USEPA as a SIP revision. 

While the Agency will need to request the United States Environmental Protection Agency's 

("USEP A") approval of any Board-approved adjusted standard from Section 218.986(a) in the 

fonn of a SIP revision, the adjusted standard will be effective at the state level immediately upon 

granting by the Board. See In the Matter of Petition of Alumax Inc. for an Adjusted Standard 

from 35 Ill. Adm. Code Part 2I 8, AS 92-13, Slip. Op. at 4 (September I, 1994); see also, In the 

Matter of Reasonably Available Control Technology for Major Sources Emitting Volatile 

Organic Materials in the Chicago Ozone Nonatlainment Area: 25 Tons, R93-14, Slip. Op. 

(Second Notice) at 5-6 (November 18, 1993). 

B. Natme of the Regulation of General Applicability- Section I 04.406{b) 

The Board promulgated 35 Ill. Adm. Code Part 218 to implement Section 182(b)(2) of 

the Clean Air Act, 42 U.S.C. § 7511 a(b )(2), which, among other things, requires individual states 

with severe non-attainment areas to adopt RACT regulations applicable to sources of VOM 

emissions within the non-attainment area. See RACTfor Chicago Ozone, R93-14, Slip Op. 

(Final Rule) at 2. As mandated by the Clean Air Act, the Board promulgated Part 218, including 

Subpart TT. I d. 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * *AS 2011-001 * * * * * 

C. Level of Justification- Section l04.406(c) 

The regulations of general applicability from which Greif seeks an adjusted standard do 

not specify a level of justification for an adjusted standard. Accordingly, the level of 

justification is that generally applicable to all adjusted standards. See 415 ILCS 5/28.1 

(Authorizing the Board to grant an adjusted standard upon adequate proof of the following: ( l) 

the factors relating to the petitioner are substantially and significantly different fi·om the factors 

relied upon by the Board in adopting the general regulation applicable to the petitioner; (2) the 

-------,·xtsterrce-ofthose-factursjustinesi!ITildjusted-slllndard;-(3)the requestml-standard-willoot resolr--·· 

in environmental or health effects substantially and significantly more adverse than the effects 

considered by the Board in adopting the rule of general applicability; and ( 4) the adjusted 

standard is consistent with applicable federal law.). 

D. Facility and Process Description- Section 1 04.406(d) 

Greif operates a fiber drum container manufacturing facility in Naperville, DuPagc 

County, TIIinois. DuPage County is part ofthe Metropolitan Chicago Interstate Air Quality 

Control Region. 40 C.P.R. § 81.14. This area is designated as a non-attainment area for ozone 

(1-hour and 8-hour standard) under 40 C.P.R.§ 81.314. 

The Naperville facility employs about 90 hourly and salaried people. Fiber drum 

manufacturing began at the Naperville plant in Aprill988. Greif's Naperville facility 

manufactures fiber drums ranging in size from six (6) gallons to seventy-five (75) gallons. In 

general, fiber drums are produced by cutting fiber material to the appropriate length, fonning it 

into a cylinder and attaching a top and bottom to the cylinder. Some of the fiber drums require 

the addition of a polyethylene drum liner to meet customer gpecifications, particularly for storage 

and transport of food-grade products. Greif conducts QC testing of the liners of these drums 

7 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* ****AS 2011-001 * * * * * 

using spray test equipment as follows: (1) a QC test fluid (a denatured alcohol product, which is 

a YOM) is spmyed into the interior of the drums at the QC spray station; (2) the drums are 

conveyed 45 feet to the QC inspection station where the interior of the drum is visually inspected 

for pinholes; (3) the drums are conveyed 120 feet to a drying oven where most of the remaining 

test fluid is evaporated; ( 4) after leaving the drying oven any remaining fluid is vacuumed from 

the d)Um and then the drum is wiped dry. The QC test fluid evaporates slowly, resulting in 

YOM emissions throughout the process. See RACT Survey at Section 1.0. 

------- Irraddition·to-the~e-rest-Process-describ-ed-ab-ove-;VC3M-emi-ssion-;rources-at1Jre---·-··---

Naperville facility include the paint drying oven, a caulk applicator, the paint spray booth, water 

based ink printing and the Weather Pak Winder. Each of these sources has a source-specific 

annual YOM limit in the FESOP, and the aggregate of those YOM limits is 1.4 tpy. Because the 

plant's emissions have historically been less than 25 tpy, the facility has not previously been 

subject to Subpart TT and does not employ any equipment to capture or destroy YOM emissions. 

E. Investigation of Compliance Alternatives: Methods for Reducing YOM 

Emissions from Greif's Quality Control Testing Process Emission Unit- Section 

I 04.406(e) 

Relevant provisions of Section 218.986 would require Greif to capture and control at 

least 81 percent ofVOM emissions from the QC Test Process through the application of 

emission capture and control equipment. Greif investigated multiple compliance alternatives and 

the corresponding costs for each alternative. See RACT Study at Section 3. As discussed below, 

the RACT Study demonstrates that dilution of the QC test fluid with water is the only technically 

feasible and economically reasonable alternative. This alternative also can be implemented 

without increased health and safety risks and without additional emissions that may potentially 

offset the benefits of any associated YOM reductions. 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * *AS 2011-001 * * * * * 

1. Capture Systems 

Greif's fiber drums with polyethylene liners are sprayed with the QC test fluid, conveyed 

45 feet to the QC test station for visual inspection and then conveyed 120 feet to the drum paint 

oven to evaporate most of the QC test fluid. The QC test fluid evaporates while the drums are 

being sprayed, transported for and awaiting inspection and then conveyed to the drum paint 

oven. Any remaining test fluid is vacuumed or wiped from the drums and to the extent it still 

contains VOM, may still be emitting VOM. An effective captnre system would require a tunnel 

-------,rrclusure<:overingihld-65-toot conveyer systemJTmnlheQC spray station to tbe inspecff~- ---· ·· 

station and, later, to the drum paint oven. See RACT Study at Section 3.1. Enclosures also 

would be needed for the hood at the QC spray station and the opening of the dmm paint oven to 

ensure adequate captnre of emissions. !d. Dueling to the associated control device(s) also would 

be required from the QC Test Process hood, the conveyor tunnel enclosure and the drum paint 

oven. !d. This type of capture system is assumed for each control method discussed below. The 

' 

capital and annual operating costs for the capture system are included within the cost summary 

for each control system. 

2. Control Technologies. 

Greif's RACT Study includes a thorough evaluation of the following add-on control 

technologies: (a) recuperative thermal incinerator; (b) carbon adsorption; and (c) biofilter and 

material substitution. !d. at Section 3.2. As detailed below, each of these potential control 

systems are economically unreasonable, have inherent characteristics that could partially offset 

the environmental benefits ofVOM reduction and/or have potentially harmful safety impacts. 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

a. Recuperative Thermal Incinerators 

Thermal incinerators heat an exhaust stream to a temperature sufficiently high to oxidize 

(burn) YOM in the exhaust. Thennal recuperative oxidizers have a heat exchanger that preheats 

the incoming air by recuperating heat from the exiting air. !d. at Section 3.2.1. As the incoming 

air passes on one side of the metal tube or plate, hot clean air from the combustion chamber 

passes on the other side of the tube or plate. Heat is transferred to the incoming air through the 

process of conduction using the metal as the medium of heat transfer. This system has heat 

------recovery·as-great·as-60-percentmld·tJwrefOre requires less natural gas ilian trauitional-~- -- -----

incinerators to boost the combustion temperatures to 1600°F (the required temperature to ensure 

complete destruction of YOM). !d. 

While a recuperative thermal incinerator can be more cost-effective than a traditional 

incinerator, it requires a large amount of natural gas as compared to other control options (fuel 

must be used even when the QC Test Process is not operating to maintain the thermal oxidizer at 

temperature). !d. Frequent operation cycles in thermal oxiders cause condensation corrosion 

and thermal deterioration of the insulation which requires ongoing maintenance costs. !d. at 

Section 1.0. ln addition, the large amount of natural gas required to operate thermal oxidizers 

generates NOx and CO emissions and small quantities of YOM and HAPs, which would 

partially offset any benefits obtained from the associated YOM reduction. !d. 

The RACT Study concludes that total capital costs of the capture system and the 

recuperative thermal incinerator control technology at Greif's Naperville facility would be 

$1,752,000 with annualized capital and operating costs of $17,672 per ton of YOM controlled. 

See RACT Study at Table 4-1. 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

b. Carbon Adsorbers 

Carbon adsorbers are used to control systems with low to medium YOM emission 

concentrations. See RACT Study ut 3.2.2. A carbon adsorbcr typically consists of two or more 

beds of activated carbon- one treats the exhallst emissions while the other is being regenerated. 

I d. Typically, regeneration involves passing steam through the carbon bed to remove the YOM 

with the steam, leaving the regenerated carbon to be reused. Carbon adsorbers work best with 

insoluble YOM, which simplifies the recovery of the YOM from the saturated beds. Jd. In some 

-----,cases;-distillation-is-required-to-separatc-the-'V0M-materi"alsihmn1Rn'llgenerution steam. Ja~·----

The QC test fluid is water soluble and would be very expensive to recover from the 

regeneration fluid. Jd. In addition, the regeneration fluid likely could be sent to a local sewage 

district along with Grief's other process wastewaters. I d. Most sewer districts use equalization 

basins to reduce biological oxygen demand loading, which in this context includes YOM, by 

blowing solvents into the atmosphere; meaning that YOM emissions may not truly be reduced by 

the use of carbon beds. I d. Further, ketones found in the denatured alcohol present an inherent 

safety risk of fires from reactions between the ketones and the carbon in the beds. I d. Although 

carbon beds that handle ketones utilize water deluge systems to control bed fires, the increased 

health and safety risks remain. I d. 

The RACT Study concludes that total capital costs ofthe capture system and ·the carbon 

adsorbers control technology would be $1,170,000. This control option would result in total 

annualized capital and operating costs of$12,594 per ton of YOM controlled. See RACT Study 

at Table 4-1. 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * ***AS 2011-001 * * * * * 

c. Biofiltcr and Material Substitution 

Biofilters can be used to reduce YOM emissions without the use of natural gas to burn 

the hydrocarbons. See RACT Study at Section 3.2.3. Bioren has proposed to install a biofilter 

on the Greif drum plant in Oakville, Ontario, which could potentially reduce YOM emissions 

from that plant by 70 percent. Id. At Naperville, the 81 percent capture and control objective 

could be met only by combining the biofilter with another control technology or by considering 

the reductions in YOM emissions from the use of the water diluted test fluid as a capture and 

-----nontrohechnulugyreductiun-:-fd;-A-biufl:lter system has lower operating costs,allhougb!he- -·- ·· ·- ·- · 

capital costs are comparable to incinerators. Id. Biofiltcrs must be heated to maintain 

destruction activity during winter months and heat for the filter can be supplied by the direct 

combustion of natural gas, steam or electricity. Id. Natural gas used for combustion would 

increase NOx emissions from the facility, partially offsetting the benefit from reductions in 

YOM emissions. Id. 

Based on the RACT Study, total capital costs to install the capture system and the 

biofilter control technology (which includes use of the water diluted test fluid) is $1,800,000 and 

annualized capital and operating costs are $11 ,667 per ton of YOM controlled. See RACT Study 

at Table 4-1. 

3. Material Substitution Options 

a. QC Test Fluid- Dilution with Acetone 

Greif considered dilution of the QC test fluid with acetone (a non-YOM material) as a 

possible alternative. However, dilution of the testing fluid with acetone could cause the gasket 

material scaling the bottom of the drum to the drum walls to dissolve. See RACT Study at 3.3.2. 

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Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

Due to the potential for product damage, diluting the QC testing fluid with acetone is considered 

technically infeasible. !d. 

b. QC Test Fluid- Dilution with Water 

Grief evaluated the operational impact of diluting the QC test fluid with varying amounts 

of water as a means to reduce YOM emissions. Grief experimented with different ratios of water 

to denatured alcohol to identify the composition able to reduce YOM emissions to the greatest 

extent possible while maintaining the ability to visually detect pinholes or other tears or 

----------- impertectiOnS!n llieoium hnmgs. 

The testing procedure involved intentionally creating pinholes in the liners of five drums 

before sending them tlrrough the QC Test Process. The drums were sprayed with varying 

modifications of the QC test fluid and visually inspected to dete1mine if the pinholes could be 

detected within an acceptable time period (here, about 70 seconds). !d. at 3.2.1. If the pinholes 

were detected, the test and the associated test fluid were considered acceptable. Id. If the 

pinholes could not be detected, the fluid was considered a technically infeasible option based on 

Grief's inability to meet its customers' quality assurance standards. !d. 

Greif experimented with five potential alternative test fluids. A mixture of 80 percent 

denatured alcohol and 20 percent water revealed pinholes in each of five test drums within about 

5 seconds. Id. Based on this result, Greif next experimented with a mixture of 70 percent 

denatured alcohol and 30 percent water. The 70/30 mixture revealed pinholes in each of five test 

drums after 7 seconds; but with noticeably lighter staining than with the 80/20 mixture. Id. A 

third test, using a SO percent denatured alcohol and 50 percent water mixtme identified 

significantly lighter staining around pinholes in each test drum within 45 seconds. I d. The test 

using 40 percent denatured alcohol and 60 percent water failed to identify flaws in the liners 

13 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * *AS 2011-001 * * * * * 

within an acceptable time period. I d. Grief then evaluated a 45 percent denatured alcohol and 

55 percent water mixture. This mixture detected all of the pinholes within 50 seconds of 

spraying- although with significantly lighter staining. I d. Based on these test nms, Greif 

detennined that 55 percent dilution with water was the highest dilution percentage that would 

allow the plant to meet its customer's quality assurance requirements. 

Greif informed the Agency of these test results and began utilizing the diluted QC test 

fluid in May 2008 to achieve immediate reductions in VOM emissions even though the Agency 

had not formally approved the substitution. To date, the water-diluted test fluid has allowed the 

detection of drum defects without harming the product. 

Diluting the QC test fluid with water also has the potential to reduce annual emissions of 

VOM from the QC Test Process below the 25 tpy applicability threshold of Section 2!8.980 and 

below the 22.8 tpy emissions limit in condition 3 of the FEElOP. This has been demonstrated by 

the significant reduction in overall facility emissions between 2007 and 2008. See supra, at 2. 

In addition, diluting the QC test fluid with water results in lower operating costs. Total capital 

costs to dilute the QC test fluid with water would be $0 and annualized capital and operating 

costs are reduced by $679 per ton ofVOC controlled. See RACT Study at Table 4-1. 

4. Compliance Alternatives Conclusion 

Three capture and control systems would be technically feasible: capture plus 

recuperative thermal oxiders, capture plus carbon adsorbers and capture plus biofilters and 

material substitution. While each of these options could achieve the 81 percent capture and 

control objectives of Subpart IT, the cost/ton ofVOM controlled range from $11,667 to 

$17,672. These costs exceed what the Board has considered reasonable in adopting RACT 

regulations. See infra at Section II0-!)(1 ). Material substitution using acetone is technically 

14 
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*****AS 2011-001 * * * * * 

infeasible because of product quality issues. Material substitution using 55 percent water and 45 

percent denatured alcohol results in an overall reduction in costs while achieving a 55 percent 

reduction in YOM emissions compared to pre-substitution levels. 

F. Greif's Proposed Adjusted Standard- Section I 04.406(±) 

Greif proposes the following adjusted standard for adoption by the Board: 

I. Greif will reduce YOM emissions from its QC Test Process 

by using a test fluid composed of 45 percent denatured 

alcohol and 55 percent water. 

2. Greif will coordinate with the Agency to submit to EPA a request for 

revision of the Sll' consistent with this proposed adjusted standard 

requiring usc of the diluted QC test fluid as an alternative to capture and 

control technology. 

3. Environmental staff of Greif's parent will conduct a formal training 

session for Naperville facility personnel on the requirements of the FESOP 

and the internal procedures for tracking compliance with FESOP 

conditions. 

4. Greif will continue to implement an improved system for monthly tracking 

and calculations of YOM emissions and monthly comparison of the 

calculations to YOM limits contained in the FE SOP. The results of the 

comparison will continue to be reported to Greif's facility management 

monthly so that any deviations or exceedances of FESOP conditions can 

be identified and tin1ely reported to the Agency as required by FESOP 

condition 6. 

G. Quantitative and Qualitative Description of Greif's Impact on the Environment 

Before and After the Proposed Adjusted Standard- Section 1 04.406(g) 

1. Air Quality Impact Analysis of Greifs Operations 

Application of the proposed adjusted standard will allow Greif to reduce current YOM 

emissions fi·om the QC Test Process by 55 percent. While this reduction is less than the 81 

percent capture and control requirement of Section 218.986( a), the proposed adjusted standard 

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will allow Grief to reduce YOM emissions below levels required by its FE SOP and the threshold 

for Subpart TT applicability. 

The emissions of YOM from the QC Test Process at the Naperville plant will have no 

impact on air quality. In 2009, state-wide YOM point source emissions were 54,668 tons. See 

Illinois Annual. Air Quality Report 2009, Table C-5 (IEPA November 2009) (available at 

www .epa.state.il.us/air/air-quality-report/2009/air-gual itv-report -2009 .pdf). Thus, even at the 

maximum pennitted emissions levels for the Naperville plant (22.8 tpy based on condition 3 of 

--·----t:he-FES0P);-Ve>M-emission:rfrorrrthe-QC!esrProcess woulo amounno a15ounJ.04% of state~-

wide point source emissions. Similarly, 2009 YOM point source emissions for the Metropolitan 

Chicago area were 11,884. See September 8, 2010 E-mail from EPA.FOIA.BOA@ lllinois.gov 

to Susan Charles responding to Freedom of Information Act request, attached as Exhibit B. 

Assuming maximum emissions pennitted under the FESOP for the Naperville plant, YOM 

emissions from the QC Test Process would amount to only 0.19% of Metropolitan Chicago point 

source emissions. 

The Board previously has found that adjusted standards from Subpart TT from sources 

with much higher YOM emissions would have no significant impact on air quality. See, e.g., In 

the Matter of' Petition of Ford Motor Co. (Chicago Assembly Plant) for an Adjusted Standard 

from 35 Ill. Adm. Code Section 218.986, AS 00-6, Slip. Op. at 5 (April6, 2000) (uncontrolled 

emissions of390 tpy would have no significant impact on air quality or human health); In the 

Matter of' Petition of Alumax, Inc. for an Adjusted Standard from 35 Ill. Adm. Code Part 218, 

AS 92-13, Slip. Op. at 9 (Sept. 1, 1994) (excess uncontrolled emissions of76 tpy would not 

significantly impact air quality). The Board also has shown a particular concern for capture and 

control technologies, such as incinerators, that create alternate emissions, e.g., NOx, which also 

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contribute to ozone formation or hazardous waste generation that offset any environmental gains 

from reducing VOM emissions. See, e.g., Alumax, AS 92-13, Slip. Op. at 7 (Board granted 

adjusted standard where control technologies created offsetting emissions ofNOx and VOM); In 

the Matter of Joint Petition of Quantum Chemical Corporation, US! Division (and the Illinois 

Environmental Protection Agency) for an Adjusted Standard from Parts of35 Ill. Adm. Code 

218.966 and 218.986, AS 92-14, Slip. Op. at 9 (Board granted adjusted standard where use of 

control teclmology would emit NOx which, like VOM, contributes to ozone fonnation, that 

-----~would-partially-offsetihe-benefits-ofVE>MTeductiun)-. - - ··- -- -------- _,_ --- --- ··----- .- -

2. Cross-Media Environmental Impacts Resulting from an Adjusted 

Standard. 

None. Greif's waste and wastewater generation is independent ofVOM emissions from 

the QC Test Process; therefore, no change in the nature or volume of waste and wastewater is 

Wlticipatcd. 

H. Justification- Section I 04.406(h) 

Where, as here, the regulation of general applicability does not specify a level of 

justification required for a petitioner to qualify for an adjusted standard, Section 28.1(c) of the 

Illinois Environmental Protection Act, 415 JLCS 5/28.1 (c), authorizes the Board to grant an 

adjusted standard upon adequate proof of the following: (1) the factors relating to the petitioner 

are substantially and significantly different from the factors relied upon by the Board in adopting 

the general regulation applicable to the petitioner; (2) the existence of those factors justifies an 

adjusted standard; (3) the requested standard will not result in environmental or health effects 

substantially and significantly more adverse than the effects considered by the Board in adopting 

the rule of general applicability; and (4) the adjusted standard is consistent with applicable 

federal law. 

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1. Factors Relating to Greif are Substantiallv and Significantly Different. 

