### 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: AS
____ _ PETITION OF GREIF PACKAGING, LLC FOR AN ADJUSTED STANDARD FROM 35 ILL ADM. CODE PART2I8 SUBPART 

### IT ) ) ) 

### ) ) 

### ) (Adjusted Standard- Air)
NOTICE OFELECfRONIC FILING TO: 

# ·-**---~Jehn-Therriault,-Gler-k------------Divisien-ef-begal-Geunsel--------** 

### Illinois Pollution Control Board Illinois Environmental Protection Agency James R. Thompson Center I021 North Grand Avenue East I00 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 ofthe Clerk ofthe Illinois Pollution Control Board, Petitioner's NOTICE OFELECTRONIC FILING, NOTICE OFAPPEARANCE, PETITIONFOR AN ADJUSTED STANDARD and CERTIFICATE OF SERVICE, copies ofwhich are attached herewith served upon you.

Date: January 24, 20II 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 ofits Attorneys

### Electronic Filing - Received, Clerk's Office, January 24, 2011 * * * * *AS 2011-001 * * * * *
BEFORETHE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF: PETITJON OF GREIF PACKAGING, LLC FOR AN ADJUSTED STAt"\IDARD FROM 35 ILLADM. CODEPART 218 SUBPART IT 

### ) ) 

### ) ) 

### ) ) AS
___ _ (Adjusted Standard- Air)


### NOTICE OFAPPEARANCE PLEASETAKENOTICE 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 ofJanuary, 2011, Ihave 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 I00 West Randolph Street, Suite 11-500 Chicago, IL 6060I 

## I .I ! '



### ----------------------------------- ··- 

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

BEFORETHE ILLINOIS POLLUTION CONTROLBOARD
IN THEMA TIEROF: PETITION OF GREIF, INC. AND GREIF PACKAGING, LLC FOR**At~** ADJUSTED STANDARD FROM 35 ILLADM. CODE PART 218 SUBPARTTT 

### ) 

### ) ) ) ) ) ) AS
___ _ (Adjusted Standard- Air)



### PETITIONFORAN ADJUSTED STANDARD 

# -------=:::::::::::===::::::::::::==========-----··--·---, GREIF, INC. and GREIF PACKAGING LLC ("Greif''), through its counsel and pursuant to 35 Ill. Adm. Code§ I04.400, 

### etseq., submitsthis 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 ofvolatile organicmaterial ("VOM") at Greif's Naperville,Illinois fiber drum manufacturing facility. 

### I. INTRODUCTIONAND SUMMARY OFPROPOSED ADJUSTED STANDARD Greifoperates a fiber (paper) drum containermanufacturing facility inNaperville, DuPage County, Illinois. In general, fiber drums are producedby cutting fiber material to the appropriate length, forming the material into a cylinder and attaching a top and bottomto the cylinder. Some ofthefiber drums require the addition ofa polyethylene drum liner to meet customer specifications, particularly for storage and transport offood-gradeproducts. Greif conducts quality control ("QC") testing ofthcliners ofthese drums by spraying a QC test fluid (a denatured alcohol product, which is a VOM) into theinterior ofthe 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 visuallyinspected for pinholes. Ifpinholes are present, the ethanol causes abrown

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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 oftheremaining 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 throughoutthe 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 airpollutants ("HAPs") at GreifsNaperville**---~faGility-ar(}-SubjsGt-to-Federaliy-Bnforeeable-State·Gperating-Permit-No:-9'707'044-(.1!f-ESE>Pl!.),..t. ---·---**  ·- Condition 3 ofthe 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 oftheplant (which includes a paint spray booth, a caulk applicator, waterbased ink printing and the Weather PakWinder). The aggregate ofthese limits is 1.4 tpy. The FESOP limits HAP emissions to I 0 tpy for any single HAP or 25 tpy for any combination ofsuch HAPs. Greifreported 2009 emissions from its Naperville facility of7.7 tons ofVOM (plant-wide) and total combinedHAPs of 1.3 tons. On July 5, 2007, the Jllinois Environmental Protection Agency ("Agency") issued Violation Notice A-2007-00132 ("Violation Notice") to Greifalleging, in relevant part, thatthe Naperville facility exceeded condition 3 ofthe FESOP, relating to YOMemissions. Greif reported emissions from the QC TestProcess in2006, 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, SubpartTT, Section 218.986(a), because emissions in 2006 and 2007 exceeded the 25 tpy applicability

1 In 2006, the FESOP was issued to GreifBros. Corporation, which had changed its name to Greif, Inc. Greif, Inc. has transferred ownership and operation oftheNaperville plant to its wholly owned subsidiary, GreifPackaging LLC. When the FESOP is renewed, it will also be transferred into the name ofGreifPackaging LLC. 2

### 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 implementreasonably available control technology ("RACT") for sources ofVOM emissions within certain areas ofIllinois. 

### See In the Matter of ReasonablyAvailable Control Technology for MajorSources Emitting Volatile OrganicMaterials in 

### the Chicago Ozone NonatlainmentArea: 25 Tons, R93-14, Final Order (January 6, 1994). Section 218.986 provides, inrelevantpart: Every owner or operator ofan emissionunit subject to [Subpart TT] shall comply with the requirements ofsubsection (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
....
Greifconducted 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 ExhibifA, Reasonably Available Control Technology Study, dated August 2010, prepared for Greifby Thomas C. Ponder, Jr., PE ("RACT Study"). Gteifsubmitted the RACT Studyto the Agency on September 16, 2010. TheRACT Studyevaluated three capture and control systems: capture plusrecuperative thermal oxidizers, captureplus carbon adsorbers and captureplusbiofilters and material substitution. The RACT Study concludes that each option could achieve at least 81 percent capture and control ofVOMemissions as required under Section 218.986(a), but only at
a costperton ofVOM emissions controlled ofbetween $11,667- $17,672. These costs exceed what the Board typically has considered reasonable in adoptingRACT 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 orwater. Material substitution using acetone was found to be technicallyinfeasiblebecause ofproduct quality
concerns related to the effect ofacetone on the product. Acetone in the QC test fluid causes the gasketmaterial that seals the drumbottom to the side walls to dissolve, which is unacceptable. However, material substitution using a test fluid composed of45 percent denatured alcohol and 55 percent water achieves a 55 percentreduction in YOM emissions and results in an overall cost -------,.ledm:tiun4Jre-RA.:eT-studyC'O'!Kluoesthan:liematerial subsrirutwn optionusing45 percent denatured alcohol and 55 percent water constitutes RACT for Grief's Naperville facility. Based
on the RACT Study and the analysis ofadjusted standard requirements as set forth herein, Greif has satisfied the conditions for issuing an adjusted standard from the 81 percent capture and control requirement ofSection 218.986(a). II. 35 ILL. ADM. Code Section 104.406: Petition for Adjusted Standard Theprocedural requirements for submission ofan adjusted standard petition to theBoard
are found at 35 Ill. Adtn. Code Part 104, RegulatoryReliefMechanisms, SubpartD. Sections I04.406(a)- 

### Q) ofSubpartD specify the information that mustbe included in any adjusted**standar~** petition. Therequisiteheadings and corresponding information required under Subpart D are set forth below. A. Standard From Which Reliefls Sought- Section I04.406(a) Greifseeks an adjusted standard from the requirements of35 

### Til. Adm. CodePart 218, Subpart TT, Section 218.986(a), Control Requirements, which sets emission reduction requirements for sources ofVOM emissions notregulated under other subparts ofPart 218. Section 218.986 became effective January 6, 1994. RACT for Chicago Ozone, R93-l4. Pursuant

4 ------. -:

### 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 thepotential to emit 25 tpy ofYOM, 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, inrelevant part: Every owner oroperator ofan emission unit subject to [Subpart IT] shall comply with the requirements ofsubsection (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
.... Greifseeks an adjusted standard from the 81 percent capture and control requirement ofSection 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 ofat least 81 percent ofYOM emissions from its QC TestProcess is not economically reasonable 

### as applied to Greif, could increase emissions ofotherpollutants and may pose increased health and safetyrisks. Other alternative control strategies are technicallyinfeasiblebecause ofnegative impacts on product quality. Instead, Griefproposes to dilute the QC test fluid from 100percent denatured alcohol to 45 percent**denature~** alcohol and 

### 55 percent water. Modification ofthe QC test fluid will reduce YOM emissions from Greifs QC TestProcess by 55 percent- to an armual emission level that is below the applicability threshold ofSubpartTT.

2 Subsections (h)- (e) arenot applicable lo the QC TestProcess at Naperville and thus are notincluded in this Petition. See 35 IlL Adm. Code Section 218.986(b)- (e) (applicable to: coating lines (subsection (b)), submission ofan equivalent alternative control plan (subsection (c)), non-contactprocess cooling water (subsection (d)) and specific control measures applicableto leaks from components subject to the control requirements ofSubpartIT (subsection (e))). 5

### Electronic Filing - Received, Clerk's Office, January 24, 2011 * * ***AS 2011-001 * * * * *

Greifwill not require an adjusted standard from Section 218.108, "Exemptions, Variations, and Alternative Means ofConh·ol orCompliance Detenninations" for the adjusted standard from Section 218.986(a) to become effective at the state level. Section 218.108 provides: Notwithstanding the provisions ofany other Sections ofthis 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------- bythe USEPA as a SIP revision.
While the Agency will need to request theUnited StatesEnvironmental Protection Agency's ("USEPA") approval ofany Board-approved adjusted standard from Section 218.986(a) in the fonn ofa SIP revision, the adjusted standard will be effective at the state level immediatelyupon grantingby the Board. SeeIn the Matter of Petition of AlumaxInc.for an AdjustedStandard from 35Ill. Adm. CodePart2I8, AS 92-13, Slip. Op. at 4 (September I, 1994); see also, In the Matter of ReasonablyAvailable Control Technology forMajor SourcesEmitting Volatile OrganicMaterials in the Chicago OzoneNonatlainmentArea: 25 Tons, R93-14, Slip. Op. (Second Notice) at 5-6 (November 18, 1993). B. Natme ofthe Regulation ofGeneral Applicability- Section I04.406{b) The Board promulgated 35 

### Ill. Adm. Code Part 218 to implement Section 182(b)(2) of the Clean Air Act, 42U.S.C. § 7511 a(b)(2), which, among other things, requires individual states with severe non-attainment areas to adopt RACTregulations applicable to sources ofVOM 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 Boardpromulgated Part 218, including Subpart TT. 

### I d. 

### 6

### Electronic Filing - Received, Clerk's Office, January 24, 2011 * * * * *AS 2011-001 * * * * *

C. Level ofJustification- Section l04.406(c) Theregulations ofgeneral applicability from which Greifseeks 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 adequateproofofthe following: (l) the factors relating to thepetitioner are substantially and significantly different fi·om the factors relied upon bythe Board in adopting the general regulation applicable to the petitioner; (2) the -------,·xtsterrce-ofthose-factursjustinesi!ITildjusted-slllndard;-(3)therequestml-standard-willoot resolr--·· in environmental orhealth effects substantially and significantlymore adverse than the effects considered bythe Board in adoptingthe rule ofgeneral applicability; and (4) the adjusted standard is consistent with applicable federal law.). D. Facility and ProcessDescription- Section 1 04.406(d) Greifoperates a fiber drum container manufacturing facility in Naperville, DuPagc County, TIIinois. DuPage County is part oftheMetropolitan Chicago Interstate Air Quality Control Region. 40 C.P.R. § 81.14. This area is designated as anon-attainment area for ozone (1-hour and 8-hour standard) under40 C.P.R.§ 81.314. TheNaperville facility employs about 90 hourly and salaried people. Fiber drum manufacturingbegan at theNaperville 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 bycutting fiber material to the appropriate length, fonning it into a cylinder and attaching a top and bottom to the cylinder. Some ofthe fiber drums require the addition ofapolyethylene drum linerto meet customer gpecifications, particularly for storage and transport offood-grade products. Greifconducts QC testing ofthe liners ofthese drums