The factors relating to Greif's ability to reduce YOM emissions are substantially and 

significantly different from any the Board may have relied on in adopting Subpart TT. First, the 

Board did not rely on any specific industry factors in adopting Subpart TT and, therefore, the 

factors associated with Greif's operations are necessarily "substantially and significantly" 

different. Second, Grief's ability to manage YOM emissions by diluting its QC test fluid is 

substantially and significantly different from factors the Board may have relied on in deciding to 

------require-capture-and-controlnrethudS"fonmmaging-VOM-emissions. Third, even lfGreif"cotilo 

not manage YOM emissions by dilution of the QC test fluid, the physical design of Greif's 

operations and the slow-evaporation of its QC test fluid are unique factors impacting and 

significantly limiting Greif's ability to capture and control YOM emissions through add-on 

controls. Fourth, the costs to achieve the 81 percent capture and control requirement of Section 

218.986(a) would exceed the threshold cost level the Board previously has found to be 

economically reasonable. 

a. The Board Did Not Consider Factors Involving the Drum 

Manufacturing Business in Adopting Subpart TT. 

Subpart TT of Part 218 is essentially a "catch-all" applicable to YOM sources that are not 

governed by other subparts of Part 218. In adopting Subpart TT, the Board did not consider 

factors relating to any specific industty or practice- including the fiber drum manufacturing 

business. Rather, the purpose of Subpart TT was to cover sources that had not otherwise been 

specifically considered. See 35lll. Adm. Code§ 218.980(a) and (b). The Board previously has 

reasoned that, because it did not consider any specific factors in adopting Subpart TT, virtually 

any factors specific to an industry or specific source not otherwise addressed in Part 218 would 

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*****AS 2011-001 * * * * * 

be "substantially and significantly different." See Ford Motor Company (2000), AS 00-6, Slip. 

Op. at5. 

In Ford Motor Company, the Board considered an adjusted standard petition in which 

Ford sought an altemative emissions control plan to address solvent cleanup operations at its 

Chicago assembly plant. Jd. Slip Op. at I. The Board stated that Subpart TT applies to YOM 

sources with certain characteristics that are not govemed by other subparts of Part 218 and, in 

adopting Subpart TT, the Board did not consider factors relating to any specific industry or 

operations were not considered in adopting Section 218.986(a), the requirement to demonstrate 

significantly different factors "is therefore met." I d. 

b. Grcifs Ability to Manage YOM Emissions Through Dilution 

of its QC Test Fluid Constitute Substantially and Significantly 

Different Factors. 

Even if the Board had considered factors impacting the capture and control of YOM 

emissions at drum manufacturers when it promulgated Section 218.986(a), it did not consider 

Greifs tmique QC Test Process, the particular complexity of constructing capture equipment 

over an extended conveyor line or the ability to manage YOM emissions by minting the QC test 

fluid with water. Construction of effective capture equipment is further complicated by the need 

to maintain physical access to the drums for visual inspection. This means the conveyor line 

cannot be totally enclosed to maximize capture. These factors are substantially and significantly 

different from emission units where material substitution is not possible and the construction and 

operation of emission capture equipment is less extensive. 

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c. Greifs QC Test Process is Substantially and Significantly 

Different from Other Manufacturing Activities Considered by 

the Board. 

In addition, even assuming, arguendo, that capture and control could be an economically 

reasonable option, Greif's specific system would be complicated by the physical location of 

different production activities within the Naperville plant, the slow evaporation of the testing 

fluid and the need for Greif to inspect drums visually after the QC test fluid has been sprayed 

into the drum. The testing fluid begins to evaporate while being sprayed in the QC spray station. 

---------'Evapuration--continues-while-~being convcyooto-a.no awmtingQCinspection ana iilso- --

as the drums arc conveyed from the inspection area to the drum paint oven and, possibly, even 

afterward. Because the lined drums must be accessible for visual inspection by plant staff, 

complete enclosure of the drum conveyor line is not possible. These factors would require large 

capture systems, including a hood at the QC spray station, at the opening of the drum paint oven 

and along the conveyor used to transport the drums from the spray station to the inspection area 

and from the inspection area to the drum oven. See RACT Study at Section 1.0. The need to 

construct and operate a capture system this complex and this large likely was not considered by 

the Board in adopting Subpart TT and will significantly impact Greif's costs to control YOM 

emissions. See infra at Section II(H)(2). 

d. Costs of Achieving RACT Control Standard Exceed those 

Considered bv Board in Setting RACT Standard. 

ln addition, as reflected in the RACT Study, feasible technologies to achieve the 81 

percent combined capture and control objective of Section 218.986(a) would require costs per 

ton of annual YOM removed ranging from $11,667 to $17,672. These costs exceed the threshold 

cost level the Board previously has found to be economically unreasonable. See In the Matter 

of Petition of Forme! Industries, Inc. for an Adjusted Standard from 35 Ill. Adm. Code. 

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. *****AS 2011-001 * * * * * 

218.40l(a), (b) and (c), AS 00-13, Slip. Op. at 9 (January 18, 2001) (Board granted adjusted 

standard and the Agency agreed that costs of$1 0,911 - $18,041 per ton ofVOM reduced were 

economically unreasonable); Ford Motor Company (2000), Slip. Op. at 5 (citing In re: Petition 

of Louis Berkman, AS 97-5 (Dec. 4, 1997) ajj'dsub nom EPA v. PCB, 308 Ill. App. 3d 741, 746 

& 752-53,721 N.E.2d 723, 726-27 & 731 (2d Dist. 1999) (for proposition that costs exceeding 

$1,734 in 1996 dollars per ton of reductions was economically unreasonable); In the Matter of 

Joint Petition of Reynolds Metals Company and the Illinois Environmental Protection Agency for 

an71.djusted-8tandardfrom-35-IJJ.e-2t·8;980,"""*8·9J=8-{Sept:-2t;-t995·)·{Board·foum!·$40;000-p-er- ·-

ton ofVOM reduced to be economically unreasonable). 

2. The Existence of These Factors Justifies an Adjusted Standard. 

The intent of the regulations promulgated under 35 lll. Adm. Code Part 218 is to 

implement RACT for VOM emission sources in the Chicago ozone non-attainment area. See In 

the Matter of Petition of Ford Motor Company (Chicago Assembly Plant) for an Adjusted 

Standard from 35 Ill. Adm. Code 218.986, AS 02-3, Slip. Op. at 4 (November 21, 2002). GreiPs 

RACT Study demonstrates that use of the water-diluted test fluid as an adjusted standard reduces 

emissions from the QC Test Process below the applicability threshold for Subpart TT3 and below 

applicable FESOP limits while reducing costs. The existence of these factors demonstrates that 

dilution of the QC test fluid constitutes RACT and justifies the granting of the instant request. 

3. The Requested Standard Will Not Result in Adverse Health Ef&cts. 

The requested adjusted standard will have little, if any, adverse impact on human health 

or the environment. In 2009, state-wide VOM point source emissions were 54,668 tons. See 

'Greif understands that Subpa1t IT is a "once in-always in" rule. 35 Ill. Adm. Code Section 218.980(c). However, 

the fact that the diluted QC test fluid will bring emissions below U1e applicability threshold is of some significance 

because the Board certainly did not consider sources with uncontrolled emissions less than the threshold being 

subject to Subpart TI. 

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Illinois Annual Air Report at Table C-5. Thus, even at the maximum permitted emission levels 

for the Naperville plant (22.8 tpy based on condition 3 of the FESOP), YOM emissions from the 

QC Test Process would amount to less than 0.04% of state-wide point source emissions and only 

0.19% of Metropolitan Chicago emissions. The Board has previously found that adjusted 

standards from Subpart TT from sources with much higher YOM emission levels would have no 

significant impact on air quality. See, e.g., Alumax, AS 92-13, Slip. Op. at 9; Ford Motor 

Company (2000), AS 00-6, Slip. Op. at 5. 

- -'f-he Hoard-has-granted-numerons-exempti"ons·to-thc-8'1---percent·capture--a:rrd·control· 

requirement in Subprut TT in cases where the annual YOM emissions that were exempted from 

Section 218.986(a) were significantly greater than those proposed by Greif. See, e.g., Ford 

Motor Co. (2000), AS 00-6, Slip. Op. at 3 (even with uncontrolled emissions of390 tpy of 

YOM, the Board found no significant impact on air quality or human health); Quantum 

Chemical Corporation, AS 92-14, Slip. Op. at 10 (Board agreed that operation of emission units 

resulting in over 260 tpy of YOM was small compared to the total YOM emissions in the 

Chicago ozone non-attainment area and would have no measurable impact on air quality); 

Alumax, AS 92-13, Slip. Op. at 9 (Board found the foregone emission reductions of76 tpy from 

not achieving 81 percent control would not significantly impact human health). 

Moreover, the Board previously has found that a control plru1 resulting in an overall 

emissions reduction constitutes a positive environmental impact. See Ford Motor Company 

(2002), AS 02-3, Slip. Op. at 4. In Ford, the Board found that a 50 tpy reduction of YOM 

emissions (from 390 tpy to 340 tpy- or 13%) was "significant" and would have a "positive 

impact on air quality." I d. Here, dilution of the QC test fluid is producing a 55% reduction of 

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* * * * * AS 20 11-00 1 * * * * * 

VOM emissions- an even greater reduction on a percentage basis than what was at issue in the 

Ford petition. 

4. The Requested Standard IS Consistent with Federal Law. 

Section 110 of the federal Clean Air Act, 42 U.S.C. § 7410, grants individual states the 

authority to promulgate a plan for implementation, maintenance and enforcement of air quality 

standards, subject to approval by EPA. Based on the RACT Study, the proposed adjusted 

standard constitutes RACT for the Greif facility, and is therefore consistent with the federal 

- --· ----Giean-AirAct. A-state-may revise its SIP;-agairrsubjectto EPA«pproval:· '42-tJ;S:e: § 74to:- · -

Greif will work with the Agency to submit a SIP revision to EPA that is consistent with any 

adjusted standard granted by the Board. 

J. Hearing- Section 104.406(j) 

Greif requests a hearing in this matter. 

K. Supporting Documentation- Section 1 04.406(k) 

1. RACT Study, attached to this Petition as Exhibit A. 

2. FOIA Response from nlinois Environmental Protection Agency, Bureau 

of Air, attached to this Petition as Exhibit B. 

lll. CONCLUSION 

Greif requests that the Board grant the proposed adjusted standard as an alternative to the 

RACT regulations adopted by the Board in Subpart TT. To require Greif to comply with the 

requirements of35 TIL Adm. Code Subpart TT, Section 218.986(a), would result in substantial 

economic hardship to Greif with no corresponding environmental benefit. Certain compliance 

options examined by Greif could have the reverse effect of creating increased emissions of other 

pollutants and environmental detriment. Finally, add-on controls are unreasonably expensive, 

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*****AS 2011-001 * * * * * 

provide little, if any, environmental benefit and certain control options may result in increased 

health and safety risks. 

WHEREFORE, Greif, Inc. requests that the Board grant Greif the proposed adjusted 

standard from 35 Ill. Adm. Code, Subpart TI, Section 2I 8.986(a), as that rule applies to the 

emissions ofVOM from Greif Packaging LLC's operations in Naperville, Jllinois . 

. ··-- Respectfull:y-submitted, 

GREIF, JNC. AND 

GREIF PACKAGING LLC 

By: Is/ Susan Charles 

Thomas W. Dimond 

Susan Charles 

ICE MTI-T.ER LT.P 

200 West Madison Street 

Chicago, Illinois 60606 

312-726-1567 

January 24, 2011 

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*****AS2011-001 ***** 

REASONABLY AVAILABLE 

CONTROL TECHNOLOGY ··--· ·-·------ -- ---·-· -------------. STUDY 

August 2010 

Prepared for: Prepared by: 

G~IF TCP 

Naperville, IL Itasca, IL 

Exhibit A 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * *AS 2011-001 * * * * * 

REASONABLY AVAILABLE CONTROL TECHNOLOGY 

STUDY 

Prepared for: 

GREIF 

58220 Frontenac Road 

Naperville, IL 60653 

Prepared by: 

TCP 

Thomas C. Ponder, Jr. PE 

Consulting Engineer 

56 Bay Drive 

Itasca, Illinois 60143 

TCP Project No. 8003 

August2010 

\. 
Electronic Filing - Received, Clerk's Office, January 24, 2011 , 

* * * * * AS 2011-001 '* * * * * 

Reasonably Available Control Technology Study 

Augus/2010 

1.0 

2.0 

3.0 

4,0 

Table of Contents 

Page 

Summary "' ,., ,. -····--., ,., .. , ... '"" ""' ... "" ........... """" .................... --· ................ 1-1 

Facility information ............. --., ................ """''"""''""""''""'''""'"''"'""""' 2-1 

Control Technologies ............................................. -- ................. --................. 3-1 

3.1 Capture Systems ............................................. __ ............................... 3-1 

3.2 Add-on Control Technologies ....................................................... -- ... 3-1 

3.2.1 Recuperative Thermal Incinerators ....................................................... 3-1 

3.2.2 Carbon Adsorbers ................................................................................... 3-1 

3.2.3 Biojilter .................................................................................................... 3-2 

3::J- ·potentialEquivaleiiO\IterriativeConfrol Plaris .. :.~::-:: . .-:~:.~.--:-: ........ : ...... 3-2 

3.3.1 QC Test Fluid -Dilution with Water ..................................................... 3-2 

3.3.2 QC Test Fluid-Dilution with Acetoue .................................................. 3-3 

Control costs ................................................. __ ............................................. 4-4 

4.1 Capital Costs .... ----................. """""'""""""'"'""'""'""'"""''"""'"' 4-4 

4.2 Annual Costs ...................................... -- ............................................. 4-4 

4.3 Reasonably Available Control Technology Costs ............................. 4-5 

4.4 Comparing RACT to the Naperville Control Systems ..................... --. 4-5 

APPENDIX A 

APPENDIX B 

CAPITAL AND ANNUAL COSTS FOR THERMAL 

OXIDIZER WITH RECUPERATIVE HEAT EXCHANGER 

CAPITAL AND ANNUAL COSTS FOR CARBON 

ADSORBER 

TCP ProjecL No, 8003 11 
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Reasonably Availnble Control Technology Study 

August2010 

LIST OF TABLES 

Page 

Table 1-1 Costs of VOM Control ($/ton) 1-3 

Table 4-1 Control Cost Comparisons Naperville RACT Study 4-3 

TCP p,~jecl No. 8003 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* ****AS 2011-001 * * * * * 

Reasonably Available Control Technology Study 

August 20 I 0 

1.0 SUMMARY 

This study was undertaken to evaluate the reasonably available control technologies 

(RACT) options that could be implemented at the quality control (QC) testing process 

emission unit of the Greiflndustrial Packaging & Services, LLC (Greif) fiber container 

facility in Naperville, Il1inois. The options are being considered to determine if the 81% 

combined capture and control requirement of 3 5 lAC 218.986 is technical! y achievable 

and economically reasonable for the QC testing process emission unit and, if not, to 

identify equivalent alternative control plans that would constitute RACT for this emission 

unit. 

Section 218.986 requires emission units subject to its requirements to achieve an overall 

reductio-n in -Uncontroiled VOM emis;on-soTat-l~ast sip~~centtht="o~gb th~~ppiication 

of emission capture and control equipment. Capture technology would involve a 

combination of permanent total enclosures and exhaust hoods designed to achieve at least 

90 percent capture ofVOM at the QC testing process. The following control equipment 

options were evaluated for potential implementation in connection with 90 percent 

capture methodology: 

• Recuperative thermal incinerator 

• Carbon adsorber 

• Biofilter 

In addition, the following methods of VOM emission reduction were evaluated as 

possible equivalent alternative control plans: 

• Dilution of the QC testing process fluid (a mixture of solvents, primarily 

denatured alcohol) with water 

• Dilution of the QC testing process fluid with acetone (a non-VOM material) 

The recuperative thermal incinerator, biofilter, carbon adsorption, and QC testing fluid 

dilution options were completely evaluated. Dilution of the testing fluid with acetone 

was determined to be technically infeasible. Acetone, does not work at Naperville since 

it causes the gasket material which seals the bottom of the drum to the drum walls to 

dissolve. Due to this problem with product damage, diluting the QC test fluid with 

acetone was determined to be infeasible. 

Capture of emissions from the QC test process is complicated by slowly evaporating 

solvents in the testing fluid and the need for employees to inspect each drum visually 

after the QC test fluid has been sprayed into the drum. Currently the drums are sprayed 

TCP r.ujoct No. 8003 J.J 
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* * * * *AS 2011-001 * * * * * 

Reasonably Available Control Technology Study 

August2010 

and inspected at the QC test station. Then the drums arc conveyed approximately 160 feet 

to the drum paint oven to insure that the test fluid completely evaporates. So, the QC test 

process requires capture of emissions at the QC test station, itself, the conveyors, and the 

drum paint oven. This is a very complicated capture system that requires tunnel 

enclosures around the conveyors. The QC test process station must be enclosed and the 

opening to drum paint oven must be reduced to ensure 90 percent capture of the 

emissions. The control system requires both enclosures of the process and dueling to the 

control device. Unifonn capture is difficult when system components include a spray 

station, tunnel hoods, and an oven. 

Because of the difficulties with the capture system, the air flow rate to the control device 

will ne.cessarily be.high .. This creates the.need for larger control-systems,-which-impacts 

costs. As reflected in Table 1-1, the costs of YOM control stated in tenns of dollars per 

ton of annual YOM reduction range from $11,167 to $17,672. This range of control costs 

is significantly higher than the level of costs considered to be economic in adopting 

RACT controls, about $2,250 per ton in 2008 dollars. 

Table 1·1 Costs ofVOM Control ($/ton) 

Control Option Cost of VOM Control ($/ton) 

Recuperative Thermal Oxidizer (20,000 acfm) 17,672 

Carbon Adsorber (20,000 acfm) 11,667 

Biofilter (20,000 acfm) & Water Diluted Solvent 11 '167 

Water Diluted solvent -679 

In addition, all control systems for the reduction of YOM emissions have inherent 

characteristics that would partially offset the environmental benefits of YOM reduction. 

Thennal oxidizers use large quantities of natural gas. Fuel will be.used even when the QC 

test process is not operating to maintain the thennal oxidizer at temperature. Frequent 

operation cycles in thetmal oxidizers cause condensation corrosion and thermal 

deterioration of the insulation. Thennal oxidi7.ers emit NOx and CO and small quantities 

of YOM and HAPS are also emi~ted. These emissions will partially offset any benefits 

obtained from YOM reduction. Carbon adsorbers also have drawbacks. Since all of the 

solvents used in the QC test process are water soluble, the used solvents can not be 

TCP Project No. 8003 1-2 
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Reasonably Available Control Technology Study 

August2010 

recovered from the carbon adsorbers without an elaborate distillation system. Given these 

difficulties, the condensed regeneration fluid is commonly discharged with wastewater to 

the sewers. Depending on the type of treatment system at the municipal b·eatment facility, 

the YOM may not be biodegraded but simply blown into the atmosphere in an 

equalization basin. In that case, YOM emission reductions at the facility will be offset by 

higher emissions at the treatment facility. Biofilters must be heated to maintain 

destruction activity during winter months. Heat for the biofilter can be supplied by the 

direct combustion of natural gas, steam, or electricity. Natural gas combustion would 

increase NOx emissions from the facility. In addition, the large size of these units may 

limit feasible locations at a facility. Also, the biofilter cannot achieve the 81% control 

objective by itself and would require au additional control system or the counting of the . --·--- --- . QC tesf fluid dilution as a control iechnologyto achieve that objective. 

In contrast, diluting the QC test fluid with water has been calculated to reduce annual 

emissions ofYOM below the 25 tons per year (tpy) threshold for applicability of Section 

218.986 at a reduced cost from pre-dilution operations. Based on this analysis, 

conversion to the diluted QC test fluid achieves RACT control for this emission unit and 

should be approvable as an equivalent alternative control plan in place ofthe 81% capture 

and control requirement of Section 218.986. 

TCP Project No. 8003 ].3 
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* * * * * AS 2011-001 * * * * * 

Reasonably Available Control Technology Study 

Augus/2010 

2.0 FACILITY INFORMATION 

Greif operates a fiber container manufacturing facility in Naperville, Illinois. The primary 

activity involves the cutting of fiber material into appropriate lengths, molding the shapes 

into a drum and connecting tops and bottoms to the dnun sides. VOM emissions are minimal 

in the actual drum making operation. Emissions occur during the application of caulk, silk 

screening of infonnation onto the drum, and in drum painting .. Combined VOM emissions 

from all these units are currently permitted at a maximum of 1.4 tpy, and Greif has proposed 

increasing the emissions from those units to an aggregate of2.6 tpy. Under 35 IAC 

218.980(d), these units are exempt from the requirements of Section 218.986 because no 

------Single unit-emits-greater-than-2.5 tpy ofVOMs-and-the-aggregate·cmissions from-the other· 

units does not exceed 5 tpy. 

Some of the fiber drums manufactured at Naperville are required by customers to have 

polyethylene liners, primarily to comply with requirements for food grade containers. Drums 

with these liners must be tested to ensure that the liner is free from pinholes or other tears or 

imperfections. The QC Test Process emission unit involves the spraying of a VOMcontaining liquid onto the polyethylene liner, which causes imperfections in the liner to 

become visible to the naked eye and detectable to plant personnel who inspect each of the 

lined dnuns as it proceeds through the process on a conveyor belt. At the Naperville plant, 

only the QC Test Process emission unit emits significant quantities ofVOM emissions. 

Emissions from the QC Test Process are currently permitted at 22.8 tpy, and Greif has 

proposed to reduce those emissions to a maximum of21 tpy. Accordingly, this study only 

assesses RACT options for the QC Test Process emission unit. 

TCP Project No. 8003 2-1 
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Reasonably Available Control Technology Study 

August2010 

3.0 CONTROL TECHNOLOGIES 

Brief descriptions of the capture and control systems evaluated for this study are given in the 

following sections. 

3.1 Capture Systems 

Due to the slow evaporation rate of the QC test fluid, the need to achieve adequate emission 

capture to achieve overall 8.1% control adds to the YOM control costs. A total tunnel enclosure 

will be required for the conveyor from the QC test process spray station to the drum paint oven. 

Enclosures will be added to the hood at the QC test process spray station and the opening of the 

drum paint oven to ensure adequate capture will be achieved. Dueling to the control device will 

be required from the QC test process hood, the conveyor tunnel enclosure and the drum paint 

oven .. T~~~co~plicated system is hard !o balance so tllll!..~equate capture is acl!!eved. The 

capital and annual operating costs for the dueling and enclosure systems are included with each 

contro 1 system. 

3.2 Add-on Control Technologies 

Recuperative thermal oxidizers, carbon adsorbers, and biofilters were the control systems 

evaluated. 

3.2.1 Recuperative Thermal Incinerators 

Recuperative thermal incinerators use a heat exchanger to capture the exhaust heat and transfer 

the heat to incoming gases. Less natural gas is needed to boost the combustion temperatures to 

1600°F to ensure complete destruction of the YO Ms. This system has heat recovery as great as 

60%. The primary advantages of this control system are lower annual costs relative to other 

incinerators and flexibility in handling a range of YOM materials. The primary disadvantages of 

this control system relative to other control options are higher operating costs due to the amount 

of natural gas that is consumed and the resulting increase in emissions ofNOx. 

3.2.2 Carbon Adsorbers 

Carbon adsorbers are used to control systems with low to medium YOM concentrations. 

Normally, a carbon adsorber consists of tv{o or more beds of activated carbon. One bed is 

treating the exhaust emissions while the other bed is being regenerated. Large systems may have 

several beds on stream while a bed is being regenerated. Carbon adsorbers work best with 

insoluble YOMs, which simplify the recovery of the YOM materials. In some cases, distillation 

is required to separate the VOM materials from the regeneration steam. Since all the YOM used 

in the QC testing process is water soluble, it would be very expensive to recover the denatured 

alcohol from the regeneration fluid. The waste steam would most likely be sent to a local 

sewage district along with wastewaters since most sewer districts will allow facilities to 

discharge water soluble solvents that are not chlorinated. However, most sewer districts use 

TCP Project No. 8003 3-1 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

Reasonably Available Control Technology Study 

August 2010 

equalization basins to reduce YOM (BOD) loading by blowing solvents into the atmosphere. 

Therefore, YOM emissions may not truly be reduced with carbon beds but only the emission 

source changed. Due to the presence of ketones in the denatured alcohol, there is also an 

inherent risk of fires from reactions between the ketones and the carbon in the beds. Carbon beds 

that handle ketones require water deluge systems to control bed fires. 

3.2.3 Biofilter 

Biofilters can be used to reduce YOM emissions without the use of natural gas to bum the 

hydrocarbons. Biorem has proposed to install a biofilter for odor control on the Greif drum plant 

in Oakville, Ontario. In this process, YOM is reduced by 70 percent by the biofilter media. 

Biorem would achieve 95% control by adding a carbon adsorber after the biofilter media. At 

Naperville, the 81% control objective could be met only by combining the biofilter with another 

· -cotili:cil techiiolo·gy or by eonsi3enng tlie reouclions-in VOM emissions Irom tne· use ofthe water 

diluted test fluid as a capture and control technology reduction. Tills system has lower operating 

costs although the capital costs are comparable to incinerators. Biofilters must be heated to 

maintain destruction activity during winter months. Heat for the biofilter can be supplied by the 

direct combustion of natural gas, steam, or electricity. Natural gas combustion would increase 

NOx emissions from the facility. 

3.3 Potential Equivalent Alternative Control Plans 

3.3.1 QC Test Fluid- Dilution with Water 

Naperville experimented with changing the QC testing process fluid from 100% denatured 

alcohol to a mix1t1re of denatured alcohol and water. The goal of the experiment was to reduce 

the proportion of denatured alcohol to the greatest extent possible, which would achieve 

corresponding reductions in YOM emissions, while maintaining the ability to visually detect 

imperfections in the drum linings. 

The experiment was conducted in the following general manner. Using a sharp point awl, 

pinholes would be made in the side and bottom of liners of five drums prior to sending them 

through the QC Test Process. The drums would then be sprayed in the QC Test Process and 

visually inspected on the conveyor system to determine if the pinholes could be detected in an 

acceptable time period. Under normal operations, it takes a drum about 70 seconds to move on a 

conveyor system from the QC Test Process spray system to the location where the drums are 

inspected. If the pinholes could be detected, the test was considered successful and the fluid 

used for the test considered acceptable. If the pinholes could not be detected, the test was 

considered a failure and unable to meet the product quality assurance standards required by 

Greif's customers. 

The first alternative test fluid consisted of 80% denatured alcohol and 20% water. At this 

mixture, plant personnel were able to detect the pinholes in all five test drums within about 5 

TCP Project No. 8003 3-2 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

Reasonably Available Control Technology Study 

August20/0 

seconds. The experiment was repeated with a test fluid consisting of 70% denatured alcohol and 

30% water. As with the first test fluid, this second mixture allowed the detection of all pinholes 

in the five test drums, although they were only detectable after 7 seconds and the staining around 

the holes was noticeably lighter than with the 80/20 mixture. Similar tests were conducted with 

mixtures of 50% denatured alcohol/50% water, then 40% denatured alcohol/60% water and 

finally 45% denatured alcohol/55% water. With the 50/50 mixture, all pinholes were detected 

within 45 seconds, although the staining was much lighter than with mixtures containing more 

alcohol. TI1e test using the 40/60 mixture failed. All of the pinholes were not visible when the 

drums reached the inspector station. Continued observation of these drums from the inspector 

station to the drying oven revealed that the pinholes did not even become visible by the time the 

drum reached the drying oven. The test using the 45/55 mixture allowed the detection of all 

pinholes within 60 seconds after spraying, although as noted above the staining around the 

--- pinholes was-signific-antly lighte; than with mixru;.~s containing ~ore ;J-;;-oi;oi. Based-on fuese. 

test runs, the plant determined that 55% dilution with water was the highest dilution percentage 

that would still allow the plant to meet its product quality assurance requirements. To date, the 

diluted test fluid has been able to allow the detection of drums with defects in the polyethylene 

liner. This diluted test fluid is less expensive than the previously used test fluid consisting of 

100% denatured alcohol. 

3.3.2 QC Test Fluid- Dilution with Acetone 

Another option to achieve reduction in YOM emissions would be to dilute the current QC test 

fluid with acetone or switch to acetone as an entire substitute because acetone is a non-YOM 

solvent. Tests by facility personnel determined that acetone, even when diluted, may dissolve 

the gasket that binds the bottom of the fiber drum to the walls of the drum. For that reason, this 

alternative was deemed by the facility to be infeasible for full implementation. 

TCP Projed No. 8003 3-3 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * * AS 2011-001 * * * * * 

Reasonably Available Control Technology Study 

August 2010 

4.0 CONTROL COSTS 

The capital and annual costs for different control options arc shown in Table 4-1. Capture 

(dueling and enclosures) costs are included in the capital and operating costs of each of the three 

control systems evaluated. The complete cost analysis of the recuperative thennal oxidizer 

control system is shown in Appendix A. The complete cost analysis of the carbon adsorbcr 

control system is shown in Appendix B. The cost for the biofilter was scaled to the projected 

biofilter size for the Naperville facility based on the bid received for the installation at the 

Oakville, Ontario facility. In addition, the cost analysis for the biofilter option assumes the 

diluted QC test fluid can be h·eated as a control technology because adding a carbon adsorber 

would dramatically increase the cost per ton of YOM controlled. 

___ ···-··- ___ 4.L __ CapitaLC.osts. ___ .. __ 

The procedures for estimating capital costs for pollution capture and control equipment generally 

follow the procedures developed by the United States Environmental Protection Agency (EPA). 

Specifically for this study, the information used to develop the capital costs were derived from 

"Estimating Costs of Air Pollution Control" by William Vatavuk. Using algorithms in the book, 

costs for the capture and control equipment were determined. After determining equipment 

costs, costs for auxiliary equipment such as fans, ductwork, and a stack were calculated. It was 

assumed that the control equipment would be too heavy to mount on the roof, so the control 

systems would be located on the ground near the QC testing process. Once the costs of the 

capture and control equipment and auxiliary equipment were determined, they were used to 

develop direct installation costs for such things as foundations, electrical work, erection, 

insulation, painting, and support facilities. Indirect costs such as engineering, construction 

management, contractor fees, and testing were added to the direct installation costs. 

Contingency costs were added to total installation costs in order to determine the total project 

cost for each control option. 

4.2 Annual Costs 

Annual costs also follow the EPA guidelines. · Items for direct operation of the capture and 

control equipment such as electricity, natural gas, operating labor, and maintenance are 

determined based on the capture and control equipment requirements. Indirect costs such as 

plant overhead, taxes, and insurance are added to the costs. Capital recovery is a method for 

recovering the cost of money used to finance the project and determining the depreciation of the 

equipment. Although there are other methods for determining these costs, capital recovery is 

used by EPA in RACT analysis in determining the cost per ton of pollutants controlled. 

Annual costs for diluted QC testing fluids are based on a $3.16/gallon cost for the 55% diluted 

testing fluid versus $4.84/gallon for the undiluted denatured alcohol. A cost savings occurs since 

the water-reduced solvent is lower cost than the all solvent test fluid. 

TCP Projecl No. 8003 4-4 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * *AS 2011-001 * * * * * 

Reasonably Available Control Technology Study 

August 2010 

4.3 Reasonably Available Control Technology Costs 

Section 218.986 requires emission units subject to its requirements to achieve an overall 

reduction in uncontrolled YOM emissions of at least 81 percent through the application of 

emission capture and control equipment. In adopting that requirement, the Illinois Pollution 

Control Board considered a level of cost per ton of estimated YOM reductions that would 

typically be incurred to achieve the 81% standard. In 1996 dollars, the Board's RACT cost 

threshold was a maximum of $1,734 per ton of YOM controlled. In re: Petition of Louis 

Berkman, AS 97-5 (Dec. 4, 1997) affd sub. nom. EPA v. PCB, 308 Ill. App. 3d 741, 746 & 752-

53 (2d Dist. 1999). Escalating that threshold to 2008 dollars, the RACT cost would be 

approximately $2,249 per tom of YOM controlled. 

4.4 Comparing RACT to the Naperville Control Systems 

----·- ------;~; review ·onlie costs· in Ta5lc<r:r-iooicatcs thataJloftne actd~-on controf systems-and their 

associated capture system upgrades cost much more than the RACT threshold of $2,249 per ton 

of YOM controlled. Control costs range from $11,667 to $17,672 per ton of YOM controlled. 

In addition, all control systems for the reduction of YOM emissions have inherent characteristics 

that would partially offset the environmental benefits of YOM reduction. Thermal oxidizers use 

large quantities of natural gas. Fuel will be used even when the QC test process is not operating 

to maintain the thermal oxidizer at temperature. Frequent operation cycles in thermal oxidizers 

cause condensation corrosion and the1mal deterioration of the insulation. Thermal oxidizers emit 

NOx and CO and small quantities of YOM and HAPS are also emitted. These emissions will 

partially offset any benefits obtained from YOM reduction. Carbon adsorbers also have 

drawbacks. Since all of the solvents used in the QC test process are water soluble, the used 

solvents can not be recovered from the carbon adsorbers without an elaborate distillation system. 

Given these difficulties, the condensed regeneration fluid is commonly discharged with 

wastewater to the sewers. Depending on the type of treatment system at tbe municipal treatment 

facility, the YOM may not be biodegraded but simply blown into the atmosphere in an 

equalization basin. In that case, YOM emission reductions at the facility will be offset by higher 

emissions at the treatment facility. Biofilters must be heated to maintain destruction activity 

during winter months. Heat for the biofilter can be supplied by the direct combustion of natural 

gas, indirect steam heat, or electric heaters. Natural gas combustion would increase NOx 

emissions from the facility. In addition, the large size of these lmits may limit feasible locations 

at a facility. Also, the biofilter cannot achieve the 81% control objective by itself and would 

require an additional control system or the counting of the QC test fluid dilution as a control 

technology to achieve that objective. 

In contrast, diluting the QC test fluid with water has been calculated to reduce armual emissions 

of YOM below tbe 25 tons per year (tpy) threshold for applicability of Section 218.986 at a 

reduced cost from pre-dilution operations. Based on this analysis, conversion to the diluted QC 

TCP Projecl No. 8003 4-5 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * * AS 2011-001 * * * * * 

Reasonably Available Comrol Technology Study 

August2010 

test fluid achieves RACT control for this emission unit and should be approvable as an 

equivalent alternative control plan in place of the 81% capture and control requirement of 

Section 218.986. 

TCP Projoct No. 3003 4-6 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * i 

Reasonably Available Control Technology Study 

August 2010 

I 

Table 4-1 Control Cost Comparisons- Naperville RA~T Study 

Control Options Controlled Uncontrolled U?, 9!1!~~~ed Controlled' Con0>11!id Tolal Total 

acfm VOMib/yr · 

VQ~;Jo'!;Y 'iO'Mibiyr VOMTPY caPital Capital .~· .,... . CoSt$ Cost, 

. ',. ~-' ···. I. $/acfm 

' Projected Emissions with undiluted --- 89,840 44.92 0 0 0 0 

QC Test Fluid ' 

QC Test Fluid Diluted with Water -- 89,840 44.92 49,412 24.71 I 0 0 

I 

Recuperative Thermal Oxidizer 20,000 89,840 44.92 72,770 36.39 ds2,ooo 87.60 

! 

Carbon Adsorber 20,000 89,840 44.92 72,770 36.39 ' 1yo.ooo 58.50 

Biofilter & Diluted QC Test Fluid 20,000 89,840 44.92 74,880 37.44 1,BOO.OOO 90.00 

I 

TCP Project No. 8003 4-7 

To~l Cost p~jq~ o.n c 

Annual VOM ., .. , .•. 

Cost.$ qpn~ll~.$ -

--·· 

-- --

-17,000 -679 

679,000 17,672 

458,000 12,594 

437,000 11,667 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS 2011-001 * * * * * 

ReilSonably Available Conlro/Technology Study 

Augus/20/0 

Appendix A 

Capital and Annual Costs for Thermal oxidizers with 

Recuperative Heat Exchangers 

TCP Project No. 8003 I 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* ****AS 2011-001 * * * * * 

Recuperative Incinerator Costs - 20000 acfm 

(All costs are in, or have been adjusted to, 1212009do/lars) 

-Base Date: 

--Analysis Date: 

-- Escalation Factor: 

COST INDEXES 

370.3 (September, 1988) 

618.4 (December, 2009) 

1.670 (Analysis/Base) 

(CE Plant Index/Equipment] 

ICE Plant Index/Equipment] 

(calculated] 

GAS STREAM and EMISSION PARAMETERS 

- Inlet stream flowrate (acfm): 20,000 Estimated 

- Inlet stream temperature (oF): 70 Greif Permit 

11 J 

· ---=-stan·dard·teiTTp1!ratare-(oF):·------ -- · 

-- Uncontrolled Emissions, lb/yr 

60-(En"glm>ertrrg"JuTigmmnr --- - - ---·--

89,840 Calculated from emission inventory 

--Controlled emissions: lb/yr (81%) 17069.6 (calculated] 

RECUPERATIVE tNCINERA TOR COSTS 

If fiow is < 5000 scfm, then use: 

Heat Exchanger Efficiency= 70%, a= 5,690, b = 0.408, P = Price, Q = flow rate 

Then P($) = aO'b 

NOTE: THIS EQUATION FOR 70% WAS USED FOR ALL FLOWS. 

--Recuperative Incinerator: $ 323,543 

TOTAL CAPITAL INVESTMENT 

--Recuperative Incinerator. 

-Fan: 

- Enclosure: 

-- Ductwork: 

- Instrumentation: 

$ 323,543 (Estimating Costs of Air Pollution Control-calculated] 

32,354 (Estimating Costs of Air Pollution Control-calculated] 

129,417 (Estimating Costs of Air Pollution Control-calculated] 

64,709 (Estimating Costs of Air Pollution Control-calculated] 

48,532 (Estimating Costs of Air Pollution Control--calculated] 

Subtotal, equipment: $ 598,555 (calculated] 

Purchased Equipment Cost (PEG): $ 706,295 [calculated] 

' " " "-escalated: $ 1,179,511 (calculated] 

Direct installation costs: 

Indirect installation costs: 

Subtotal, installation: 

Retrofit factor: 

TOTAL CAPITAL INVESTMENT($): 

($/acfm): 

$ 294,878 (Estimating Costs of Air Pollution Control--calculated] 

$ 117,951 (Estimating Costs of Air Pollution Control--calculated] 

$ 412,829 (calculated] 

1.1 [Engineeringjudgment] 

$1,751,574 [calculated] 

87.6 [calculated] 

======~~=================~==================;===================================== 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS2011-001 ***** 

Operating factor (hr/yr): 

Operating labor rate ($/hr): 

Supervising Labor factor 

Maintenance labor rate ($/hr): 

Maintenance Materials factor 

Operating labor factor (hr/sh): 

Maintenance labor factor (hr/sh): 

Natural Gas Usage,scfh 

Natural Gas Price, $/MMBtu 

Electricity usage, kWh: 

Electricity price ($/kWhr): 

Annual interest rate (fraction): 

Control system life (years): 

__ c_ap.iiai.L~c.olleJY factP£ ____ .. 

Taxes, insurance, admin. factor: 

Overhead factor: 

Item 

ANNUAL COSTS 

2,000 [calculated] 

28.50 Estimated 

0.15 [EPA Control Cost Manual] 

22.00 Estimated 

1.00 Estimated 

0.50 [EPA Control Cost Manual] 

0.50 [EPA Control Cost Manual] 

440.0 Calculated (based on ratio to flow) 

5. 00 Estimated 

7.00 Calculated (based on ratio to flow) 

0.090 Estimate,d 

0.08 [OMB Guidelines] 

20 [EPA Control Cost Manual] 

. _Q,j_Oj_9_ Lcalcu.La_ted] _ .. __ . _. _ __ . 

0.04 [EPA Control Cost Manual] 

0.06 [EPA Control Cost Manual] 

Cost ($/year) 

--------------------------- ------------------------------------ Operating labor 

Supervisory labor 

Maintenance labor 

Maintenance materials 

Electricity 

Natural Gas 

Overhead 

Tax,ins .. adm 

Cap. recov. 

TOTAL ANNUAL COST: 

Tons of VOC controlled 

Cost per ton of VOC Controlled 

14,250 

2,138 

175,157 

175,157 

1,260 

4,576 

22,002 

70,063 

178,402 

$ 643,005 

36.39 

$17,672 

[calculated] 

" 

" 

.. 