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### 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 ofthe drums at the QC spray station; (2) the drums are conveyed 45 feet to the QC inspection station where the interior ofthe drum is visually inspected for pinholes; (3) the drums are conveyed 120 feet to a drying oven where most oftheremaining test fluid is evaporated; (4) after leavingthe 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 thepaint drying oven, a caulk applicator, the paint spraybooth, water based inkprinting and the Weather PakWinder. Each ofthese sources has a source-specific annual YOM limit in the FESOP, and the aggregate ofthose YOM limits is 1.4 tpy. Because the plant's emissions havehistoricallybeen less than 25 tpy, thefacility has not previouslybeen subject to Subpart

### TT and does notemploy any equipment to capture or destroy YOM emissions. E. Investigation ofCompliance Alternatives: Methods for Reducing YOM Emissions from Greif's Quality Control TestingProcess Emission Unit- Section I04.406(e) Relevant provisions ofSection 218.986 would require Greifto capture and control at least 81 percent ofVOM emissions from the QC Test Process through the application of emission capture and control equipment. Greifinvestigated 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 ofthe QC test fluid with wateris the only technically feasible and economicallyreasonable alternative. This alternative also can be implemented without increased health and safetyrisks and without additional emissions that maypotentially offset the benefits ofany associated YOM reductions.

8

### 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 drumpaint
oven to evaporate most ofthe QC test fluid. The QC test fluid evaporates while the drums are being sprayed, transported for and awaiting inspection and then conveyed to the 

### drumpaint
oven. Anyremainingtest fluid is vacuumed or wiped from the drums and tothe extent it still contains VOM, may still be emitting VOM. An effective captnre system would require a tunnel -------,rrclusure<:overingihld-65-tootconveyer 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 ofthe dmm paint oven to
ensure adequate captnre ofemissions. 

### !d. Dueling to the associated control device(s) also would be required from the QC Test Process hood, the conveyor tunnel enclosure and the drumpaint
oven. 

### !d. This type ofcapture 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 ofthe 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 ofthese potential control systems are economically unreasonable, have inherent characteristics that could partially 

### offset the environmental benefits ofVOMreduction and/orhavepotentiallyharmful safety impacts.

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a. Recuperative 

### Thermal Incinerators Thermal incinerators heat an exhaust stream to a temperature sufficientlyhigh 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 airpasses onone sideofthe metal tube orplate, hot clean air from the combustion chamber passes on the other side ofthe tube orplate. Heat is transferred to the incoming air through the process ofconduction using the metal as the medium ofheat transfer. This system has heat ------recovery·as-great·as-60-percentmld·tJwrefOrerequires less natural gasilian**trauitional-~-** -- ----- incinerators to boost the combustion temperatures to 1600°F (therequired temperature to ensure complete destruction ofYOM). 

### !d. While a recuperative thermal incineratorcanbemore cost-effective than a traditional incinerator, it requires a large amount ofnatural gas as comparedto othercontrol options (fuel mustbeused even when the QC Test Process isnot operatingto maintain thethermal oxidizer at temperature). 

### !d. Frequent operation cycles in thermal oxiders cause condensation corrosion and thermal deterioration ofthe insulation which requires ongoingmaintenance costs. 

### !d. at Section 1.0. 

### ln addition, the large amount ofnatural gasrequired to operatethermal oxidizers generates NOx and CO emissions and small quantities ofYOM and HAPs, which would partially offset anybenefits obtainedfrom the associated YOM reduction. 

### !d. TheRACT Study concludes that total capital costs ofthe capture system and the recuperative thermal incinerator control technology at Greif'sNaperville facility would be $1,752,000 with annualized capital and operating costs of$17,672 perton ofYOM controlled. 

### See RACT Studyat Table4-1.

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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 oftwo ormore beds ofactivated carbon- one treats the exhallst emissions while the otheris beingregenerated. 

### Id. Typically,regeneration involves passing steam through the carbonbed to remove the YOM withthe steam, leaving theregenerated carbon to bereused. Carbon adsorbers work best with insoluble YOM, which simplifies the recovery ofthe YOM from the saturatedbeds. Jd. In some

-- ---,cases;-distillation-is-required-to-separatc-the-'V0M-materi"alsihmn1Rn'llgenerution steam.**Ja~·----** The QCtest fluid is water soluble and would be very expensivetorecover from the regeneration fluid. 

### Jd. In addition, theregeneration fluid likely could be sent to a local sewage district along with Grief's other process wastewaters. 

### Id. Most sewerdistricts use equalization basins to reducebiological oxygen demand loading, which in this context includes YOM, by blowing solvents into the atmosphere; meaning that YOM emissions may not truly bereduced by the use ofcarbonbeds. 

### Id. Further, ketones found in the denatured alcohol present an inherent safetyrisk offires from reactionsbetween the ketones and thecarbon in thebeds. 

### Id. Although carbon beds that handle ketones utilizewater 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 technologywould be$1,170,000. This control option would result in total annualized capital and operating costs of$12,594perton ofYOM controlled. 