" 

" 

" 

" 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * *AS 2011-001 * * * * * 

Reasonably Available Control Technology Study 

August 2010 

-----···--

Appendix B 

Capital and Annual Costs for Carbon Adsorbers 

TCP Proje<l No. 8003 2 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * * AS 2011-001 * * * * * 

Carbon Adsorbers - Naperville, Ohio - 20000 acfm 

(All costs are in, or have been adjusted to, 12/2009 dollars) 

-- Base Date: 

--Analysis Date: 

--Escalation Factor: 

COST INDEXES 

370.3 (September, 1988) 

618.4 (December, 2009) 

1.670 (Analysis/Base) 

[CE Plant Index/Equipment) 

[CE Plant Index/Equipment) 

[calculated] 

GAS STREAM and EMISSION PARAMETERS 

-Inlet stream flowrate (acfm): 20,000 Estimated 

-Inlet stream temperature (oF): 70 Greif Permit 

- -- ----=-stanaarcrteliiperatUre(6F):· --- --- --- · - --- · -- --oo--[Engineering juagment] 

[1) 

-Uncontrolled Emissions, lb/yr 89,840 Calculated from emission inventory 

--Controlled emissions: lb/yr (81%) 17069.6 [calculated] 

CARBON ADSORBER COSTS 

If the carbon weight is between 350 and 14,000 pounds then use: 

Then P($) = 32.8 (We)"-"" 

The carbon volume at Naperville is 400 113 

If the carbon density Is 28.8 pounds per cubic foot; then the weight of the carbon Is 

400*28.8= 11520 pounds 

where P($) is the equipment price and We is the weight of the carbon. 

-- Carbon Adsorber in stainless steel: $ 204,058 

TOTAL CAPITAL INVESTMENT 

--Carbon Adsorber: 

-- Fan: 

-Enclosure: 

-Ductwork: 

-Instrumentation: 

$ 204,058 [Estimating Costs of Air Pollution Control--calculated] 

20,406 [Estimating Costs of Air Pollution Control-calculated) 

81,623 [Estimating Costs of Air Pollution Control-calculated] 

40,812 [Estimating Costs of Air Pollution Contro~-calculated] 

30,609 [Estimating Costs of Air Pollution Contro~-calculated] 

Subtotal, equipment: $ · 377,507 [calculated] 

Purchased Equipment Cost (PEG): $ 471,883 [calculated] 

' " " "-escalated: $ 788,044 [calculateq) 

Direct installation costs: 

Indirect installation costs: 

Subtotal, installation: 

Retrofit factor: 

$ 197,011 [Estimating Costs of Air Pollution Control--calculated) 

$ 78,804 [Estimating Costs of Air Pollution Control--calculated) 

$ 275,815 [calculated] 

1.1 [Engineering judgment] 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

*****AS2011-001 ***** 

TOTAL CAPITAL INVESTMENT($): 

($/acfm): 

$1,170,245 (calculated] 

58.5 (calculated] 

=~==================~======================================================~===== 

Inputs: 

Operating factor (hr/yr): 

Operating labor rate ($/hr): 

Supervising Labor factor 

Maintenance labor rate ($/hr): 

Maintenance Materials factor 

Operating labor factor (hr/sh): 

Maintenance labor factor (hr/sh): 

Steam Usage, pounds per hour 

Steam E.ti>&,_$/1illl0 pounds 

Electricity usage, kWh: 

Electricity price ($/kWhr): 

Annual interest rate (fraction): 

Control system life (years): 

Capital recovery factor: 

Taxes, insurance, admin. factor: 

Overhead factor: 

Item 

Operating labor 

Supervisory labor 

Maintenance labor 

Maintenance materials 

Electricity 

Steam 

Overhead 

Tax,ins.,adm 

Cap. recov. 

ANNUAL COSTS 

2,000 (calculated] 

28.50 

0.15 [EPA Control Cost Manual] 

22.00 Estimated 

1. 00 Estimated 

0.50 [EPA Control Cost Manual] 

0.50 [EPA Control Cost Manual] 

2000.0 Calculated (based on ratio to flow) 

.. _j2.j)_Q_!:'J>1irnate!L. -·-··. 

17.30 Calculated (based on ratio to flow) 

0. 080 Estimated 

0.06 [OMB Guidelines] 

20 [EPA Control Cost Manual] 

0.1019 [calculated] 

0.04 (EPA Control Cost Manual] 

0.06 (EPA Control Cost Manual] 

Cost ($/year) 

14,250 (calculated] 

2,138 " 

117,025 " 

117,025 " 

2,768 " 

24,000 " 

15,026 " 

46,810 " 

119,192 " 

------------ -----------------. -------- TOTAL ANNUAL COST: $ 458,233 " 

Tons of VOC controlled 36.39 

Cost per ton of VOC Controlled $12,594 
Electronic Filing - Received, Clerk's Office, January 24, 2011 

* * * * *AS 2011-001 * * * * * 

Charles, Susan 

From: BOA, EPA.FOJA [EPA.FOJA.BOA@IIIinois.gov[ 

Sent: Wednesday, September 08, 2010 4:10PM 

To: Charles, Susan 

Subject: RE: FOIA Request- Susan Charles 9/3/2010 3:11:35 PM 

Dear Ms. Charles, 

Page I of! 

Here are the annual facility-reported VOM emissions in tons per year for the Chicago area as requested. 

2004 2005 

17,005 16,622 

· · ··-sincerely,----· 

FOIA Unit 

Bureau of Air 

2006 2007 

15,928 15,691 

Illinois Environmental Protection Agency 

--Original Message2008 2009 

14,119 11,884 

From: Susan Charles [mailto:Susan.Charles@icemiller.com[ 

Sent: Friday, September 03,2010 3:12PM 

To: BOA, EPA.FOIA 

Subject: FOJA Request- Susan Charles 9/3/2010 3:11 :35 PM 

Following Information submitted for FOIA request: 9/3/2010-3942225 

Request for information was routed to: 

Bureau of Air- Unit- 217/524-5683- 217/524-5023(FAX) 

From: Ms. Susan Charles 

Organization: Ice Miller LLP 

Organization Type: Legal Consultant 

Location: 200 W. Madison Street 

Chicago, I L. 60606 

Cook 

Phone: (312) 726-7146 

Fax: (312) 726-7102 

Susan.Charles@icemiller.com 

Subject Matter. Metropclitan Ch'1cago Interstate Air Qual'rty Contra 

Specific information requested from: Bureau of Air- Unit- 217/524-5683- 217/524-5023(FAX) 

Date From: 2004 To: 2009 

Most Recent: Yes 

Other Information: Please provide annual emissions data (in aggregate tons per year) of Volatile Organic Material 

("VOM") from pcint sources in the Metropolitan Chicago Interstate Air Quality Control Region. Please provide 

data for calendar years 2004 - 2008 and, to the extent available, 2009. 

Fee Waiver/Reduction Justification: Not Applicable 

-end of requestExhibit n 

1/24/2011 
Electronic Filing- Received, Clerk's Office, February 10, ~9ollnACHMENT No. __ 

BEFORE 11-IE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER OF: 

PETI110N OF GREIF, INC. AND 

GREIF PACKAGING, LLC 

FOR AN ADJUSTED STANDARD FROM 

35 ILL ADM. CODE PART 218 

SUBPART IT 

) 

) 

) 

) 

) 

) 

) 

AS 2011-001 

(Adjusted Standard- Air) 

NOTICE OF ELECTRONIC FILING 

TO: 

John Therriauli, Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

100 West Randolph Street, Suite 11-500 

Chicago, IL 60601 

Division of Legal Counsel 

Illinois Environmental Protection Agency 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

PLEASE TAKE NOTICE that I have today electronically filed with the Office of the 

Clerk of the Illinois Pollution Control Board, Petitioners' NOTICE OF ELECTRONIC 

FILING, PROOF OF PETITION NOTICE REQmREMENTS and CERTJFICA TE OF 

SERVICE, copies of which are attached herewith and served upon you. 

Date: February 10,2011 

Thomas W. Dimond 

Susan Charles 

ICE MILLERLLP 

200 West Madison Street 

Suite 3500 

Chicago, Illinois 60606 

Respectfully submitted, 

GREIF, INC. and GREIF PACKAGING, LLC 

· By: /s/ Susan Charles 

One of its Attorneys 

1 
Electronic Filing - Received, Clerk's Office, February 10, 2011 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MA TIER OF: 

PETITION OF GREIF, INC. AND 

GREIF PACKAGING, LLC 

FOR AN ADJUSTED STANDARD FROM 

.35 ILL ADM. CODE PART 218 

SUBPARTTT 

) 

) 

) 

) 

) 

) 

) 

AS 2011-001 

(Adjusted Standard- Air) 

PROOF OF PETITION NOTICE REQUIREMENTS 

Pursuant to 35 Ill. Adm. Code Sections 104.408 and I 04.410, on January 27, 20 II, 

petitioners Greif, Inc. and Greif Packaging, LLC ("Greif') published notice of the filing of their 

Petition for an Adjusted Standard ("Petition") by advertisement in a newspaper of general 

circulation in the area of Greifs Naperville plant. In support of this filing Greif states the 

following: 

I. Greiffi1ed the Petition with the Clerk of the Illinois Pollution Control Board on 

January 24, 20 I 1. 

2. Pursuant to the Petition, Greif seeks an adjusted standard from 35 lll. Adm. Code 

§ 218.986( a) as it applies to control requirements for emissions of volatile {)rganic material at 

Greifs fiber drum manufacturing facility located in Naperville, Illinois. 

3. On January 27,2011, Greif published notice of the filing of the Petition by 

advertisement in the Naperville Sun. a newspaper of general circulation in Naperville, Illinois. 

4. As required by 35 Ill. Adm. Code Section 104.408(a), Greif published notice of 

the filing of the Petition within 14 days after it filed the Petition. 

5. The notice includes the specific language required by 35 Ill. Adm. Code Section 

104.408(b ). 
Electronic Filing - Received, Clerk's Office, February 10, 2011 

6. AB required by 35 Ill. Adm. Code Section 104.410, a certificate of publication 

issued by the publisher of the Naperville Sun ce1tifying publication of the notice on January 27, 

20 II is attached as Exhibit 1. The ce_rtificate of publication attaches Greifs notice as it appeared 

in the Naperville Sun and states that the Naperville Sun satisfies the requirements of the Illinois 

Notice by Publication Act, 715 ILCS 5/0.01, et seq. The language included in Griefs notice is 

consistent with 35 Ill. Adm. Code Section 104.408(b). 

WHEREFORE, for the reasons stated above, Greif has satisfied the requirements for 

providing notice of the filing of its Petition for an Adjusted Standard and for filing proof of such 

notice with the Illinois Pollution Control Board. 

Date: February I 0, 2011 

Thomas W. Dimond 

Susan Charles 

ICE MILLER LLP 

200 West Madison Street 

Suite 3500 

Chicago, Illinois 60606 

Respectfully submitted, 

GREIF, INC. and GREIF PACKAGING, LLC 

By: Is/ Susan Charles 

One of its Attorneys 

2 
Electronic Filing - Received, Clerk's Office, February 10, 2011 

CERTIFICATE OF SERVICE 

I, the undersigned, certify that on this lOth day of February, 2011, I have served 

electronically the attached NOTICE OF ELECTRONIC FILING and PROOF OF PETITION 

NOTICE REQUIREMENTS upon the following person: 

John Therriault, Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

100 West Randolph Street, Suite 11-500 

Chicago, IL 6060 I 

and by U.S. Mail, first class postage prepaid, to the following persons: 

Division of Legal Counsel 

Illinois Environmental Protection Agency 

1021 North Grand Avenue East 

P.O .. Box 19276 

Springfield, IL 62794-9276 

/s/ Susan Charles 

Susan Charles 
ICE MILLER LLP 

104478 V1 Greif ASP 

Electronic Filing - Received, Clerk's Office, February 10, 2011 

Sun Times Media 

ADORDERNUMBER: 0000030356-01 

PO NUMBER: 

AMOUNT: 

NO OF AFFIDAVITS: 

ICE MillER LLP 

104478 V1 Greif ASP 

$147.60 

1 

2300 CABOT DR STE 455 

LISLE, ll60532-46i3 

Sun-Times Media West 

Certificate of Publication 

State of Illinois~ County of DuPage 

Surr Times Media West, does hereby certify it has published the attached 

advertisments In the followihg secular newspapers. All newspapers meet Illinois 

Complied Statue requirements for publication of Notices per Chapter 715 ILCS 5/0,01 

et seq. R.S. 1874, P728 Sec 1, EFF. July 1, 1874. Amended by laws 1959, P1494, EFF. 

July 17, 1959. Formerly Ill. Rev. Stat. 1991, CH100, Pl. 

Note: Notice appeared in the following checked positions. 

PUBLICATION DATE(S): 01/2712011 

Naperville Sun 

IN WITNESS WHEREOF, the undersigned, being duly authorized, has caused 

this Certificate to be signed and notarized 

By ~,P,JrJ,Z·· • &4.. 

(/ John G. Bleshke 

Account Manager- Public Legal Notices 

Subscribed and sworn to before me this 27th Day of January 2011 A.D. 

~~J-~ Notary Public 

Exhibit 1 

OFFICIAl SEAL 

OATiiERINE A CYNCAR 

NOTARY I'UBUO, IJTAl'E OF IUJNOJS 

KANE COUNTY 

MY OOMM!.96JON ro<PlA!lS 11!1~4 
I 

I 

I 

I 

I 

I 

·•· .. 
l 

!EPA ATTACHMENT NO._ 

ILLINOIS POLLUTION CONTROL BOARD 

March 17,201 I 

IN THE MATTER OF: 

PETITION OF GREIF PACKAGING, 

LLC., FOR AN ADJUSTED STANDARD 

FROM 35 ILL. ADM. CODE PART 218 

SUBPARTTT 

) 

) 

) 

) 

) 

) 

ORDER OF THE BOARD (by G.L. Blankenship): 

AS Il-l 

(Adjusted Standard- Air) 

On January 24,2011, Greif Packaging, LLC. (Greif) filed a petition for an adjusted 

standard (Petition) pursuant to 35 IlL Adm. Code § I 04.400, et seq. Greif seeks an adjusted 

standard from 35 IlL Adm. Code§ 218.986(a) as it applies to control requirements for emissions 

of volatile organic material (YOM) at Greifs fiber drum manufacturing facility in Naperville, 

Du Page County. Greif has requested a hearing to satisfy the State Implementation Plan 

requirements for Reasonably Available Control Technology. 

Section 28.1 of the Act ( 415 ILCS 5/28.1 (2008)) and 35 IlL Adm. Code I 04.408 require 

publication of a notice of an adjusted standard proceeding in a newspaper of general circulation 

in the area affected by the petitioner's activity. The notice must be published within 14 days of 

filing a petition for an adjusted standard with the Board. See 35 Ill. Adm. Code I 04.408(a). As 

required by 35JIL Adm. Code 104.410, Greif timely filed a certificate of publication with the 

Board on February 10, 2011. The notice of petition was published in the Naperville Sun on 

January 27,2011. 

The Board finds that the notice and petition meet the requirements of Section 28.1 of the 

Act ( 415 ILCS 5/28.1 (2004)) and 35 Ill. Adm. Code I 04.408 and accepts this matter for hearing. 

Unless otherwise ordered by the hearing officer, the Illinois Environmental Protection Agency 

(Agency) must file a response including its recommendations concerning the Board's proposed 

action on this petition within 45 days after service of the petition. See 35 Ill. Adm. Code 

104.416(a). On March 9, 2011, the Agency filed a motion for an extension of time to file its 

response. Greif did not oppose this motion. On March I 0, 20 II, the Hearing Officer granted the 

Agency until April 11, 2011 to file its recommendation. 

Hearings shall be scheduled and completed in a timely manner. The hearing officer shall 

inform the Clerk of the Board of the time and location of hearing at least 40 days in advance of 

hearing so that a 30-day public notice of hearing may be published. Today's order provides no 

determination on the informational sufficiency or merits ofGreifs petition. The Board, through 

orders of its own or its hearing officer, may direct Greif to provide additional information concerning 

its request prior to hearing. 

IT IS SO ORDERED. 
2 

I, John Therriault, Assistant Clerk of the Illinois Pollution Control Board, certify that the 

Board adopted the above order on March 17,2011, by a vote of 5-0. 

John Therriault, Assistant Clerk 

Illinois Pollution Control Board 
/EPA ATTACHMENT NO. i_ 

RECEIVED 

CLERK'S OFFICE 

ILLINOIS POLLUTION CONTROL BOARD 

March 21,2011 

MAR 21 2011 

STATE OF ILLINOIS ~n Control Board 

IN THE MA TIER OF: 

PETITION OF GREIF PACKAGING, 

LLC., FOR AN ADJUSTED STANDARD 

FROM 35 ILL. ADM. CODE PART 218 

SUBPARTTT 

) 

) 

) 

) 

) 

) 

AS 11-1 

(Adjusted Standard- Air) 

HEARING OFFICER ORDER 

The hearing officer directs petitioner to address the pre-hearing questions attached to this 

order. Written responses to the Board's questions must be filed at least 30 days before the 

hearing. Prefiled testimony must be filed at least 14 days before the hearing. A hearing date will 

be scheduled when the parties decide how much time will be needed to prepare these documents. 

The Illinois Environmental Protection Agengy' s deadline for filing its recommendation is April 

11,2011. 

IT IS SO ORDERED. 

Bradley P. Halloran 

Hearing Officer 

lllinois Pollution Control Board 

James R. Thompson Center, Suite 11-500 

100 West Randolph 

Chicago, lllinois 60601 

312.814.8917 
2 

CERTIFICATE OF SERVICE 

It is hereby certified that true copies of the foregoing order were mailed, first 

class, on March 21, 2011, to each of the persons on the attached service list. 

It is hereby certified that a true copy of the foregoing order was hand delivered to 

the following on March 21, 2011: 

John T. Therriault 

Illinois Pollution Control Board 

James R. Thompson Center 

100 W. Randolph St., Ste. 11-500 

Chicago, Illinois 60601 

~~-\~~- \ 

Bradley P. Halloran 

Hearing Officer 

lllinois Pollution Cntrol Board 

James R. Thompson Center 

100 West Randolph Street, Suite 11-500 

Chicago, lllinois 
AS 2011-001 

Division of Legal Counsel 

IEPA 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

AS 2011-001 

Thomas W. Dimond 

Ice Miller LLP 

200 W. Madison, Suite 3500 

Chicago, IL 60606 

3 

AS 2011-001 

Susan Charles 

Ice Miller LLP 

200 W. Madison, Suite 3500 

Chicago, IL 60606 
35 lAC 104.406(g) 

AS 11-9 GREIF PACKAGING, LLC 

BOARD QUESTIONS FOR PETITIONER 

I. Currently, the Illinois State Implementation Plan (SIP) relies on Reasonably Available 

Control Technology (RACT) for 35 lAC 218 Subpart TT sources, like Greif Packaging, 

that would require 81% capture and control reductions in VOM emissions. As the 

petition indicates, since Greif is proposing a 55% reduction in lieu of 81%, IEPA would 

need to submit an SIP revision to USEPA for approval. Greif indicated it will work with 

the Agency to submit the SIP revision. Pet. at 23. 

Greif Packaging provided a "RACT Study" dated August 20 I 0 addressing various 

compliance alternatives (Pet. Exh. A), however, the study did not include an ambient air 

quality impact analysis. Although the petition relates Greif's maximum permitted VOMs 

to the Statewide and Chicago Area emissions (Pet. at 16.), Greif has not demonstrated 

that the proposed adjusted standard will not cause or contribute to violations of the 

National Ambient Air Quality Standard (NAAQS) for ozone or delay efforts to attain the 

NAAQS in a timely manner. 

The hearing officer directs Greif to provide an Ambient Air Quality Impact Analysis for 

ozone as part of its petition to demonstrate that the proposed adjusted standard will not 

cause or contribute to violations of the NAAQS for ozone or delay efforts to attain the 

NAAQS in a timely manner. Greif should consult with the IEP A as to the necessary 

elements Greif should provide in the analysis to assure the IEPA has sufficient supporting 

documentation for the SIP revision request. 

The Board notes that IEPA has previously relied on petitioners to conduct an Ambient 

Air Quality Impact Analysis for ozone using the "Scheffe Method". See AS 04-1, In the 

Matter of: Petition of Crownline Boats, Inc. for an Adjusted Standard from 35 lAC 

215.301 at 9-10, and Technical Document Section 5 and Appendix 16. See AS 09-4, In 

the Matter of: Petition of Royal Fiberglass Pools, Inc. for an Adjusted Standard from 35 

lAC 215.301, Technical Document Section 6. See AS 09-4, illinois EPA's Response to 

Questions posed by the Illinois Pollution Control Board in the Matter of Royal Fiberglass 

Pools' Petition for an Adjusted Standard, October 14, 2009 at 2. See also AS 09-4, 

lllinois EPA's Response to Further Questions posed by the Illinois Pollution Control 

Board in the Matter of Royal Fiberglass Pools' Petition for an Adjusted Standard, 

October 27, 2009 at 2. 

The Scheffe method, formally known as "VOC/NOx Point Source Screening Tables", by 

Richard D. Scheffe, USEPA, September 1988, can befound at: 

http://www .docstoc.com/docs/34211795/DISCLAIMER 

http://ndep.nv.gov/bapc/permitting/download/modellscheffe.doc 
If Greif applies the Scheffe Method, Greif should consider the worst case scenario, using 

the maximum permitted VOM emissions. The analysis should also quantify the 

difference in emissions that would occur if Greif complied with 81% versus the 55% 

reduction based on past and projected annual emissions data. The analysis should 

provide a basis (such as an ozone increment or other basis as suggested by the !EPA) to 

indicate if the 55% reduction would constitute a significant increase over the 81% 

reduction due to the adjusted standard. 

35 lAC 1 04.406(0 

2. Since the Ambient Air Quality Impact Analysis for ozone might be performed based on 

the assumption that 22.8 tons per year (tpy) would be the maximum VOM emitted from 

the QC Test Process, would you please comment on proposing a condition in the adjusted 

standard language that would limit VOMs to 22.8 tpy or less from the QC Test Process. 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

IEPA ATTACHMENT NO. 5 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MA ITER OF: 

PETITION OF GREIF PACKAGING, LLC AS 2011-01 

FOR AN ADJUSTED STANDARD FROM 

35 ILL ADM. CODE PART 218 

SUBPART IT 

) 

) 

) 

) 

) 

) 

(Adjusted Standard- Air) 

NOTICE OF ELECTRONIC FILING 

TO: 

John Therriault, Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

100 West Randolph Street, Suite 11-500 

Chicago, IL 60601 

Charles Matoesian 

Division of Legal Counsel 

Illinois Environmental Protection Agency 

1 021 North Grand Avenue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

PLEASE TAKE NOTICE that I have today electronically filed with the Office of the 

Clerk of the Illinois Pollution Control Board, Petitioner's NOTICE OF ELECTRONIC 

FILING, AMENDED PETITION FOR AN ADJUSTED STANDARD and CERTIFICATE 

OF SERVICE, copies of which are attached herewith served upon you. 

Date: May 31,2011 

TI1omas W. Dimond 

Susan Charles 

ICE MILLER LLP 

200 West Madison Street 

Suite 3500 

Chicago, lllinois 60606 

Respectfully submitted, 

ICE MILLER, LLP 

By: !sf Susan Charles 

One of its Attorneys 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

CERTIFICATE OF SERVICE 

I, the undersigned, cettify that on this 31st day of May, 2011, I have setved electronically 

the attached NOTICE OF ELECTRONIC FILING and AMENDED PETITION FOR AN 

ADJUSTED STANDARD upon the following person: 

John Therriault, Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

100 West Randolph Street, Suite 11-500 

Chicago, 11 60601 

and by U.S. Mail, first class postage prepaid, to the following persons: 

Charles Matoesian 

Division of Legal Counsel 

nlinois Environmental Protection Agency 

I 021 North Grand A venue East 

P.O. Box 19276 

Springfield, 11 62794-9276 

lsi Susan Charles 

Susan Charles 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER OF: 

PETITION OF GREIF, INC. AND 

GREIF PACKAGING LLC 

FOR AN ADJUSTED STANDARD FROM 

351LLADM. CODE PART 218 

SUBPARTTI 

) 

) 

) 

) 

) 

) 

) 

AS 2011-001 

(Adjusted Standard- Air) 

AMENDED PETITION FOR AN ADJUSTED STANDARD 

GREIF, INC. and GREIF PACKAGING LLC ("Greif''), through counsel and pursuant to 

35 Ill. Adrn. Code § 104.400, et seq., submit this Amended Petition for an Adjusted Standard 

("Petition") to the Illinois Pollution Control Board ("Board"), seeking an adjusted standard from 

35111. Adm. Code§ 218.986(a) as it applies to the emissions of volatile organic material 

("YOM") into the atmosphere from Greif's fiber drum manufacturing facility located at 5 S 220 

Frontenac Road in Naperville, DuPage County, Illinois. 

I. INTRODUCTION AND SUMMARY OF PROPOSED ADJUSTED STANDARD 

Greif operates a fiber (paper) drum container manufacturing facility in Naperville, 

DuPage County, Illinois. In general, fiber drums are produced by cutting fiber material to the 

appropriate length, forming the material into a cylinder and attaching a top and bottom to the 

cylinder. Some of the fiber drums require the addition of a polyethylene drum liner to meet 

customer specifications, particularly for storage and transport of food-grade products. Greif 

conducts quality control ("QC") testing ofthe liners of these drums by spraying a QC test fluid (a 

denatured alcohol product, which is a YOM) into the interior of the drums at the QC spray 

station. 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Greif uses an automated system to spray the interior of the dn.un liners with QC test fluid. 

As a drum moves along the conveyor belt toward the QC spray station it triggers a sensor on the 

guide rail that causes the drum to stop. A mechanical wand then drops down into the dn.nn and 

sprays the QC test fluid. The wand is calibrated so that each spray releases about the same 

amount of QC test fluid into each drum. Once the QC test fluid has been sprayed onto the drum 

liner, the wand retracts so the drum may continue to move along the conveyor. 

The drums then are conveyed 45 feet to the QC inspection station where the interior of 

the drum is visually inspected for pinholes. If pinholes are present, the ethanol causes a brown 

spot to appear, enabling the line inspector to detect the pinhole. The drum next is conveyed 120 

feet to a drying oven where most of the remaining test fluid is evaporated. After leaving the 

drying oven any remaining fluid is vacuumed from the drum and then the drum is wiped dry. 

VOM is emitted throughout the QC Test Process as well as in the paint drying oven. 

Greif tracks its VOM emissions on a monthly basis by calculating the mass of VOMs 

used and assuming that all usage is emitted to the atmosphere. To calculate mass, Greif records 

the volume of denatured alcohol held as inventory on the first and last day of each month. Greif 

also tracks the volume of any denatured alcohol purchased within each month. The volwne of 

denatured alcohol purchased during a month is added to the inventory held on the first day of 

that month. The total, less any inventory remaining on the last day of the month, equals the 

volmne of denatured alcohol used. The volume is then multiplied by the VOM content (in 

pounds per gal) of the denatured alcohol to compute the mass (in pOlmds) ofVOM emitted 

during the month. 

2 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Air emissions ofVOM and hazardous air pollutants ("HAPs") at Greifs Naperville 

facility are subject to Federally Enforceable State Operating Penni! No. 9707044 ("FESOP"). 1 

Condition 3 of the FESOP limits VOM emissions from the QC Test Process to 22.8 tons per year 

("tpy''). Condition 3 also includes emission lmit specific limits on VOM emissions from the 

remainder of the plant (which includes a paint spray booth, a caulk applicator, and ink printing). 

The aggregate of these limits is 1.4 tpy. The FESOP limits HAP emissions to 10 tpy for any 

single HAP or 25 tpy for any combination of such HAPs. Greif reported 2010 emissions from its 

Naperville facility of9.95 tons ofVOM (plant-wide) and total combined HAPs of 1.87 tons. 

On July 5, 2007, the Illinois Environmental Protection Agency ("Agency") issued 

Violation Notice A-2007-00132 ("Violation Notice") to Greif alleging, in relevant part, that the 

Naperville facility exceeded condition 3 of the FESOP, relating to VOM emissions. Greif 

reported emissions fi-om the QC Test Process in 2006, 2007, 2008, 2009 and 2010 of 35.2, 46.7, 

19.1, 7.7 and 8.95 tons, respectively. The Agency alleges that Greifs VOM emissions now are 

subject to the 81 percent capture and control requirements of 35 Ill. Adm. Code Part 218, 

Subpart TI, Section 218.986(a), because emissions in 2006 and 2007 exceeded the 25 tpy 

applicability threshold and because Subpart TT is a "once in- always in" regulation. See 35 Ill. 

Adm. Code Section 218.980 (a)- (c). 

The Board promulgated 35 Ill. Adm. Code Part 218 to implement reasonably available 

control technology ("RACT") for sources ofVOM emissions within certain areas of Illinois. See 

In the Matter of Reasonably Available Control Technology for Major Sources Emitting Volatile 

ln 2006, the FESOP wns issued to Greif Bros. Corpomtion, which had changed its name to Greif, Inc. 

Greif, Inc. has transferred ownership and operation of the Naperville plant to its wholly owned subsidiary, Greif 

Packaging LLC. When the FESOP is renewed, it will also be transferred into the name of Greif Packaging LLC. 

3 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Organic Materials in the Chicago Ozone Nonattainmenl Area: 25 Tons, R93-14, Final Order 

(January 6, 1994). Section 218.986 provides, in relevant pa1i: 

Every owner or operator of an emission unit subject to [Subpart IT] shall comply 

with the requirements of subsection (a), (b), (c), (d), or(e) below. 

a) Emission capture and control equipment which achieves an 

overall reduction in uncontrolled VOM emissions of at 

least 8 I percent from each emission unit .... 

Greif conducted a RACT Study to evaluate whether various emission control options for 

the QC Test Process satisfy RACT control requirements in Section 218.986(a). See Exhibit A, 

Reasonably Available Control Technology Study, dated August 2010, revised March 2011, 

prepared for Greifby Thomas C. Ponder, Jr., PE ("RACT Study"). Greif submitted the RACf 

Study to the Agency on September 16, 2010. The RACT Study evaluated three capture and 

control systems: capture plus recuperative thermal oxidizers, capture plus carbon adsorbers and 

capture plus biofilters and material substitution. The RACT Study concludes that each option 

could achieve at least 81 percent capture and control of VOM emissions as required under 

Section 218.986(a), but only at a cost per ton ofVOM emissions controlled ofbetween $11,667-

$17,672. These costs exceed what the Board typically has considered reasonable in adopting 

RACT regulations. See infra at Section Il(H)(l )(d). 

The RACT Study also evaluated the technical feasibility and economic reasonableness of 

two material substitution options: mixing the QC test fluid with acetone or water. Material 

substitution using acetone was fotmd to be technically infeasible because of product quality 

concerns related to the effect of acetone on the product. Acetone in the QC test fluid causes the 

gasket material that seals the drum bottom to the side walls to dissolve, which is unacceptable. 

However, material substitution using a test fluid composed of 45 percent denatured alcohol and 

4 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

55 percent water achieves a 55 percent reduction in VOM emissions and results in an overall cost 

reduction. The RACT Study concludes that the material substitution option using 45 percent 

denatured alcohol and 55 percent water constitutes RACT for Grief's Naperville facility. 

After determining that t11e 45/55 QC test fluid mixture could satisfy appropriate product 

quality standards, Greif conducted additional tests to determine whether the amount of QC test 

fluid applied to each drum nm through its QC Test Process could be reduced. Based on this 

testing, Greif determined that it could reduce the QC test fluid sprayed to an amount not to 

exceed 48 grams. 

Based on the RACT Study and the analysis of adjusted standard requirements as set forth 

herein, Greif has satisfied the conditions for issuing an adjusted standard from the 81 percent 

capture and control requirement of Section 218.986( a). 

II. 35 ILL. ADM. Code Section 104.406: Petition for Adjusted Standard 

The procedural requirements for submission of an adjusted standard petition to the Board 

are folmd at 35 Til. Adm. Code Part 104, Regulatory Relief Mechanisms, Subpart D. Sections 

104.406(a)- (1) of Subpart D specify the information that must be included in any adjusted 

standard petition. The requisite headings and corresponding information required under Subpart 

D ru·e set forth below. 

A. Standard From Which Relief Is Sought- Section 1 04.406(a) 

Greif seeks an adjusted standard fTOm the requirements of 35 TIL Adm. Code Part 218, 

Subpart TT, Section 218.986(a), Control Requirements, which sets emission reduction 

requirements for sources ofVOM emissions not regulated under other subparts of Part 2!8. 

Section 218.986 became effective January 6, 1994. RACTfor Chicago Ozone, R93-14. Pursuant 

to Section 218.980(b )(1 ), the applicability threshold for Subpart TT is the potential to emit 25 

5 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

tpy of YOM, in the aggregate, from emission units at a source other than those specifically 

excluded from Subpart TT. The control requirements for qualifYing emission units at sources 

subject to Subpart TT are set f01th in Section 218.986. Section 218.986 provides, in relevant 

part: 

Every owner or operator of an emission unit subject to [Subpart TT] shall comply 

with the requirements of subsection (a), (b), (c), (d), or (e) below. 

a) Emission capture and control equipment which achieves an 

overall reduction in uncontrolled YOM emissions of at 

least 81 percent from each emission unit .... 

Greif seeks an adjusted standard from the 81 percent capture and control requirement of Section 

218.986(a) as it applies to Griefs Naperville facility. The facility is not seeking an adjusted 

standard from Section 218 .986(b) - ( e )_2 

As Greif will demonstrate, achieving capture and control of at least 81 percent of YOM 

emissions from its QC Test Process is not economically reasonable as applied to Greif, could 

increase emissions of other pollutants and may pose increased health and safety risks. Other 

alternative control strategies are technically infeasible because of negative impacts on product 

quality. Instead, Grief proposes to dilute the QC test fluid from 100 percent denatured alcohol to 

45 percent denatured alcohol and 55 percent water. Greif also will limit the amount of QC test 

fluid that will be sprayed into each drum. These proposed modification of the QC Test Process 

will reduce YOM emissions from Greifs QC Tesl Process by approximately 70 percent on a lmit 

basis- to an armual emission level that is below the applicability threshold of Subpart TT. 

2 Subsections (1>)- (e) are not applicable to the QC Test Process at Naperville and thus are not included in this 

Petition. See 35 Ill. Adm. Code Section 218.986(b)- (e) (applicable to: coating lines (subsection(!>)), submission 

of an equivalent alternative control plan (subsection (c)), non-contact process cooling water (subsection (d)) and 

specific control measures applicable to leaks from components subject to the control requirements of Subpart IT 

(subsection (e))). 

6 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Greif will not require an adjusted standard from Section 218.108, "Exemptions, 

Variations, and Alternative Means of Control or Compliance Detetminations" for the adjusted 

standard from Section 218.986(a) to become effective at the state level. Section 218.108 

provides: 

Notwithstanding the provisions of any other Sections of this Part: 

a) Any exemptions, variations or alternatives adopted by the 

Board pursuant to Section 28, 28.1 or 35 of the Act to the 

control requirements, emission limitations, or test methods 

set forth in this Part shall be effective only when approved 

by the USEP A as a SIP revision. 

While the Agency will need to request the United States Environmental Protection Agency's 

("US EPA") approval of any Board-approved adjusted standard :from Section 218.986(a) in the 

form of a SIP revision, the adjusted standard will be effective at the state level immediately upon 

granting by the Board. See In the Matter of Petition of Alumax Inc. for an Adjusted Standard 

from 35 Ill. Adm. Code Part 218, AS 92-13, Slip. Op. at 4 (September I, 1994); see also, In the 

Matter of Reasonably Available Control Technology for Major Sources Emitting Volatile 

Organic Materials in the Chicago Ozone Nonattainment Area: 25 Tons, R93-14, Slip. Op. 

(Second Notice) at 5-6 (November 18, 1993). 

B. Nature of the Regulation of General Applicability- Section I 04.406(b) 

The Board promulgated 35 Ill. Adm. Code Part 218 to implement Section 182(b)(2) of 

the Clean Air Act, 42 U.S.C. § 7511 a(b )(2), which, among other things, requires individual states 

with severe non-attainment areas to adopt RACT regulations applicable to sources of YOM 

emissions within the non-attainment area. See RACTfor Chicago Ozone, R93-14, Slip Op. 

(Final Rule) at 2. As mandated by the Clean Air Act, the Board promulgated Part 218, including 

Subpart TT. Id. 

7 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

C. Level ofJustification- Section 104.406(c) 

The regulations of general applicability from which Greif seeks an adjusted standard do 

not specify a level of justification for an adjusted standard. Accordingly, the level of 

justification is that generally applicable to all adjusted standards. See 415 ILCS 5/28.1 

(Authorizing the Board to grant an adjusted standard upon adequate proof of the following: (1) 

the factors relating to the petitioner are substantially and significantly different from the factors 

relied upon by the Board in adopting the general regulation applicable to the petitioner; (2) the 

existence of those factors justifies an adjusted standard; (3) the requested standard will not result 

in environmental or health effects substantially and significantly more adverse than the effects 

considered by the Board in adopting the rule of general applicability; and (4) the adjusted 

standard is consistent with applicable federal law.). 

D. Facility and Process Description- Section 104.406(d) 

Greif operates a fiber drum container manufacturing facility in Naperville, DuPage 

County, illinois. DuPage County is part of the Metropolitan Chicago Interstate Air Quality 

Control Region. 40 C.F.R. § 81.14. This area is designated as a non-attainment area for owne 

(!-hour and 8-bour standard) under 40 C.F.R. § 81.314. 

The Naperville facility employs about 90 hourly and salaried people. Fiber drum 

manufacturing began at the Naperville plant in Aprill988. Greif's Naperville facility 

manufactures fiber drums ranging in size from six (6) gallons to seventy-five (75) gallons. In 

general, fiber drums are produced by cutting fiber material to the appropriate length, forming it 

into a cylinder and attaching a top and bottom to the cylinder. Some of the fiber drunJs require 

the addition of a polyethylene drum liner to meet customer specifications, particularly for storage 

and transport of food-grade products. 

8 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Greif conducts QC testing ofthe drum liners as follows: (1) as a drum moves along the 

conveyor belt toward the QC spray station it triggers a sensor on the guide rail causing the 

conveyor belt to stop; (2) a mechanical wand drops into the drum and releases the QC test fluid; 

(3) the mechanical wand retracts, the conveyor belt is restarted and the drum is conveyed 45 feet 

to the QC inspection station where the interior is visually inspected for pinholes (if pinholes are 

present, the ethanol causes a brown spot to appear, enabling the line inspector to detect the 

pinhole); (4) the drum is conveyed 120 feet to a drying oven where most of the remaining test 

fluid is evaporated; (5) after leaving the drying oven any remaining fluid is vacuumed from the 

drum and the drum is wiped dry. The QC test fluid evaporates slowly, resulting in YOM 

emissions throughout the process. See RACI' Survey at Section 1.0. 

In addition to the QC Test Process described above, permitted YOM emission sources at 

the Naperville facility include a caulk applicator, the paint spray booth and ink printing. Each of 

these sources has a source-specific annual YOM limit in the FESOP, and the aggregate of those 

YOM limits is 1.4 tpy. Because the plant's emissions have historically been less than 25 tpy, the 

facility has not previously been subject to Subpart TT and does not employ any equipment to 

capture or destroy YOM emissions. 

E. Investigation of Con1pliance Alternatives: Methods for Reducing YOM 

Emissions from Greif's Quality Control Testing Process Emission Unit- Section 

104.406(e) 

Relevant provisions of Section 218.986 would require Greif to captnre and control at 

least 81 percent of YOM emissions from the QC Test Process through the application of 

emission capture and control equipment. Greif investigated multiple compliance alternatives and 

the corresponding costs for each alternative. See RACI' Stndy at Section 3. As discussed below, 

the RACT Stndy demonstrates that dilution of the QC test fluid with water is the only technically 

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feasible and economically reasonable alternative. This alternative also can be implemented 

without increased health and safety risks and without additional emissions that may potentially 

offset the benefits of any associated VOM reductions. 

1. Capture Systems 

Greif's fther drwns with polyethylene liners are sprayed with the QC test fluid, conveyed 

45 feet to the QC test station for visual inspection and then conveyed 120 feet to the drum paint 

oven to evaporate most of the QC test fluid. The QC test fluid evaporates while the drums are 

being sprayed, transported for and awaiting inspection and then conveyed to the drum paint 

oven. Any remaining lest fluid is vacuumed or wiped fi·om the drums and to the extent it still 

contains VOM, may still be emitting VOM. An effective capture system would require a tunnel 

enclosure covering the 165 foot conveyer system from the QC spray station to the inspection 

station and, later, to the drum paint oven. See RACT Study at Section 3.1. Enclosures also 

would be needed for the hood at the QC spray station and the opening of the drum paint oven to 

ensure adequate capture of emissions. ld. Dueling to the associated control device(s) also would 

be required from the QC Test Process hood, the conveyor tunnel enclosure and the drum paint 

oven. !d. This type of capture system is assumed for each control method discussed below. TI1e 

capital and annual operating costs for the capture system are included within the cost summary 

for each control system. 

2. Control Technologies. 

Greif's RACT Study includes a thorough evaluation of the following add-on control 

technologies: (a) recuperative thermal incinerator; (b) carbon adsorption; and (c) biofilter and 

material substitution. Jd. at Section 3.2. As detailed below, each of these potential control 

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systems are economically unreasonable, have inherent charactetistics that could partially offset 

the environmental benefits ofVOM reduction and/or have potentially h<mnf11l safety impacts. 

a. Recuperative Thermal Incinerators 

Thennal incinerators heat an exhaust stream to a temperature sufficiently high to oxidize 

(bum) VOM in the exhaust. Thermal recuperative oxidizers have a heat exchanger that preheats 

the incoming air by recuperating heat from the exiting air. ld. at Section 3.2.1. As the incoming 

air passes on one side of the metal tube or plate, hot clean air from the combustion chamber 

passes on the other side of the tube or plate. Heat is transferred to the incoming air through the 

process of conduction using the metal as the medium of heat transfer. This system has heat 

recovery as great as 60 percent and therefore requires less natural gas than traditional 

incinerators to boost the combustion temperatures to I 600°F (the required temperature to ensure 

complete destruction ofVOM). ld. 