### See RACT Study at Table4-1.

]]

### Electronic Filing - Received, Clerk's Office, January 24, 2011 * * ***AS 2011-001 * * * * *

c. Biofiltcr and Material Substitution Biofilters can beused to reduce YOM emissions without the use ofnatural gas to burn the hydrocarbons. See RACT Study at Section 3.2.3. Bioren has proposed to install abiofilter
on the Greifdrum plant in Oakville, Ontario, which could potentiallyreduce YOM emissions from that plantby 70 percent. Id. AtNaperville, the 81 percent capture and control objective could bemet onlyby combiningthe biofilterwith another control technology or by considering the reductions in YOM emissions from the use ofthe water diluted test fluid as a capture and -----nontrohechnulugyreductiun-:-fd;-A-biufl:ltersystemhas lower operating costs,allhougb!he- -·- ···- ·- · capital costs are comparableto incinerators. Id. Biofiltcrs mustbeheated to maintain destruction activity duringwintermonths and heat for the filter canbe supplied by the direct combustion ofnatural gas, steam or electricity. Id. Natural gas used for combustion would increase NOx emissions from the facility, partially offsetting the benefitfrom 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 ofthe water diluted test fluid) is $1,800,000 and annualized capital and operating costs are $11 ,667 perton ofYOMcontrolled. See RACT Study at Table4-1. 3. MaterialSubstitution Options


### a. QC 

### TestFluid- Dilution with 

### Acetone Greifconsidered dilution ofthe QC test fluid with acetone (anon-YOM material) as a possible alternative. However, dilution ofthe testing fluid with acetone could cause the gasket material scalingthebottom ofthe drum 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 TestFluid- 

### Dilution with Water Griefevaluated the operational impact ofdiluting the QC test fluid with varying amounts ofwater as a means to reduce YOM emissions. Griefexperimented with differentratios ofwater to denatured alcohol to identify the composition able to reduce YOM emissions to the greatest extent possible whilemaintaining the abilityto visually detect pinholes or othertears or

----------- 

### impertectiOnS!n llieoium hnmgs. The testing procedure involved intentionallycreatingpinholes in the liners offive drums before sending them tlrrough the QC Test Process. The drums were sprayed with varying modifications ofthe QC test fluid and visually inspected to dete1mine ifthe pinholes could be detected within an acceptable time period (here, about 70 seconds). !d. 

### at 3.2.1. Ifthe pinholes
were detected, the test and the associated test fluid were considered acceptable. Id. 

### Ifthe 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. 

### Greifexperimented with five potential alternativetest fluids. Amixture of80 percent denatured alcohol and 20 percent waterrevealed pinholes in each offive test drums within about 5seconds. Id. 

### Based on this result, Greifnext experimented with a mixture of70 percent denatured alcohol and 30 percent water. The70/30 mixture revealed pinholes in each offive test drums after 7 seconds; butwith 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 aroundpinholes in each test drum within 

### 45 seconds. 

### Id. The test using 40 percent denatured alcohol and 60 percent water failed to identify flaws in theliners
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within an acceptable timeperiod. 

### Id. Griefthen evaluated a 45 percent denatured alcohol and 55 percent water mixture. This mixture detected all ofthepinholes within 50 seconds of spraying- although with significantly lighter staining. I

### d. Based on these testnms, Greif detennined that 55 percent dilution with waterwas the highest dilution percentage that would allow the plant to meet its customer's quality assurancerequirements. Greifinformed the Agency ofthese testresults andbeganutilizing 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 ofdrum defects withoutharming the product. Diluting the QC test fluid with water also has thepotential to reduce annual emissions of VOM from the 

### QC Test Process below the 25 tpy applicability threshold ofSection 2!8.980 and below the 22.8 tpy emissions limit in condition 3 ofthe 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 $679perton ofVOC controlled. See RACT Study at Table 4-1. 

### 4. ComplianceAlternatives Conclusion Three capture and control systems would be technically feasible: capture plus recuperativethermal oxiders, capture plus carbon adsorbers and capture plus biofilters and material substitution. While each ofthese options could achieve the 81 percent capture and control objectives ofSubpart IT, the cost/ton ofVOM controlledrange from $11,667 to $17,672. These costs exceed what theBoard has considered reasonable in adopting RACT regulations. See infra at Section 

### II0-!)(1). Material substitution usingacetone is technically

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### Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * *

infeasiblebecause ofproduct 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 I04.406(±) Greifproposes the following adjusted standard foradoption bythe Board: 

### I. Greifwill reduce YOM emissions from its QC Test Process by using a test fluid composed of 45 percent denatured alcohol and 55 percent water.
2. Greifwill coordinate with the Agency to submit to EPA arequest for revision ofthe Sll' consistent with thisproposed adjusted standard requiringusc ofthe diluted QC test fluid as an alternative to capture and control technology. 3. Environmental staffofGreif's parent will conduct a formal training session for Naperville facility personnel ontherequirements ofthe FESOP and the internal procedures for tracking compliance with FESOP conditions. 4. Greifwill continue to implement an improved system for monthlytracking and calculations ofYOM emissions and monthly comparison ofthe calculations to YOM limits contained in the FESOP. Theresults ofthe comparison will continue to bereported to Greif's facility management monthly so that any deviations or exceedances ofFESOP conditions can be identified and tin1ely reported to the Agency as required byFESOP condition 6. G. Quantitative and Qualitative Description ofGreif's Impact on theEnvironment Before and After the Proposed Adjusted Standard- Section 1 04.406(g) 1. AirQualityImpactAnalysis of Greifs Operations Application ofthe proposed adjusted standard 

### will allow Greifto reduce current YOM emissions fi·om the QCTest Process by 55 percent. While thisreduction is lessthanthe 81 percent capture and control requirement ofSection 218.986(a), the proposed adjusted standard

15

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

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

will allow Griefto reduce YOM emissions below levels required by its FESOP and the threshold for SubpartTTapplicability. The emissions ofYOM from the QC TestProcess at the Napervilleplant will have no impacton airquality. In 2009, state-wide YOM point source emissions were 54,668 tons. See Illinois Annual.Air QualityReport 2009, Table C-5 (IEPANovember 2009) (available at
www.epa.state.il.us/air/air-quality-report/2009/air-gualitv-report-2009.pdf). Thus, even at the maximumpennitted emissions levels for the Napervilleplant (22.8 tpy basedon condition 3 of --·----t:he-FES0P);-Ve>M-emission:rfrorrrthe-QC!esrProcesswoulo amounno a15ounJ.04%of**state~-** widepoint 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 ofInformation Act request, attached as Exhibit B. Assuming maximum emissions pennittedunderthe FESOP for the Napervilleplant, YOM emissions from the QC TestProcess would amount to only 0.19% ofMetropolitan Chicago point
source emissions. TheBoardpreviouslyhas found that adjusted standards from SubpartTTfrom sources with muchhigher YOM emissions would haveno significant impact on air quality. See, e.g., In theMatter of' Petition of FordMotor Co. (ChicagoAssemblyPlant) for anAdjustedStandard from 35Ill. Adm. Code Section 218.986, AS 00-6, Slip. Op. at 5 (April6, 2000) (uncontrolled emissions of390 tpy wouldhave no significantimpact on air quality orhuman health); In the Matter of' Petition of Alumax, Inc.for anAdjustedStandard from 35Ill. Adm. Code Part218, AS 92-13, Slip. Op. at 9 (Sept. 1, 1994) (excessuncontrolled emissions of76tpywould not significantly impact air quality). TheBoard also has shown a particular concern for capture and control technologies, such as incinerators, that create alternate emissions, e.g., NOx, which also

16

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * *

contribute to ozone formation orhazardous 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 theMatter of JointPetition of Quantum Chemical Corporation, US!Division (and the Illinois EnvironmentalProtectionAgency) for anAdjustedStandard from Parts of35Ill. Adm. Code 218.966and218.986, AS 92-14, Slip. Op. at 9 (Board granted adjusted standard whereuse of control teclmology would emit NOxwhich, likeVOM, contributes to ozone fonnation, that**-----~would-partially-offsetihe-benefits-ofVE>MTeductiun)-.**- - ··- -- 

### -------- 

## _,_ --- --- ··----- .-

# - 2. Cross-Media EnvironmentalImpactsResulting from anAdjusted Standard. None. Greif's waste and wastewater generation is independent ofVOM emissions from the QCTestProcess; therefore, no changein the nature orvolume ofwaste and wastewater is Wlticipatcd. H. Justification- Section I04.406(h) Where, as here, the regulation ofgeneral applicability does not specify a level of justification required for a petitionerto qualify for an adjusted standard, Section 28.1(c) ofthe Illinois Environmental Protection Act, 415 JLCS 5/28.1(c), authorizes theBoard to grant an adjusted standard upon adequateproofofthe following: 

### (1) the factors relating to thepetitioner
are substantially and significantly different from thefactors relied uponbythe Board in adopting the general regulation applicable to thepetitioner; (2) the existence ofthose factors justifies an adjusted standard; (3) therequested standard will notresult in environmental orhealth effects substantially and significantlymore adverse than theeffects consideredby theBoard in adopting therule ofgeneral applicability; and (4) the adjusted standard is consistentwith applicable federal law.
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### Electronic Filing - Received, Clerk's Office, January 24, 2011 * * * * * 

### AS 2011-001 * * * * *
1. Factors Relating to Greif are Substantiallv andSignificantlyDifferent. 

### 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, evenlfGreif"cotilo not manage YOM emissionsby dilution ofthe QC test fluid, the physical design ofGreif's operations and the slow-evaporation ofits 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 ofSection 218.986(a) would exceed the threshold cost level the Board previouslyhas found to be economicallyreasonable.
a. The Board Did Not Consider Factors Involving theDrum ManufacturingBusiness in 

### Adopting SubpartTT. 

### Subpart TT ofPart 218 is essentially a "catch-all" applicable to YOM sources that are not governed by other subparts ofPart 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 ofSubpart TT was to cover sources thathad not otherwisebeen specifically considered. See 35lll. 

### Adm. Code§ 218.980(a) and (b). The Boardpreviouslyhas 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

18

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * 

### * *
be "substantially and significantly different." See FordMotor Company (2000), 

### AS 00-6, Slip. Op. at5. In FordMotor 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 byother subparts ofPart 218 and, in adopting SubpartTT, 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." Id. b. GrcifsAbility to Manage YOM Emissions Through Dilution ofits QC TestFluid Constitute Substantially and Significantly DifferentFactors. Even ifthe Board had considered factors impacting the capture and control ofYOM emissions at drum manufacturers when itpromulgated Section 218.986(a), it did not consider Greifs tmique QC Test Process, the particular complexity ofconstructing capture equipment
over an extended conveyor line or the abilityto manage YOM emissionsby minting the QC test fluid with water. Construction ofeffective capture equipmentis further complicated by the need to maintainphysical access to the drums for visual inspection. This means the conveyor line cannotbe totally enclosed to maximize capture. These factors are substantially and significantly different from emission units where material substitutionis not possible and the construction and operation ofemission capture equipment is less extensive.

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### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * *

c. Greifs QC Test Process is Substantially and Significantly Differentfrom Other ManufacturingActivities 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 ofthetesting fluid and the need for Greifto inspect drums visually after the QC test fluid has been sprayed into the drum. Thetesting fluid begins to evaporate whilebeing 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. Becausethe lined drums must beaccessible for visual inspection byplant staff, complete enclosure ofthe drum conveyor line isnot possible. These factors would require large capture systems, including ahood at the QC spray station, at the opening ofthe drumpaint oven and along the conveyorused to transport the drums from the spray station to the inspection area and from the inspection area to thedrum oven. See RACT Study at Section 1.0. Theneed to construct and operate a capture system this complex and this large likely was not considered by theBoard in adopting SubpartTT and will significantly impact Greif's costs to control 

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

### d. Costs ofAchieving RACT Control Standard Exceed those Considered bv Board in Setting RACT Standard. lnaddition, 

### as reflected 

### in the RACT Study, feasible technologies to achievethe 81 percent combined capture and control objectiveofSection 218.986(a) would require costs per ton ofannual 

### YOMremoved ranging from $11,667 to $17,672. These costs exceed the threshold cost level theBoard previouslyhas found to be economicallyunreasonable. See In the Matter of Petition of Forme!Industries, Inc.for anAdjustedStandard from 35Ill. Adm. Code.