While a recuperative thermal incinerator can be more cost-effective than a traditional 

incinerator, it requires a large amount of natural gas as compared to other control options (fuel 

must be used even when the QC Test Process is not opemting to maintain the thermal oxidizer at 

temperature). ld. Frequent operation cycles in thennal oxiders cause condensation corrosion 

and thermal deterioration of the insulation which requires ongoing maintenance costs. I d. at 

Section 1.0. In addition, the large amount of natural gas required to operate thermal oxidizers 

generates NOx and CO emissions and small quantities ofVOM and HAPs, which would 

partially offset any benefits obtained from the associated VOM reduction. ld. 

The RACT Study concludes that total capital costs of the capture system and the 

recuperative thermal incinerator control technology at Greifs Naperville facility would be 

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Electronic Filing - Received, Clerk's Office, 05/31/2011 

$1,752,000 with annualized capital and operating costs of$17,672 per ton ofVOM controlled. 

See RACT Study at Table 4-1. 

b. Carbon Adsorbcrs 

Carbon adsorbers are used to control systems with low to medium YOM emission 

concentrations. See RACT Study at 3 .2.2. A carbon adsorber typically consists of two or more 

beds of activated carbon- one treats the exhaust emissions while the other is being regenerated. 

Id. Typically, regeneration involves passing steam through the carbon bed to remove the VOM 

with the steam, leaving the regenerated carbon to be reused. Carbon adsorbers work best with 

insoluble VOM, which simplifies the recovery of the VOM from the saturated beds. Id. In some 

cases, distillation is required to separate the VOM materials from the regeneration steam. !d. 

The QC test fluid is water soluble and would be very expensive to recover from the 

regeneration fluid. !d. In addition, the regeneration fluid likely could be sent to a local sewage 

district along with Grief's other process wastewaters. !d. Most sewer districts use equalization 

basins to reduce biological oxygen demand loading, which in this context includes VOM, by 

blowing solvents into the atmosphere; meaning that VOM emissions may not truly be reduced by 

the use of carbon beds. Id. Further, ketones fomd in the denatured alcohol present an inherent 

safety risk of fires from reactions between the ketones and the carbon in the beds. !d. Although 

carbon beds that handle ketones utilize water deluge systems to control bed fires, the increased 

health and safety risks remain. !d. 

The RACT Study concludes that total capital costs of the capture system and the carbon 

adsorbers control technology would be $1,170,000. This control option would result in total 

annualized capital and operating costs of$12,594 per ton ofVOM controlled. See RACT Study 

at Table 4-1. 

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c. Biofiltcr and Material Substitution 

Biofilters can be used to reduce VOM emissions without the use of natural gas to bum 

the hydrocarbons. See RACT Study at Section 3.2.3. Bioren has proposed to install a biofilter 

on the Greif drum plant in Oakville, Ontario, which could potentially reduce VOM emissions 

from that plant by 70 percent. Id. At Naperville, the 81 percent capture and control objective 

could be met only by combining the biofilter with another control technology or by considering 

the reductions in VOM emissions from the use of the water diluted test fluid as a capture and 

control technology reduction. Id. A biofilter system has lower operating costs, although the 

capital costs are comparable to incinerators. !d. Biofilters must be heated to maintain 

destruction activity during winter months and heat for the filter can be supplied by the direct 

combustion of natural gas, steam or electricity. Id. Natural gas used for combustion would 

increase NOx emissions from the facility, partially offsetting the benefit from reductions in 

VOM emissions. Id. 

Based on the RACT Study, total capital costs to install the capture system and the 

biofilter control technology (which includes use of the water diluted test fluid) is $1,800,000 and 

annualized capital and operating costs are $11,667 per ton ofVOM controlled. See RACT Study 

at Table 4-1. 

3. Material Substitution Options 

a QC Test Fluid- Dilution with Acetone 

Greif considered dilution of the QC test fluid with acetone (a non-VOM material) as a 

possible alternative. However, dilution of the testing fluid with acetone could cause the gasket 

material sealing the bottom of the d.tum to the drum walls to dissolve. See RACT Study at 3.3.2. 

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Due to the potential for product damage, diluting the QC testing fluid with acetone is considered 

technically infeasible. !d. 

b. QC Test Fluid- Dilution with Water 

Grief evaluated the operational impact of diluting the QC test fluid with varying amounts 

of water as a means to reduce YOM emissions. Grief experimented with different ratios of water 

to denatured alcohol to identify the composition able to reduce YOM emissions to the greatest 

extent possible while maintaining the ability to visually detect pinholes or other tears or 

imperfections in the drum linings. 

The testing procedure involved intentionally creating pinholes in the liners of five drums 

before sending them through the QC Test Process. The dn1ms were sprayed with varying 

modifications of the QC test fluid and visually inspected to determine if the pinholes could be 

detected within an acceptable time period (here, about 70 seconds). Jd. at 3.2.1. If the pinholes 

were detected, the test and the associated test fluic! were considerec! acceptable. Id. If the 

pinholes could not be c!etected, the fluid was consic!crerl a technically infeasible option based on 

Grief's inability to meet its customers' quality assurance standards. !d. 

Greif experimented with five potential alternative test fluids. A mixture of 80 percent 

c!enatured alcohol and 20 percent water revealed pinholes in each of five test drums within about 

5 seconds. !d. Based on this result, Greif next experimented with a mixture of70 percent 

denatured alcohol and 30 percent water. The 70/30 mixture revealed pinholes in each of five test 

drums after 7 seconds; but with noticeably lighter staining than with the 80/20 mixture. !d. A 

third test, using a 50 percent denatured alcohol and 50 percent water mixture identified 

significantly lighter staining around pinholes in each test drum within 45 seconds. Id. The test 

using 40 percent denatured alcohol and 60 percent water failed to identify flaws in the liners 

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within an acceptable time period. !d. Grief then evaluated a 45 percent denatured alcohol and 

55 percent water mixture. This mixture detected all of the pinholes within 50 seconds of 

spraying- although with significantly lighter staining. !d. Based on these test runs, Greif 

detennined that 55 percent dilution with water was the highest dilution percentage that would 

allow the plant to meet its customer's quality assurance requirements. 

Greifinfonned the Agency of these test results and began utilizing the diluted QC test 

fluid in May 2008 to achieve immediate reductions in VOM emissions even though the Agency 

bad not formally approved the substitution. To date, the water-diluted test fluid has allowed the 

detection of drum defects without banning the product. 

After detennining that the 45/55 QC test fluid mixture could satisfy appropriate QC 

standards, Greif conducted additional tests to detennine whefuer the amount of QC test fluid 

applied to each drum could be reduced. Based on this testing, Greif detennined that it could 

reduce the QC test fluid sprayed into each drum to an amount not to exceed 48 grams. 

Diluting the QC test fluid with water and reducing the amount of fluid used also has the 

potential to reduce annual emissions ofVOM from the QC Test Process below the 25 tpy 

applicability threshold of Section 218.980 and below the 22.8 tpy emissions limit in condition 3 

oftl1e F.ESOP. This has been demonstrated by a significant reduction in overall facility 

emissions between 2007 and 2008 and the approximate 70% reduction in per drum emissions. In 

addition, diluting the QC test fluid with water results in lower operating costs. Total capital costs 

to dilute the QC test fluid with water would be $0 and annualized capital and operating costs are 

reduced by $541 per ton ofVOC controlled. See RACT Study at Table 4-1. 

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4. Compliance Alternatives Conclusion 

Three capture and control systems would be technically feasible: capture plus 

recuperative thennal oxiders, capture plus carbon adsorbers and capture plus biofilters and 

material substitution. While each of these options could achieve the 81 percent capture and 

control objectives of Subpart TT, the cost/ton of YOM controlled range from $11,667 to 

$17,672. These costs exceed what the Board has considered reasonable in adopting RACT 

regulations. See infra at Section TI(H)(l ). Material substitution using acetone is technically 

infea~ible because of product quality issues. Material substitution using 55 percent water and 45 

percent denatured alcohol combined with reducing the amount of QC test fluid applied to each 

lined drum that is tested results in an overall reduction in costs while achieving an approximately 

70% reduction in YOM emissions compared to pre-substitution levels. 

F. Greif's Proposed Adjusted Standard- Section 104.406(f) 

Greif proposes the following adjusted standard for adoption by the Board: 

1. The proposed adjusted standard applies to the emission of YOM into the 

atmosphere from Greif's fiber dnuu manufacturing facility located at 5 S 

220 Frontenac· Road in Naperville, DuPage County, Illinois. 

2. Greif will reduce YOM emissions from its QC Test Process by using a 

test fluid composed of 45 percent denatured alcohol and 55 percent water. 

3. The QC Test Process equipment will be calibrated to spray no more than 

an average of 48 grams of QC test fluid per drum to be measured as 

foilows: once per quarter Greif will conduct a test to verify that the 

average amount of QC test fluid sprayed into at least five dnm1s meets this 

condition. 

4. All records and logs required by this adjusted standard shall be retained at 

a readily accessible location at the source for at least five years from the 

date of entry and shall be made available for inspection and copying by 

the Agency or USEP A upon request. Any records retained in an 

electronic format (e.g., complJter) shall be capable of being retrieved and 

printed on paper during normal source office hours so as to be able to 

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respond to an Agency-or USEP A request for records dming the course of a 

source inspection. 

5. Greif will maintain records of its denatured alcohol usage that will allow 

the monthly calculation ofthe amount of denatured alcohol used dming 

the month and the calculation ofVOM emissions on a 12-month rolling 

total basis for comparison to annual VOM limits in the FESOP. 

6. Greif will continue to investigate the availability of alternative QC test 

fluids with lower VOM content. Greif will incorporate such lower VOM 

QC test fluids into its QC Test Process provided that the lower VOM QC 

test fluids allow visual detection of pinholes or other tears or 

imperfections in the drwn linings within an acceptable period of time and 

does not result in any negative product quality impacts. 

7. Greif will coordinate with the Agency to submit to USEPA a request for 

revision of the SIP consistent witl1 this proposed adjusted standard 

requiring use of the diluted QC test fluid and limiting the amount of QC 

test fluid sprayed per drum as an alternative to capture and control 

technology. 

8. The proposed adjusted standard will not affect the calculation of Greif's 

potential Emissions Reduction Market System ("ERMS") baseline or its 

ERMS allotment if Greif's Naperville plant should participate in the 

ERMS program. 

9. Environmental staff of Greif's parent will conduct a formal training 

session for Naperville facility personnel on the requirements of the FESOP 

and the internal procedures for tracking compliance with FESOP 

conditions. 

10. Greif will continue to implement an improved system for monthly tracking 

and calculations ofVOM emissions and monthly comparison of the 

calculations to VOM limits contained in the FESOP. The results ofthe 

comparison will continue to be reported to Greif's facility management 

monthly so that any deviations or cxceedances ofFESOP conditions can 

be ideotified and timely reported to the Agency as required by FESOP 

condition 6. 

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G. Quantitative and Qualitative Description of Greif's Impact on the Environment 

Before and After the Proposed Adjusted Standard- Section 1 04.406(g) 

1. Air Quality Impact Analysis ofGre(fs Operations 

Application of the proposed adjusted standard will allow Greif to reduce YOM emissions 

from the QC Test Process by about 70% on a per drum basis compared to pre-change levels. 

While this reduction is less than the 81 percent capture and control requirement of Section 

218.986(a), the proposed adjusted standard will allow Grief to reduce YOM emissions below 

levels required by its FESOP and the threshold for Subpart TT applicability. 

The emissions of YOM from the QC Test Process at the Naperville plant will have a 

minimal impact on air quality. In 2009, state-wide YOM point source emissions were 54,668 

tons. See Illinois Annual Air Quality Report 2009, Table C-5 (!EPA November 2009) (available 

at www.epa.state.il.us/air/air-quality-report/2009/air-quality-report-2009.pdf) (2010 data was not 

available at the time Greif filed its Amended Petition). Thus, even at the maximum permitted 

emissions levels for the Naperville plant (22.8 tpy based on condition 3 of the FESOP), YOM 

emissions from the QC Test Process would amount to about 0.04% of state-wide point source 

emissions. Similarly, 2009 YOM point source emissions for the Metropolitan Chicago area were 

11,884. See September 8, 2010 E-mail from EPA.FOIA.BOA@ Illinois.gov to Susan Charles 

responding to Freedom of Infonnation Act request, attached as Exhibit B. Assuming maximum 

emissions permitted under the FESOP for the Naperville plant, YOM emissions from the QC 

Test Process would amount to only 0.19% of Metropolitan Chicago point source emissions. 

The Board previously has found that adjusted standards from Subpart TT from sources 

with much higher YOM emissions would have no significant impact on air quality. See, e.g., In 

the Matter of Petition of Ford Motor Co. (Chicago Assembly Plant) for an Adjusted Standard 

from 35 R/. Adm. Code Section 218.986, AS 00-6, Slip. Op. at 5 (April6, 2000) (uncontrolled 

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Electronic Filing- Received, Clerk's Office, 05/31/2011 

emissions of 390 tpy would have no significant impact on air quality or lnunan health); In the 

Matter of Petition of Alumax, Inc.for an Adjusted Standard from 35 Ill. Adm. Code Part 218, 

AS 92-13, Slip. Op. at 9 (Sept. I, 1994) (excess uncontrolled emissions of76 tpy would not 

significantly impact air quality). The Board also has shown a particular concern for capture and 

control technologies, such as incinerators, tlmt create alternate emissions, e.g., NOx, which also 

contribute to ozone formation or hazardous waste generation that offset any environmental gains 

from reducing YOM emissions. See, e.g., Alumax, AS 92-13, Slip. Op. at 7 (Board granted 

adjusted standard where control technologies created offsetting emissions ofNOx and YOM); In 

the Matter of Joint Petition of Quantum Chemical Corporation, US! Division (and the Jllinois 

Environmental Protection Agency) for an Adjusted Standard from Parts of35 Ill. Adm. Code 

218.966 and 218.986, AS 92-14, Slip. Op. at 9 (Board granted adjusted standard where use of 

control technology would emit NOx which, like YOM, contributes to ozone fonnation, that 

would partially offset tl1e benefits of YOM reduction). 

2. Cross-Media Environmental Impacts Resulting from an Adjusted 

Standard. 

None. Greifs waste and wastewater generation is independent of YOM emissions from 

the QC Test Process; therefore, no change in the nature or volume of waste and wastewater is 

anticipated. 

H. Justification- Section 1 04.406(h) 

Where, as here, the regulation of general applicability does not specify a level of 

justification required for a petitioner to qualify for an adjusted standard, Section 28.1 (c) of the 

lllinois Environmental Protection Act, 415 ILCS 5/28.1 (c), authorizes the Board to grant an 

adjusted standard upon adequate proof of the following: (1) the factors relating to ilie petitioner 

are substantially and significantly different from ilie factors relied upon by the Board in adopting 

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the general regulation applicable to the petitioner; (2) the existence of those factors justifies an 

adjusted standard; (3) the requested standard will not result in environmental or heallh effects 

substantially and significantly more adverse than the effects considered by the Board in adopting 

the mle of general applicability; and (4) the adjusted standard is consistent with applicable 

federal law. 

1. Factors Relating to Grei(are Substanlial/v and Significantly Di([erent. 

The factors relating to Greif's ability to reduce VOM emissions are substantially and 

significantly different from any the Board may have relied on in adopting Subprut TT. First, the 

Boru·d did not rely on any specific industry factors in adopting Subpart TT ru1d, therefore, the 

factors associated with Greif's operations are necessarily "substantially and significantly" 

different. Second, Griefs ability to manage VOM emissions by diluting its QC test fluid and 

limiting the amount of QC test fluid sprayed into each drum is substantially and significantly 

different from factors tl1e Board may have relied on in deciding to require caph.ire and control 

methods for managing VOM emissions. Third, even if Greif could not manage VOM emissions 

by dilution ofthe QC test fluid, the physical design of Greif's operations and the slowevaporation of its QC test fluid are unique factors impacting and significantly limiting Greif's 

ability to capture and control VOM emissions through add-on controls. Fourth, the costs to 

achieve the 81 percent capture and control reqtlirement ofSection218.986(a) would exceed the 

fureshold cost level the Board previously has found to be economically reasonable. 

a. The Board Did Not Consider Factors Involving the Drum 

Manufacturing Business in Adopting Subpart TT. 

Subpart TT of Part 218 is essentially a "catch-all" applicable to VOM sources that are not 

governed by other subparts of Part 218. In adopting Subpart IT, the Board did not consider 

factors relating to any specific industry or practice- including the fiber drmn manufacturing 

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business. Rather, the purpose of Subpart TI wa~ to cover sources that had not othc1wise been 

specifically considered. See 35 Ill. Adm. Code§ 218.980(a) and (b). The Board previously has 

reasoned that, because it did not consider any specific factors in adopting Subpart TT, virtually 

any factors specific to an industry or specific source not otherwise addressed in Part 218 would 

be "substantially and significantly different." See Ford Motor Company (2000), AS 00-6, Slip. 

Op. at 5. 

In Ford Motor Company, the Board considered an adjusted standard petition in which 

Ford sought an alternative emissions control plan to address solvent cleanup operations at its 

Chicago assembly plant. ld. Slip Op. at 1. The Board stated that Subpart TI applies to YOM 

sources with certain characteristics that are not governed by other subparts of Part 218 and, in 

adopting Subpart TI, the Board did not consider factors relating to any specific industry or 

practice. I d. Slip. Op. at 5. The Board then ruled that, because factors relating to Ford's cleaning 

operations were not considered in adopting Section 218 .986( a), the requirement to demonstrate 

significantly different factors "is therefore met." Jd. 

b. Greirs Ability to Manage VOM Emissions Through Dilution 

of its QC Test Fluid and Limitations on the Amount of QC 

Test Fluid Used Constitute Substantially and Significantly 

Different Factors. 

Even if the Board had considered factors impacting the capture and control of YOM 

emissions at drum manufacturers when it promulgated Section 218.986(a), it did not consider 

Greif's unique QC Test Process, the particular complexity of constmcting capture equipment 

over an extended conveyor line or the ability to manage YOM emissions by diluting the QC test 

fluid with water and limiting the amount of QC test fluid applied to each drum. Construction of 

effective capture equipment is further complicated by the need to maintain physical access to the 

drums for visual inspection. This means the conveyor line cannot be totally enclosed to 

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maximize capture. These factors are substantially and significantly different from emission tmits 

where material substitution is not possible and the construction and operation ofemission 

capture equipment is less extensive. 

e. Greirs QC Test Process is Substantially and Significantly 

Different from Other Manufacturing Activities Considered by 

the Board. 

In addition, even assuming, arguendo, that capture and control could be an economically 

reasonable option, Greif's specific system would be complicated by the physical location of 

different production activities within the Naperville plant, the slow evaporation of the testing 

fluid and the need for Greif to inspect drums visually after the QC test fluid has been sprayed 

into the drum. The testing fluid begins to evaporate while being sprayed in the QC spray station. 

Evaporation continues while the drum is being conveyed to and awaiting QC inspection and also 

ai; the dmrns are conveyed from the inspection area to the drum paint oven and, possibly, even 

afterward. Because the lined drums must be accessible for visual inspection by plant staff, 

complete enclosure of the drum conveyor line is not possible. These factors would require large 

capture systems, including a hood at the QC spray station, at the opening of the drum paint oven 

and along the conveyor used to transport the drums from the spray station to the inspection area 

and from the inspection area to the drum oven. See RACT Study at Section 1.0. The need to 

construct and operate a capture system this complex and this large likely was not considered by 

the Board in adopting Subpart TT and will significantly impact Greif's costs to control VOM 

emissions. See irifra at Section II(H)(2). 

d. Costs of Achieving RACT Control Standard Exceed those 

Considered by Board in Setting RACT Standard. 

In addition, as reflected in the RACT Study, feasible technologies to achieve the 81 

percent combined capture and control objective of Section 218.986(a) would require costs per 

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ton of annual VOM removed ranging from $11,667 to $17,672. These costs exceed the threshold 

cost level the Board previously has found to be economically unreasonable. See In the Matter 

of Petition of Forme/ Industries, Inc. for an Adjusted Standard from 35 Ill. Adm. Code. 

2I8.401(a), (b) and (c), AS 00-13, Slip. Op. at 9 (January 18, 2001) (Board granted adjusted 

standard and the Agency agreed that costs of $10,911 - $18,041 per ton of YOM reduced were 

economically unreasonable); Ford Motor Company (2000), Slip. Op. at 5 (citing In re: Petition 

of Louis Berkman, AS 97-5 (Dec. 4, 1997) ajj'd sub nom EPA v. PCB, 308 Ill. App. 3d 741, 746 

& 752-53, 721 N.E.2d 723,726-27 & 731 (2d Dist. 1999) (for proposition that ccsts exceeding 

$1,734 in 1996 dollars per ton of reductions was economically unreasonable); In the Matter of 

Joint Petition of Reynolds Metals Company and the Illinois Environmental Protection Agency for 

an Adjusted Standard from 351AC 2I8.980, AS 91-8 (Sept. 21, 1995) (Board found $40,000 per 

ton of YOM reduced to be economically unreasonable). 

2. The Existence o(These Factors Justifies an Adjusted Standard. 

The intent of the regulations promulgated under 35 Til. Adm. Code Part 218 is to 

implement RACT for VOM emission sources in the Chicago ozone non-attaimnent area. See In 

the Matter of Petition of Ford Motor Company (Chicago Assembly Plant) for an Adjusted 

Standard from 35Ill. Adm. Code 218.986, AS 02-3, Slip. Op. at 4 (November 21, 2002). Greifs 

RACT Study demonstrates that use of the water-diluted test fluid as an adjusted standard reduces 

emissions from the QC Test Process below the applicability threshold for Subpart TT3 and below 

applicable FESOP limits while reducing costs. The existence of these factors demonstrates that 

dilution of the QC test fluid constitutes RACT and justifies the granting of the instant request. 

3 Greif understands that Subpart lT is a "once in-always in" rule. 35 Ill. Adm. Code Section 218.980(c). However, 

the fact that the diluted QC test fluid will bring emissions below the applicability threshold is of some significance 

because the Board certainly did not consider sources with uncontrolled emissions less than the threshold being 

subject to Subpart TI. 

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3. The Requested Standard Will Not Result in Adverse Health Effects. 

The requested adjusted standard will have little, if any, adverse impact on human health 

or the cnvir01m1ent. In 2009, state-wide VOM point source emissions were 54,668 tons. See 

Illinois Annual Air Report at Table C-5 (2010 emission data was not available at the time Greif 

filed its Amended Petition). Thus, even at the maximum pennitted emission levels for the 

Naperville plant (22.8 tpy based on condition 3 of the FESOP), VOM emissions from the QC 

Test Process would amount to less than 0.04% of state-wide point source emissions and only 

0.19% of Metropolitan Chicago emissions. The Board has previously fotmd that adjusted 

standards from Subpmt TT from sources with much higher VOM emission levels would have no 

significant impact on air quality. See, e.g., Alumax, AS 92-13, Slip. Op. at 9; Ford Motor 

Company (2000), AS 00-6, Slip. Op. at 5. 

The Board has granted numerous exemptions to the 81 percent capture and control 

requirement in Subpart TT in cases where the annual VOM emissions that were exempted from 

Section 218.986(a) were signifiCalltly greater than those proposed by Greif See, e.g., Ford 

Motor Co. (2000), AS 00-6, Slip. Op. at 3 (even with uncontrolled emissions of390 tpy of 

VOM, the Board found no significant impact on air quality or human health); Quantum 

Chemical Corporation, AS 92-14, Slip. Op. at 10 (Board agreed that operation of emission units 

resulting in over 260 IPY ofVOM was small compared to the total VOM emissions in the 

Chicago ozone non-attainment area and would have no measurable impact on air quality); 

Alumax, AS 92-13, Slip. Op. at 9 (Board found the foregone emission reductions of76 tpy from 

not achieving 81 percent control would not significantly impact human health). 

Moreover, the Board previously has found that a control plan resulting in an overall 

emissions reduction constitutes a positive environmental impact. See Ford Motor Company 

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(2002), AS 02-3, Slip. Op. at 4. In Ford, the Board fotmd that a 50 tpy reduction ofVOM 

emissions (from 390 tpy to 340 tpy- or 13%) was "significant" and would have a "positive 

impact on air quality." I d. Here, dilution ofthe QC test fluid and limitation on the amount of 

QC test fluid used per drum is producing roughly a 70% reduction ofVOM emissions- an even 

greater reduction on a percentage basis than what was at issue in the Ford petition. 

4. The Requested Standard is Consistent with Federal Law. 

Section 110 of the federal Clean Air Act, 42 U.S.C. § 7410, grants individual states the 

authority to promulgate a plan for implementation, maintenance and enforcement of air quality 

standards, subject to approval by USEP A. Based on the RACT Study, the proposed adjusted 

standard constitutes RA CT for the Greif facility, and is therefore consistent with the federal 

Clean Air Act. A state may revise its SIP, again subject to USEPA approval. 42 U.S.C. § 7410. 

Greif will work with the Agency to submit a SIP revision to USEPA that is consistent with any 

adjusted standard granted by the Board. 

J. Hearing-Section 104.4060) 

Greif requests a heruing in this matter. 

K. Supporting Documentation- Section! 04.406{k) 

1. RACT Study, attached to this Petition as Exhibit A. 

2. FOIA Response from illinois Environmental Protection Agency, Bureau 

of Air, attached to this Petition as Exhibit B. 

III. CONCLUSION 

Greif requests that the Board grant the proposed adjusted standard as an altemative to the 

RACT regtJlations adopted by the Board in Subpart IT. To require Greif to comply with the 

requirements of35 ill. Adm. Code Subpart TT, Section 218.986(a), would result in substantial 

economic hardship to Greif with no corresponding environinental benefit. Certain compliance 

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Electronic Filing - Received, Clerk's Office, 05/31/2011 

options examined by Greif could have the reverse effect of creating increased emissions of other 

pollutants and envirorunental detriment. Finally, add-on controls arc unreasonably expensive, 

provide little, if any, envirorunental benefit and certain control options may result in increased 

health and safety risks. 

WHEREFORE, Greif, Inc. requests that the Board grant Greif the proposed adjusted 

standard from 35 Jll. Adm. Code, Subpart IT, Section 218.986(a), as that rule applies to the 

emissions ofVOM from Greif Packaging LLC's operations in Naperville, Illinois. 

Respectfully submitted, 

GREIF, INC. AND 

GREIF PACKAGING LLC 

By: Is/ Susan Charles 

Thomas W. Dimond 

Susan Charles 

ICE MILLER LLP 

200 West Madison Street 

Chicago, Illinois 60606 

312-726-1567 

May 31,2011 

26 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

REASONABLY AVAILABLE 

CONTROL TECHNOLOGY 

STUDY 

Prepared for: 

G~IF 

Naperville, I L 

August 2010 

Revised: March 2011 

Exhibit A 

Prepared by: 

TCP 

Itasca, IL 
Electronic Filing - Received, Clerk's Office, 05/31/2011 

REASONABLY AVAILABLE CONTROL TECHNOLOGY 

STUDY 

Prepared for: 

G~IF 

55220 Frontenac Road 

Naperville, IL 60653 

Prepared by: 

TCP 

Thomas C. Ponder, Jr. PE 

Consulting Engineer 

56 Bay Drive 

Itasca, Illinois 60143 

TCP Project No. 8003 

August 2010 

Revised: March 2011 
Reasonabt~l~l?JbPe'C:b~ fojLjpJJnol~f§t,m,ved, Clerk's Office, 05/31/2011 

August 2010: Revised March 2011 

Table of Contents 

Page 

1.0 Summary ..................................................................................................... 1-1 

2.0 Facility information ....................................................................................... 2-1 

3.0 Control Technologies ................................................................................... 3-1 

3.1 Capture Systems .............................................................................. 3-1 

3.2 Add-on Control Technologies ............................................................ 3-1 

3.2.1 Recuperative Thermal Incinerators ....................................................... 3-1 

3.2.2 Carbon Adsorbers ................................................................................... 3-1 

3.2.3 Biofilter .................................................................................................... 3-2 

3.3 Potential Equivalent Alternative Control Plans .................................. 3-2 

3.3.1 QC Test Fluid- Dilution with Water ..................................................... 3-2 

3.3.2 QC Test Fluid- Dilution with Acetone .................................................. 3-3 

4.0 Control costs ................................................................................................ 4-4 

4.1 Capital Costs .................................................................................... 4-4 

4.2 Annual Costs ..................................................................................... 4-4 

4.3 Reasonably Available Control Technology Costs ............................. 4-5 

4.4 Comparing RACT to the Naperville Control Systems ........................ 4-5 

APPENDIX A 

APPENDIX 8 

TCP Project No. 8003 

CAPITAL AND ANNUAL COSTS FOR THERMAL 

OXIDIZER WITH RECUPERATIVE HEAT EXCHANGER 

CAPITAL AND ANNUAL COSTS FOR CARBON 

ADSORBER 

ii 
R bl Flectronic FJ"Iina -

1

Received, Clerk's Office, 05/31/2011 easona jAvm?abfe -contra 1 eCHno ogy study 

August 2010: Revised March 2011 

LIST OF TABLES 

Page 

Table 1·1 Costs ofVOM Control ($/ton) 1-3 

Table 4-1 Control Cost Comparisons Naperville RACT Study 4-3 

TCP Projecl No. ROOJ iii 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

1.0 SUMMARY 

This study was undertaken to evaluate the reasonably available control technologies 

(RACT) options that could be implemented at the quality control (QC) testing process 

emission unit of the Greif Packaging LLC (Greif) fiber container facility in Naperville, 

Illinois. The options are being considered to dete1minc if the 81% combined capture and 

control requirement of35 IAC 218.986 is technically achievable and economically 

reasonable for the QC testing process emission unit and, if not, to identify equivalent 

altemative control plans that would constitute RACT for this emission unit. 

Section 218.986 requires emission units subject to its requirements to achieve an overall 

reduction in w1controllcd YOM emissions of at least·81 percent through the application 

of emission capture and control equipment. Capture technology would involve a 

combination of pen11anent total enclosures and exhaust hoods designed to achieve at least 

90 percent capture ofVOM at the QC testing process. The following control equipment 

options were eval?ated for potential implementation in connection with 90 percent 

capture methodology: 

• Recuperative them1al incinerator 

• Carbon adsorber 

• Biofilter 

In addition, the following methods ofVOM emission reduction were evaluated as 

possible equivalent alternative control plans: 

• Dilution of the QC testing process fluid (a mixture of solvents, primarily 

denatured alcohol) with water 

• Dilution of the QC testing process fluid with acetone (a non-VOM material) 

The recuperative thermal incinerator, biofilter, carbon adsorption, and QC testing fluid 

dilution options were completely evaluated. Dilution of the testing fluid with acetone 

was determined to be teclmically infeasible. Acetone, does not work at Naperville since 

it causes the gasket material which seals the bottom of the drum to the drum walls to 

dissolve. Due to this problem with product damage, diluting the QC test ·fluid with 

acetone was detem1ined to be infeasible. 

Capture of emissions from the QC test process is complicated by slowly evaporating 

solvents in the testing fluid and the need for employees to inspect each drum visually 

TCP Project No. 8003 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

after the QC test fluid has been sprayed into the dnnn. Currently the drums are sprayed 

and inspected at the QC test station. Then the drums are conveyed approximately 160 feet 

to the drum paint oven to insure that the test fluid completely evaporates. So, the QC test 

process requires capture of emissions at the QC test station, itself, the conveyors, and the 

dnnn paint oven. This is a very complicated capture system that requires tunnel 

enclosures arotmd the conveyors. The QC test process station must be enclosed and tbe 

opening to dmm paint oven must be reduced to ensure the desired 90 percent capture of 

the emissions. The control system requires both enclosures of the process and dueling to 

the control device. Uniform capture is difficult when system components include a spray 

station, a test inspection station, tunnel hoods, and an oven. The estimated airflows for 

each step in the pmcess are as follows: 

• Spray station- 3,000 ACFM 

• Tutmel to Inspection Station- 2,000 ACFM 

• Inspection Station- 5,000 ACFM 

• Tunnel to Drying Oven- 5,000 ACFM 

• Drying Oven- 5,000 ACFM 

The total flow to the control device is estimated to be 20,000 ACFM to ensure adequate 

capture to meet the overall 81% control objective. Each ventilation system was designed 

for a face velocity of 150 feet per minute to attain adeqtlate capture. The spray station 

would have an opening offour feet by five feet on the hood over the spray station. The 

inspection station would bave an opening of six feet by five and balffeet to allow access 

by the inspectors. The conveyor from the spray station to the inspection booth is 45 feet. 

Asstuning a hood clearance of two inches on each side of the dnun requires 2,000 ACFM 

of ventilation to maintain the 150 feet per minute face velocity. The conveyor from the 

inspection station to the oven is 120 feet. A ventilation rate of 5,000 ACFM will maintain 

a face velocity of150 feet per minute. The ventilation rate of the drying oven is 5,000 

ACFM. 

Because of the difficttlties with the capture system, the air flow rate to the control device 

will necessarily be high. This creates the need for larger control systems, which impacts 

costs. As reflected in Table 1-1, the costs ofVOM control stated in terms of dollars per 

ton of annual VOM reduction range from $11,167 to $17,672. This range of control costs 

is higher than the level of costs considered to be economic in adopting RACT controls. 

TCP Project No. 8003 2 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Table 1-1 Costs ofVOM Control ($/ton) 

Control Option Cost of VOM Control ($/ton) 

Recuperative Thermal Oxidizer (20,000 acfm) 17,672 

Carbon Adsorber (20,000 acfm) 11,667 

Biofilter (20,000 acfm) & Water Diluted Solvent 11,167 

Water Diluted solvent -541 

In addition, all control systems for the reduction ofVOM emissions have inherent 

characteristics that would partially offset the envirornnental benefits ofVOM reduction. 

Thermal oxidizers use large quantities of natural gas. Fuel will be used even when the QC 

test process is not operating to maintain the thennal oxidizer at temperature. Frequent 

operation cycles in thennal oxidizers cause condensation corrosion and thermal 

deterioration of the insulation. Thennal oxidizers emit NOx and CO and small quantities 

ofVOM and HAPS are also emitted. These emissions will partially offset any benefits 

obtained from VOM reduction. Carbon adsorbers also have drawbacks. Since all of the 

solvents used in the QC test process are water soluble, the used solvents can not be 

recovered from the carbon adsorbers without an elaborate distillation system. Given these 

difficulties, the condensed regeneration fluid is commonly discharged with wastewater to 

the sewers. Depending on the type of treatment system at the municipal treatment facility, 

the VOM may not be biodegraded but simply blown into the atmosphere in an 

equalization basin, In that case, VOM emission reductions at the facility will be offset by 

higher emissions at the treatment facility. Biofilters must be heated to maintain 

destruction activity during winter months. Heat for the biofilter can be supplied by the 

direct combustion of natural gas, steam, or electricity. Natural gas combustion would 

increase NOx emissions from the facility. In addition, the large size of these units may 

limit feasible locations at a facility. Also, the biofilter cannot achieve the 81% control 

objective by itself and would require an additional control system or the counting of the 

QC test fluid dilution as a control technology to achieve that objective. 

In contrast, diluting the QC test fluid with water has been calculated to reduce annual 

emissions ofVOM below the 25 tons per year (tpy) threshold for applicability of Section 

218.986 at a reduced cost from pre-dilution operations. Based on this analysis, 

conversion to the diluted QC test fluid achieves RACT control for this emission unit and 

TCP Project No. 8003 3 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

should be approvable as an equivalent altemative control plan in place of the 81% capture 

and control requirement of Section 218.986(a). 

TCP Project No. 8003 4 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

2.0 FACILITY INFORMATION 

Greif operates a fiber container manufacturing facility in Naperville, Illinois. The primary 

activity involves the cutting of fiber material into appropriate lengths, molding the shapes 

into a drum and connecting tops and bottoms to the dmm sides. YOM emissions are minimal 

in the actual drum making operation. Emissions occur during the application of caulk, silk 

screening of inf01mation onto the drum, and in drum painting .. Combined YOM emissions 

from all these units are currently pennitted at a maximum of 1.4 tpy, and Greif has proposed 

increasing the emissions from those units to an aggregate of2.6 tpy. Under 35 IAC 

218.980(d), theseunits·are exempt from the requirements of Section 218.986 becatJse no 

single unit emits greater than 2.5 tpy ofYOMs and the aggregate emissions from the other 

units does not exceed 5 tpy. 

Some ofthe fiber dnnns manufactured at Naperville are required by customers to have 

polyethylene liners, primarily to comply with requirements for food grade containers. Drums 

with these liners must be tested to ensure that the liner is free from pinholes or other tears or 

imperfections. The QC Test Process emission unit involves the spraying of a YOMcontaining liquid onto the polyethylene liner, which causes imperfections in the liner to 

become visible to the naked eye and detectable to plant personnel who inspect each of the 

lined drums as it proceeds through the process on a conveyor belt. At the Naperville plant, 

only the QC Test Process emission unit emits significant quantities of YOM emissions. 

Emissions from the QC Test Process are currently permitted at 22.8 tpy, and Greif has 

proposed to reduce those emissions to a maximum of 21 tpy. Accordingly, tllis study only 

assesses RACT options for the QC Test Process emission unit. 

TCP Project No. 8001 I 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

3.0 CONTROL TECHNOLOGIES 

Brief descriptions of the capture and control systems evaluated for this study are given in the 

following sections. 

3.1 Capture Systems 

Due to the slow evaporation rate of the QC test fluid, the need to achieve adequate emission 

capture to achieve overall 81% control adds to the VOM control costs. A total tunnel enclosure 

will be required for the conveyor from the QC test process spray station to the drum paint oven. 

Enclosures will be added to the hood at the QC test process spray station and the opening of the 

drum paint oven to ensure adequate capture will be achieved. Ducting to the control device will 

be required from the QC test process hood, the conveyor tunnel enclosure and the dmm paint 

oven. This complicated system is hard to balance so that adequate capture is achieved. The 

capital and rumual operating costs for the dueling and enclosure systems are included with each 

control system. 

3.2 Add-on Control Technologies 

Recuperative thermal oxidizers, carbon adsorbers, and biofilters were the control systems 

evaluated. 

3.2.1 Recuperative Thermal Incinerators 

Recuperative thermal incinerators tJSe a heat exchanger to capture the exhaust heat and transfer 

the heat to incoming gases. Less natural gas is needed to boost the combustion temperatures to 

1600°F to ensure complete destruction of the VOMs. This system has heat recovery as great as 

60%. The primary advantages of this control system are lower annual costs relative to other 

incinerators and flexibility in handling a range of VOM materials. The primary disadvantages of 

this control system relative to other control options are higher operating costs due to the amount 

of natural gas that is consumed and the resulting increase in emissions ofNOx. 

3.2.2 Carbon Adsorbers 

Carbon adsorbers are used to control systems with low to medium VOM concentrations. 

Normally, a carbon adsorber consists of two or more beds of activated carbon. One bed is 

treating the exhaust emissions while the other bed is being regenerated. Large systems may have 

several beds on stream while a bed is being regenerated. Carbon adsorbers work best with 

insoluble VOMs, which simplify the recovery of the VOM materials. In some cases, distillation 

is required to separate the VOM materials from the regeneration sterun. Since all the VOM used 

in the QC testing process is water soluble, it would be very expensive to recover the denatured 

TCP rroject No. 8003 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

alcohol from the regeneration fluid. The waste steam would most likely be sent to a local 

sewage disb·ict along with wastewaters since most sewer districts will allow facilities to 

discharge water soluble solvents that are not chlorinated. However, most sewer districts use 

equalization basins to reduce YOM (BOD) loading by blowing solvents into the abnosphere. 

TI1erefore, YOM emissions may not truly be reduced with carbon beds but only the emission 

source changed. Due to the presence of ketones in the denatured alcohol, there is also an 

inherent risk of fires from reactions between the ketones and the carbon in the beds. Carbon beds 

that handle ketones require water deluge systems to control bed fires. 

3.2.3 Blofilter 

Biofilters can be used to reduce YOM emissions without the use of natural gas to bum the 

hydrocarbons. Biorem has proposed to install a biofilter for odor control on the Greif drum plant 

in Oakville, Ontario. In this process, YOM is reduced by 70 percent by the biofilter media. 

Biorem would achieve 95% control by adding a carbon adsorber after the biofilter media. At 

Naperville, the 81% control objective could be met only by combining the biofilter with another 

control technology or by considering the reductions in YOM emissions from the use of the water 

diluted test fluid as a capture and control technology reduction. This system has lower operating 

costs although the capital costs are comparable to incinerators. Biofilters must be heated to 

maintain destruction activity during winter months. Heat for the biofilter can be supplied by the 

direct combustion of natural gas, steam, or electricity. Natuml gas combustion would increase 

NOx emissions from the facility. 