20

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

. *****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$10,911

- $18,041 per ton ofVOMreduced were economically unreasonable); FordMotor Company (2000), Slip. Op. at 5 (citingIn re: Petition of LouisBerkman, 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 perton ofreductions was economically unreasonable); In theMatter of JointPetition of Reynolds Metals Company and the Illinois Environmental ProtectionAgency for an71.djusted-8tandardfrom-35-IJJ.e-2t·8;980,"""*8·9J=8-{Sept:-2t;-t995·)·{Board·foum!·$40;000-p-er- ·- ton ofVOMreduced to be economicallyunreasonable). 2. TheExistence of These Factors Justifies anAdjustedStandard. The intent ofthe regulations promulgatedunder 35 

### lll. Adm. Code Part 218 is to implementRACTfor VOM emission sources in the Chicago ozone non-attainment area. SeeIn theMatter of Petition of FordMotor Company (Chicago AssemblyPlant) for anAdjusted Standard from 35Ill. Adm. Code 218.986, AS 02-3, Slip. Op. at 4 (November 21, 2002). GreiPs RACT Study demonstrates that use ofthewater-diluted test fluid as an adjusted standard reduces emissions from the QC TestProcess below the applicability threshold for Subpart

### TT3 and below applicable FESOP limits whilereducing costs. Theexistence ofthese factors demonstrates that dilution ofthe QC test fluid constitutes RACT andjustifiesthe granting ofthe instant request. 3. The RequestedStandard WillNotResultinAdverseHealth Ef&cts. Therequested adjusted standard will have little, ifany, adverse impact on humanhealth
orthe environment. In 2009, state-wide VOM point source emissions were 54,668 tons. See

'Greifunderstands that Subpa1tIT 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 belowU1e applicabilitythreshold is ofsome significance because the Board certainly didnot consider sources with uncontrolled emissions less than the threshold being subjectto SubpartTI. 21

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * *

IllinoisAnnualAirReport 

### at Table C-5. Thus, even at the maximum permitted emission levels for the Naperville plant (22.8 tpy based on condition 3ofthe FESOP), YOM emissions from the QC Test Process would amount to less than 0.04% ofstate-widepoint source emissions and only 0.19% ofMetropolitan Chicago emissions. TheBoard has previously found that adjusted standards from SubpartTT 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; FordMotor 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 greaterthan those proposedby Greif. See, e.g., Ford MotorCo. (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 humanhealth); Quantum Chemical Corporation, 

### AS 92-14, Slip. Op. 

### at 10 (Board agreed that operation ofemission units resulting in over260 tpy ofYOM was small compared to the total YOM emissions in the Chicago ozonenon-attainment area and would have no measurable impact on airquality); 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 emissionsreduction constitutes apositive 

### environmental impact. See FordMotor Company (2002), 

### AS 02-3, Slip. Op. 

### at 4. InFord, 

### theBoard found that a 50 tpy reduction ofYOM emissions (from 390 tpy to 340 tpy- or 13%) was "significant" and would have a "positive impact on air quality." Id. Here, dilution ofthe QC test fluid is producing a 55% reduction of

22

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

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

### * * * * *
VOM emissions- an even greater reduction on apercentage basis than what was at issue in the Fordpetition. 4. The RequestedStandard IS Consistent with FederalLaw. Section 110 ofthe federal Clean AirAct, 42 U.S.C. 

### § 7410, grants individual states the authorityto promulgate a plan for implementation, maintenance and enforcement ofair quality standards, subject to approval by EPA. Based on the RACT Study, theproposed adjusted standard constitutes RACT for the Greiffacility, and is therefore consistent with the federal

- --· ----Giean-AirAct. A-state-may revise its SIP;-agairrsubjecttoEPA«pproval:· '42-tJ;S:e: 

### § 74to:- · - Greifwill work with the Agencyto submit a SIP revision to EPA that is consistent with any adjusted standard granted bythe Board. J. Hearing- Section 104.406(j) Greifrequests ahearing in this matter. 

### K. SupportingDocumentation- Section 1 04.406(k) 1. RACT Study, attached to this Petition as Exhibit A. 2. FOIA Response from nlinois Environmental Protection Agency, Bureau ofAir, attached to this Petition as Exhibit B. 

### lll. CONCLUSION Greifrequests that the Board grantthe proposed adjusted standard as an alternative to the RACTregulations adopted bythe Board in Subpart TT. To require Greifto comply with the requirements of35 TIL Adm. Code Subpart TT, Section 218.986(a), would result in substantial economichardship to Greifwith no corresponding environmental benefit. Certain compliance options examined by Greifcould have thereverse effect ofcreating increased emissions ofother pollutants and environmental detriment. Finally, add-on controls are unreasonably expensive,



### 23

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * * provide little, ifany, environmental benefit and certain control options may result in increased health and safety risks.
WHEREFORE, Greif, Inc. requests that the Board grant Greifthe proposed adjusted standard from 35 Ill. Adm. Code, SubpartTI, Section 2I8.986(a), as that rule applies to the emissions ofVOM from GreifPackagingLLC'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 200WestMadison Street Chicago, Illinois 60606 312-726-1567 January 24, 2011

24

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****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 '* * * * * ReasonablyAvailable Control TechnologyStudy 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 ThermalIncinerators
.......................................................3-1 3.2.2 CarbonAdsorbers
...................................................................................3-1 3.2.3 Biojilter
....................................................................................................3-2 

### 3::J- ·potentialEquivaleiiO\IterriativeConfrol Plaris
..**:.~::-::**

### .**.-:~:.~.--:-:**

### ........:...... 3-2 3.3.1 QCTest Fluid-Dilution with Water
.....................................................3-2 3.3.2 QCTest Fluid-Dilution withAcetoue
..................................................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

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * * ReasonablyAvailnble Control Technology Study August2010 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**p,~jecl** No. 8003

### Electronic Filing - Received, Clerk's Office, January 24, 2011 * ****AS 2011-001 * * * * * ReasonablyAvailable Control Technology Study August20 I 0 

### 1.0 SUMMARY 

### This study was undertaken to evaluate the reasonably available control technologies (RACT) options that could be implemented atthe quality control (QC) testing process emission unit ofthe Greiflndustrial Packaging & 

### Services, LLC (Greif) fiber container facility in Naperville, Il1inois. The options are being considered to determine ifthe 81% combined capture and control requirement of3 5 lAC 218.986 is technical!y achievable and economically reasonable for the 

### QC testing process emission unit and, ifnot, to identify equivalent alternative control plans that would constitute RACT forthis 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**  ofemission capture and control equipment. Capture technology would involve a combination ofpermanent 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 90percent capture methodology:
• Recuperative thermal incinerator
• Carbon adsorber
• Biofilter In addition, the following methods ofVOM emission reduction were evaluated as possible equivalent alternative control plans:
• Dilution ofthe QC testing process fluid (amixture ofsolvents, primarily denatured alcohol) with water • Dilution ofthe 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 ofthe testing fluid with acetone was determined to betechnically infeasible. Acetone, does not work atNaperville since it causes the gasket material which seals thebottom ofthe 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 ofemissions 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 afterthe QC test fluid has been sprayed intothe drum. Currentlythe drums are sprayed
TCP r.ujoctNo. 8003 J.J

### Electronic Filing- Received, Clerk's Office, January 24, 2011 * * * * *AS 2011-001 * * * * * ReasonablyAvailable 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 ofemissions at the QC test station, itself, the conveyors, and the drum paint oven. This is a very complicated capture system thatrequires tunnel enclosures around the conveyors. The QC test process station must be enclosed and the opening to drum paint oven mustbereduced to ensure 90 percent capture ofthe emissions. The control system requires both enclosures ofthe process and dueling to the control device. Unifonn capture is difficultwhen system components include a spray station, tunnel hoods, and an oven. Because ofthe difficulties with the capture system, the air flow rate to the control device will ne.cessarilybe.high
..This creates the.need for larger control-systems,-which-impacts costs. As reflected in Table 1-1, the costs ofYOM control stated in tenns ofdollars per ton ofannual YOMreduction range from $11,167 to $17,672. This range ofcontrol costs is significantly higher than the level ofcosts considered to be economic in adopting RACT controls, about $2,250per

### ton in 2008 dollars.


### Table 1·1 Costs ofVOM Control ($/ton)
Control Option Cost ofVOM Control ($/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 thereduction ofYOM emissions have inherent characteristics that would partially offset the environmental benefits ofYOMreduction. Thennal oxidizers use large quantities ofnatural gas. Fuel will be.used even when the 

### QC test process is not operatingto maintain the thennal oxidizer at temperature. Frequent operation cycles in thetmal oxidizers cause condensation corrosion and thermal deterioration ofthe insulation. Thennal oxidi7.ers emitNOx and CO and small quantities ofYOM and HAPS are also**emi~ted.** These emissions will partially offset anybenefits obtained from YOM reduction. Carbon adsorbers also have drawbacks. Since all ofthe solvents used in the QC testprocess are water soluble, theused solvents can not be
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### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * * ReasonablyAvailable 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 oftreatment system at the municipal b·eatment facility, the YOM may not be biodegraded but simplyblown into the atmosphere in an equalization basin. In that case, YOM emission reductions at the facility will be offsetby higher emissions at the treatment facility. Biofilters must beheated to maintain destruction activity during winter months. Heat for the biofilter canbe supplied by the direct combustion ofnatural gas, steam, orelectricity. Natural gas combustion would increaseNOx emissions from the facility. In

### addition, the large size ofthese units may limit feasible locations at afacility. Also, thebiofilter cannot achieve the 81% control objective by itselfand would require au additional control system or the counting ofthe

. --·--- --- . 

### QC tesffluid dilution as a control iechnologytoachieve that objective. In contrast, dilutingthe QC 

### test fluid with waterhas been calculated to reduce annual emissions ofYOM below the 25 tons per year (tpy) threshold for applicability ofSection 218.986 at areduced cost frompre-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 ofthe81% capture and control requirement ofSection 218.986.

TCP Project No. 8003 ].3

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

### AS 2011-001 * * * * * ReasonablyAvailable Control TechnologyStudy Augus/2010 

### 2.0 FACILITY INFORMATION
Greifoperates afiber container manufacturing facility in Naperville, Illinois. The primary activity involves the cutting offiber 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 occurduring the application ofcaulk, silk screening ofinfonnation onto the drum, and in drum painting
.. Combined VOM emissions from all these units are currentlypermitted at amaximum of1.4 tpy, and Greifhas 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 ofSection 218.986 because no ------Single unit-emits-greater-than-2.5 tpy ofVOMs-and-the-aggregate·cmissions from-the other· units does not exceed 5tpy. Some ofthe fiber drums manufactured atNaperville are required by customers to have polyethylene liners, primarily to comply with requirements for food grade containers. Drums with these liners mustbe tested to ensure that the liner is free from pinholes or other tears or imperfections. The QC Test Process emission unit involves the spraying ofaVOMcontaining liquid onto the polyethylene liner, which causes imperfections in the liner to become visible to the naked eye and detectable to 

### plantpersonnel who inspect each ofthe lined dnuns as itproceeds through the process on aconveyorbelt. At the Naperville plant, only the QC Test Process emission unit emits significant quantities ofVOM emissions. Emissions from the QC Test Process are currentlypermitted at 22.8 tpy, and Greifhas 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

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * * ReasonablyAvailable Control TechnologyStudy August2010 

### 3.0 CONTROL TECHNOLOGIES Briefdescriptions ofthe 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 ofthe 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 contro1system. 

### 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 theheat to incoming gases. Less natural gas is needed to boost the combustion temperatures to 1600°F to 

### ensure complete destruction ofthe YOMs. This system has heat recovery as great as 60%. The primary advantages ofthis control system are lower annual costs relative to other incinerators and flexibility in handling arange ofYOM materials. Theprimary disadvantages of this control system relative to other control options are higher operating costs due to the amount ofnatural gas that is consumed and theresultingincrease 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 ofthe 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 * * * * * ReasonablyAvailable Control TechnologyStudy 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 offires from reactions between the ketones and the carbon in thebeds. Carbonbeds 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 Greifdrum 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 thebiofilter with another
·-cotili:cil techiiolo·gy or

### by eonsi3enngtlie reouclions-in VOM emissions

# Iromtne· useofthe 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 ofnatural gas, steam, or electricity. Natural gas combustion would increase NOx emissions from the facility. 