3.3 Potential Equivalent Alternative Control Plans 

3.3.1 QC Test Fluid- Dilution with Water 

Naperville experimented with changing the QC testing process fluid from 100% denatured 

alcohol to a mixture of denatured alcohol and water. The goal of the experiment was to reduce 

the proportion of denatured alcohol to the greatest extent possible, which would achieve 

corresponding reductions in YOM emissions, while maintaining the ability to visually detect 

imperfections in the drum linings. 

The experiment was conducted in the following general manner. Using a sharp point awl,. 

pinholes would be made in the side and bottom of liners of five drums prior to sending them 

through the QC Test Process. The drums would then be sprayed in the QC Test Process and 

visually inspected on the conveyor system to deten11ine if the pinholes could be detected in an 

acceptable time period. Under nonnal operations, it takes a drum about 70 seconds to move on a 

conveyor system from the QC Test Process spray system to the location where the drums are 

inspected. If the pinholes could be detected, the test was considered successflll and the fluid 

TCP Project No. 8003 2 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

used for the test considered acceptable. If the pinholes could not be detected, the test was 

considered a failure and unable to meet the product quality assurance standards required by 

Greif's customers. 

The first altemative test fluid consisted of 80% denatured alcohol and 20% water. At this 

mixture, plant personnel were able to detect the pinholes in all five test dmms within about 5 

seconds. The expe1iment was repeated with a test fluid consisting of 70% denatured alcohol and 

30% water. As with the first test fluid, this second mixture allowed the detection of all pinholes 

in the five test dmms, although they were only detectable after 7 seconds and the staining around 

the holes was noticeably lighter than with the 80/20 mixture. Similar tests were conducted with 

mixtures of 50% denatured alcohol/50% water, then 40% denatured alcohol/60% water and 

finally 45% denatured alcohol/55% water. With the 50/50 mixture, all pinholes were detected 

within 45 seconds, although the staining was much lighter than with mixtures containing more 

alcohol. The test using the 40/60 mixture failed. All of the pinholes were not visible when the 

drums reached the inspector station. Continued observation of these dmms from the inspector 

station to the drying oven revealed that the pinholes did not even become visible by the time the 

drum reached the drying oven. The test using the 45/55 mixture allowed the detection of all 

pinholes within 60 seconds after spraying, although as noted above the staining around the 

pinholes was significantly lighter than with mixtures containing more alcohol. Based on these 

test mns, the plant detennined that 55% dilution with water was the highest dilution percentage 

that would still allow the plant to meet its product quality assurance requirements. To date, the 

diluted test fluid has been able to allow the detection of drums with defects in the polyethylene 

liner. TI1is diluted test fluid is less expensive than the previously used test fluid consisting of 

I 00% denatured aleohol. 

After determining that the 45/55 QC test fluid mixture could satisfy appropriate QC 

standards, Greif conducted additional tests to dctem1inc whether the amount of QC test fluid 

applied to each dmm could be reduced. Based on this testing, Greif determined that it could 

reduce the QC test fluid sprayed into each drwn to an an1ount not to exceed 48 grams. Diluting 

the QC test fluid with water and reducing the amount of QC test fluid used results in an 

approximate 70% reduction in emissions on a per drwn basis. 

3.3.2 QC Test Fluid- Dilution with Acetone 

Another option to achieve reduction _in VOM emissions would be to dilute the current QC test 

fluid with acetone or switch to acetone as an entire substitute because acetone is a non-VOM 

solvent. Tests by facility personnel determined that acetone, even when diluted, may dissolve 

tl1e gasket that binds the bottom of the fiber drum to the walls of the drum. For that reaso11, this 

alternative was deemed by the facility to be infeasible for full implementation. 

TCP Project No. BOOJ 3 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

4.0 CONTROL COSTS 

TI1e capital and annual cests for different centro! options are shown in Table 4-1. Capture 

(dueling and enclosures) costs are included in the capital and operating costs of each of the three 

control systems evaluated. The complete cost aoalysis of the recuperative thennal oxidizer 

control systen1 is shown in Appendix A. The complete cost analysis of the carbon udsorber 

control system is shown in Appendix B. The cost for the bio.filter was scaled to the projected 

biofilter size for the Naperville facility based on the bid received for the installation at the 

Oakville, Ontario facility. In addition, the cest analysis for the biofilter option assumes the 

diluted QC test fluid can be treated as a control teclmology because adding a carbon adsorber 

would dramatically increase the cost per ton ofVOM controlled. 

4.1 Capital Costs 

The procedures for estimating capital cests for pollution capture and centro! equipment generally 

follow the procedures developed by the United States Enviromnental Protection Agency (EPA). 

Specifically for this shtdy, the infmmation used to develop the capital costs were derived from 

"Estimating Costs of Air Pollution Control" by William Vatavuk. Using algorithms in the book, 

cests for the capture and control equipment were determined. After detetmining equipment 

costs, cests for auxiliary equipment such as fans, ductwork, and a stack were calculated. It was 

assumed that the control equipment would be too heavy to mount on the roof, so the centro! 

systems would be located on the ground near the QC testing process. Once the costs of the 

capture aod control equipment and auxiliary equipment were determined, they were used to 

develop direct installation cests for such things as foundations, electrical work, erection, 

insulation, painting, and support facilities. Indirect cests such as engineering, construction 

maoagement, centractor fees, and testing were added to the direct installation costs. 

Contingency costs were added to total installation costs in order to determine the total project 

cost for each centro! option. 

4.2 Annual Costs 

Annual costs also follow the EPA guidelines. Items for direct operation of the capture and 

control equipment such as electricity, natural gas, operating labor, and maintenance are 

determined based on the capture and control equipment requirements. Indirect costs such as 

plant overhead, taxes, aod insurance are added to the costs. Capital recovery is a method for 

recovering the cost of money used to finance the project and detennining the depreciation of the 

equipment. Although there are other methods for determining these costs, capital recovery is 

used by EPA in RACT analysis in dete1111ining the cost per ton of pollutants centrolled. 

TCP Projrel No. 8003 4 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Annual costs for diluted QC testing fluids are based on a $3.16/gallon cost for the 55% diluted 

testing fluid versus $4.84/gallon for the undiluted denatured alcohol. A cost savings occurs since 

the water-reduced solvent is lower cost than the all solvent test fluid. 

4.3 Reasonably Available Control Technology Costs 

Section 218.986 requires emission units subject to its requirements to achieve an overall 

reduction in uncontrolled VOM emissions of at least 81 percent through the application of 

emission capture and control equipment. In adopting that requirement, the Illinois Pollution 

Control Board considered a level of cost per ton of estimated VOM reductions that would 

typically be incurred to achieve the 81% standard. In 1996 dollars, the Board's RACT cost 

threshold was a maximwn of$1,734 per ton ofVOM controlled. In re: Petition of Louis 

Berlanan, AS 97-5 (Dec. 4, 1997) aft'd sub. nom. EPA v. PCB, 308 Til. App. 3d 741,746 & 752-

53 (2d Dist. 1999). 

4.4 Comparing RACT to the Naperville Control Systems 

A review of the costs in Table 4-1 indicates that all of the add-on control systems and their 

associated capture system upgrades cost much more thim the RACT. Control costs range from 

$11,667 to $17,672 per ton ofVOM controlled. 

In addition, all control systems for the reduction ofVOM emissions have inherent characteristics 

that would patiially offset the enviromnental benefits ofVOM reduction. Thermal oxidizers use 

large quantities of natural gas. Fuel will be used even when the QC test process is not operating 

to maintain the thermal oxidizer at temperature. Frequent operation cycles in thermal oxidizers 

cause condensation corrosion and thermal deterioration of the insulation. Thermal oxidizers emit 

NOx and CO and small quantities ofVOM and HAPS are also emitted. These emissions will 

partially offset any benefits obtained from VOM reduction. Carbon adsorbers also have 

drawbacks. Since all of the solvents used in the QC test process are water soluble, the used 

solvents cannot be recovered from the carbon adsorbers without an elaborate distillation system. 

Given these difficulties, the condensed regeneration fluid is commonly discharged with 

wastewater to the sewers. Depending on the type of treatment system at the municipal treatment 

facility, the VOM may not be biodegraded but simply blown into the atmosphere in an 

equalization basin. In that case, VOM emission reductions at the facility will be offset by higher 

emissions at the treatment facility. Biofilters must be heated to maintain destruction activity 

during winter months. Heat for the biofilter can be supplied by the direct combustion of natural 

gas, indirect steam heat, or electric heaters. Natural gas combustion would increase NOx 

emissions fi·om the facility. In addition, the large size of these units may limit feasible locations 

at a facility. Also, the biofilter cannot achieve the 81% control objective by itself and would 

TCP Project No. 8003 5 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

require an additional control system or the counting of the QC test fluid dilution as a control 

technology to achieve that objective. 

In contrast, diluting the QC test fluid with water has been calculated to reduce annual emissions 

of VOM below the 25 tons per year (tpy) threshold for applicability of Section 218.986 at a 

reduced cost from pre-dilution operations. Based on this analysis, conversion to the diluted QC 

test fluid achieves RACT control for this emission unit and should be approvable as an 

equivalent alternative control plan in place of the 81% captme and control requirement of 

Section 218.986. 

TCP Projecl No. 8003 6 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Table 4-1 Control Cost Comparisons - Naperville RACT Study 

Control Options Controlled Uncontrolled Uncontrolled Controlled Controlled Total Total Total COst per Ton c 

acfm VOM lblyr VOMTPY Capital capital Annual VOM VOMTPY VOM lb/yr Cost,$ Cos I, Cost, S Controlled, $ 

$/acfm 

Projected Emissions with -- 89,840 44.92 0 0 0 0 ---- --- undiluted QC Test Fluid 

QC Test Fluid Diluted with Water -- 89,840 44.92 49,412 31.44 0 0 -17,000 -541 

Recuperative Thermal Oxidizer 20,000 89,840 44.92 72,770 36.39 1,752,000 87.60 679,000 17,672 

Carbon Adsorber 20,000 89,840 44.92 72,770 36.39 1 '170,000 58.50 - 458,000 12,594 

Biofilter & Diluted QC Test Fluid 20,000 89,840 44.92 74,880 37.44 1,800.000 90.00 437,000 11,667 

-
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Appendix A 

Capital and Annual Costs for Thermal oxidizers with 

Recuperative Heat Exchangers 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Recuperative Incinerator Costs - 20000 acfm 

(All costs are in, or have been adjusted to, 1212009dollars) 

-- Base Date: 

--Analysis Date: 

- Escalation Factor. 

COST INDEXES 

370.3 (September, 1988) 

618.4 (December, 2009) 

1.670 (Anatys'1s/Base) 

[CE Plant Index/Equipment] 

(CE Plant Index/Equipment] 

[calculated] 

GAS STREAM and EMISSION PARAMETERS 

-- Inlet stream flowrate (acfm): 

--Inlet stream temperature (oF): 

--Standard temperature (oF): 

20,000 Estimated 

70 Greif Permit 

60 [Engineering judgment] 

[1] 

- Uncontrolled Emissions, lb/yr 

--Controlled emissions: lblyr (81 %) 

89,840 Calculated from emission inventory 

17069.6 (calculated] 

RECUPERATIVE INCINERATOR COSTS 

If flow is < 5000 scfm, then use: 

Heat Exchanger Efficiency = 70%, a= 5,690, b = 0.408, P =Price, Q = flow rate 

Then P($) = aQAb 

NOTE: THIS EQUATION FOR 70% WAS USED FOR ALL FLOWS. 

- Recuperative Incinerator: $ 323,543 

TOTAL CAPITAL INVESTMENT 

-- Recuperative Incinerator: $ 323,543 [Estimating Costs of Air Pollution Control--calculated] 

-Fan: 

-Enclosure: 

-Ductwork: 

- Instrumentation: 

32,354 [Estimating Costs of Air Pollution Control-calculated] 

129,417 (Estimating Costs of Air Pollution Control-calculated) 

64,709 (Estimating Costs of Air Pollution Control-calculated] 

48,532 [Estimating Costs of Air Pollution Control-calculated) 

Subtotal, equipment: $ 598,555 [ca/cu/ateq) 

Purchased Equipment Cost (PEC): $ 706,295 [calculated] 

' " " "-escalated: $ 1,179,511 [calculated] 

Direct installation costs: $ 294,878 [Estimating Costs of Air Pollution Control-calculated) 

Indirect installation costs: $ 117,951 [Estimating Costs of Air Po/lu1"1on Control-calculated] 

Subtotal, installation: $ 412,829 [calculated] 

Retrofit factor: 1.1 [Engineering judgment) 

TOTAL CAPITAL INVESTMENT($): $1,751,574 [calculated] 

($/acfm): 87.6 [calculated) 

================================================================================== 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Operating factor (hr/yr): 

Operating labor rate ($/hr): 

Supervising Labor factor 

Maintenance labor rate ($/hr): 

Maintenance Materials factor 

Operating labor factor (hr/sh): 

Maintenance labor factor (hr/sh): 

Natural Gas Usage,scfh 

Natural Gas Price, $/MMBtu 

Electricity usage, kWh: 

Electricity price ($/kWhr): 

Annual interest rate (fraction): 

Control system life (years): 

Capital recovery factor: 

Taxes, insurance, admin. factor: 

Overhead factor: 

Item 

Operating labor 

Supervisory labor 

Maintenance labor 

Maintenance materials 

Electricity 

Natural Gas 

Overhead 

Tax,ins.,adm 

Gap. recov. 

TOTAL ANNUAL COST: 

Tons of VOC controlled 

Cost per ton of VOC Controlled 

ANNUAL COSTS 

2,000 [calculated] 

28.50 Estimated 

0.15 [EPA Control Cost Manual] 

22.00 Estimated 

1. 00 Estimated 

0.50 [EPA Control Cost Manual] 

0. 50 [EPA Control Cost Manual) 

440.0 Calculated (based on ratio to flow) 

5. 00 Estimated 

7.00 Calculated (based on ratio to flow) 

0.090 Estimated 

0.08 [OMB Guidelines) 

20 [EPA Control Cost Manual] 

0.1019 [calculated] 

0.04 [EPA Control Cost Manual] 

0.06 [EPA Control Cost Manual] 

Cost ($/year) 

14,250 [calculated] 

2,138 " 

175,157 " 

175,157 " 

1,260 

4,576 " 

22,002 " 

70,063 " 

178,402 " 

$ 643,005 " 

36.39 

$17,672 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Appendix B 

Capital and Annual Costs for Carbon Adsorbers 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

Carbon Adsorbers - Naperville, Ohio - 20000 acfm 

(All costs are In, or have been adjusted to, 1212009 dollars) 

-- Base Date: 

--Analysis Date: 

- Escalation Factor: 

COST INDEXES 

370.3 (September, 1988) 

618.4 (December, 2009) 

1.670 (Analysis/Base) 

[CE Plant Index/Equipment] 

{CE Plant Index/Equipment] 

[calculated] 

GAS STREAM and EMISSION PARAMETERS 

--Inlet stream flowrate (acfm): 

··Inlet stream temperature (oF): 

·- Slandard temperature (oF): 

20,000 Estimated 

70 Greif Permit 

60 [Engineering judgment] 

[1 1 

•• Uncontrolled Emissions, lb/yr 

-Controlled emissions: lb/yr (81%) 

89,840 Calculated from emission inventory 

17069.6 {calculated] 

CARBON ADSORBER COSTS 

If the carbon weight is between 350 and 14,000 pounds then use: 

Then P($) = 32.8 0Ncl"'"0 

The carbon volume at Naperville Is 400 ft3 

If the carbon density is 28.8 pounds per cubic foot: then the weight of the carbon is 

400'28.8= 11520 pounds 

where P($) is the equipment price and W, is the weight of the carbon. 

- Carbon Adsorber in stainless steel: $ 204,058 

TOTAL CAPITAL INVESTMENT 

•• Carbon Adsorber: 

··Fan: 

- Enclosure: 

-Ductwork: 

-Instrumentation: 

$ 204,058 {Estimating Costs of Air Pollution Control--calculated] 

20,406 [Estimating Costs of Air Pollution Control-calculated] 

81,623 [Estimating Costs of Air Pollution Control--calculated] 

40,812 [Estimating Costs of Air Pollution Contro~-calculated] 

30,609 [Estimating Costs of Air Pollution Control--calculated] 

Subtotal, equipment $ 377,507 (calculated] 

Purchased Equipment Cost (PEC): $ 471,883 [calculated] .. .. '

1

-escalated: $ 788,044 [calculated] 

Direct installation costs: $ 197,011 [Estimating Costs of Air Pollution Control--calculated] 

Indirect installation costs: $ 78,804 [Estimating Costs of Air Pollution Control--calculated] 

Subtotal, installation: $ 275,815 (calculated] 

Retrofit factor. 1.1 [Engineering judgment] 
Electronic Filing- Received, Clerk's Office, 05/31/2011 

TOTAL CAPITAL INVESTMENT($): 

($/acfm): 

$1,170,245 [calculated] 

58.5 [calculated] 

=============~=====================================================~============= 

Operating factor (hr/yr): 

Operating labor rate ($/hr): 

Supervising Labor factor 

Maintenance labor rate ($/hr): 

Maintenance Materials factor 

Operating labor factor (hr/sh): 

Maintenance labor factor (hr/sh): 

Steam Usage,pounds per hour 

Steam Price, $/1000 pounds 

Electricity usage, kWh: 

Electricity price ($/kWhr): 

Annual interest rate (fraction): 

Control system life (years): 

Capital recovery factor: 

Taxes, insurance, admin. factor: 

Overhead factor: 

Item 

ANNUAL COSTS 

2,000 [calculated] 

28.50 

0.15 [EPA Control Cost Manual] 

22.00 Estimated 

1.00 Estimated 

0.50 [EPA Control Cost Manual] 

0.50 [EPA Control Cost Manual] 

2000.0 Calculated (based on ratio to flow) 

12.00 Estimated 

17.30 Calculated (based on ratio to flow) 

0.080 Estimated 

0.06 [OMB Guidelines] 

20 [EPA Control Cost Manual] 

0.1019 [calculated] 

0.04 [EPA Control Cost Manual] 

0.06 [EPA Control Cost Manual] 

Cost ($/year) 

-------------------------------------------------------------------------------------

Operating labor 

Supervisory labor 

Maintenance labor 

Maintenance materials 

Electricity 

Steam 

Overhead 

Tax,ins.,adm 

Cap. recov. 

14,250 

2,138 

117,025 

117,025 

2,768 

24,000 

15,026 

46,810 

119,192 

[calculated] 

" 

" 

" 

" 

" 

------------------------------------------------------- TOTAL ANNUAL COST: $ 458,233 " 

Tons of VOC controlled 36.39 

Cost per ton of VOC Controlled $12,594 
Page I of 1 

Electronic Filing- Received, Clerk's Office, 05/31/2011 

Charles, Susan 

From: BOA, EPA.FOIA [EPA.FOIA.BOA@IIIinois.gov] 

Sent: Wednesday, September 08, 2010 4:10PM 

To: Charles, Susan 

Subject: RE: FOIA Request- Susan Charles 9/312010 3:11:35 PM 

Dear Ms. Charles, 

Here are the annual facility-reported VOM emissions in tons per year for the Chicago area as requested. 

2004 2005 

17,005 16,622 

Sincerely, 

FOIAUnit 

Bureau of Air 

2006 2007 

15,928 15,691 

Illinois Environmental Protection Agency 

----Original Message--

2008 2009 

14,119 11,884 

From: Susan Charles [mailto:Susan.Charles@icemiller.com] 

Sent: Friday, September 03,2010 3:12PM 

To: BOA, EPA.FOIA 

Subject: FOIA Request- Susan Charles 91312010 3:11:35 PM 

Following information submitted for FOIA request: 9/3/2010-3942225 

Request for information was routed to: 

Bureau of Air- Unit- 217/524-5683- 217/524-5023(FAX) 

From: Ms. Susan Charles 

Organization: Ice Miller LLP 

Organization Type: Legal Consullant 

Location: 200 W. Madison Street 

Chicago, IL. 60606 

Cook 

Phone: (312) 726-7146 

Fax: (312) 726-7102 

Susan.Charles@lcemiller.com 

Subject Matter: Metropolitan Chicago Interstate Air Quality Contra 

Specific information requested from: Bureau of Air- Unit- 2171524-5683- 217/524-5023(FAX) 

Date From: 2004 To: 2009 

Most Recent: Yes 

Other Information: Please provide annual emissions data (in aggregate tons per year) of Volatile Organic Material 

("VOM") from point sources in the Metropolitan Chicago Interstate Air Quality Control Region. Please provide 

data for calendar years 2004- 2008 and, to the extent available, 2009. 

Fee Waiver/Reduction Justification: Not Applicable 

--end of requestExhibit B 

1124/2011