### 3.3 Potential EquivalentAlternative 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 ofdenatured alcohol and water. The goal ofthe 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 ofliners 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 ifthe pinholes could be detected in an acceptable timeperiod. Under normal operations, ittakes 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. Ifthe 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 ProjectNo. 8003 3-2

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * 

### * ReasonablyAvailable Control Technology Study August20/0 

### seconds. The experiment was repeated with a test fluid consisting of70% denatured alcohol and 30% water. As with the first test fluid, this second mixture allowed the detection ofall 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 ofthe 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 visibleby 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 ofdrums 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 ofthe fiber drum to the walls ofthe drum. Forthat reason, this alternative was deemedbythe facility to be infeasible for 

### full implementation.

TCP ProjedNo. 8003 3-3

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

### AS 2011-001 * * * * * ReasonablyAvailable Control Technology Study August2010 

### 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 ofeach ofthe 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 costperton ofYOM 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 ofAir 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 ofthe 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 ofmoney used to finance theproject and determining the depreciation ofthe equipment. Although there are other methods for determining these costs, capital recovery is used by EPA in RACT analysis in determining the costperton ofpollutants 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 * * * * * ReasonablyAvailable Control Technology Study August2010 

### 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 ofYOM 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 ofYOM controlled. Control costs range from $11,667 to $17,672 per ton ofYOM controlled. In addition, all control systems for the reduction ofYOM emissions haveinherent characteristics that would partially offset the environmental benefits ofYOM reduction. Thermal oxidizers use large quantities ofnatural gas. Fuel will be used evenwhen the QC testprocess is not operating to maintain the thermal oxidizer at temperature. Frequent operation cycles inthermal oxidizers cause condensation corrosion and the1mal deterioration ofthe insulation. Thermal oxidizers emit NOx and CO and small quantities ofYOM and HAPS are also emitted. These emissions will partially offset anybenefits obtained from YOM reduction. Carbon adsorbers also have drawbacks. Since all ofthe solventsused in the QCtest process are water soluble, the used solvents cannot berecovered 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 onthe type oftreatment system 

### at tbe municipal treatment facility, the YOM may not bebiodegraded but simplyblown into the atmosphere in an equalization basin. In that case, YOM emissionreductions at the facility will beoffset byhigher emissions at the treatment facility. Biofilters must beheated to maintain destruction activity duringwintermonths. Heat for thebiofilter canbesupplied bythe direct combustion ofnatural gas, indirect steam heat, or electricheaters. Natural gas combustion would increase NOx emissions from the facility. In addition, the large size oftheselmits may limit feasible locations at a facility. Also, the biofilter cannot achieve the 81%control objectiveby itselfand would require an additional control system or the counting ofthe QC test fluid dilution as a control technology to achievethat 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 * * * * * ReasonablyAvailable 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 ProjoctNo. 3003 4-6

### Electronic Filing - Received, Clerk's Office, January 24, 2011 *****AS 2011-001 * * * * * 

### i ReasonablyAvailable Control Technology Study August2010 

### 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 * * * * * ReilSonablyAvailable Conlro/TechnologyStudy Augus/20/0



## Appendix A Capital and Annual Costs for Thermal oxidizers with Recuperative Heat Exchangers

TCP ProjectNo. 8003 I

### Electronic Filing - Received, Clerk's Office, January 24, 2011 * ****AS 2011-001 * 

### * * * *
Recuperative Incinerator Costs - 20000 acfm (All costs are in, orhave been adjustedto, 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 70 Greif Permit - Inlet stream temperature (oF): 

### 11J

·---=-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 tNCINERATOR COSTS Iffiow 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 ofAir Pollution Control-calculated] 129,417 (Estimating Costs ofAir Pollution Control-calculated] 64,709 (Estimating Costs ofAir 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 ofAir Pollution Control--calculated] $ 117,951 (Estimating Costs ofAir 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 laborfactor (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 ofVOC 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 * * * * * ReasonablyAvailable Control Technology Study August2010

-----···--



## 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, orhave been adjustedto, 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 Ifthe 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 ofthe 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 ofAir 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 "



# ------------ -----------------. 

# -------- TOTALANNUAL COST: $ 458,233 

### " Tons ofVOC controlled 36.39 Cost per ton ofVOC 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 ofAir 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 ofAir- 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, IL. 60606 Cook Phone: (312) 726-7146 Fax: (312) 726-7102 Susan.Charles@icemiller.com Subject Matter. Metropclitan Ch'1cago InterstateAir Qual'rty Contra Specific information requested from: Bureau ofAir- 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) ofVolatile 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 request

### Exhibit 

## 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 ILLADM. CODE PART 218 SUBPARTIT 

### ) ) ) 

### ) ) ) 

### ) 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 ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276
PLEASETAKENOTICEthat I have today electronically filed with the Office ofthe Clerk ofthe Illinois Pollution Control Board, Petitioners' NOTICE OFELECTRONIC FILING,PROOF OF PETITIONNOTICE REQmREMENTS and CERTJFICA TE OF SERVICE, copies ofwhich are attached herewith and served upon you.

Date: February 10,2011 Thomas W. Dimond Susan Charles ICEMILLERLLP 200 West Madison Street Suite 3500 Chicago, Illinois 60606 Respectfully submitted, GREIF, INC. and GREIF PACKAGING, LLC

· By: /s/ Susan Charles One ofits Attorneys

1

### Electronic Filing - Received, Clerk's Office, February 10, 2011
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATIER OF: PETITION OF GREIF, INC. AND GREIF PACKAGING, LLC FORANADJUSTED 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 I04.410, on January 27, 20II, petitioners Greif, Inc. and GreifPackaging, LLC ("Greif') published notice ofthe filing oftheir Petition for an Adjusted Standard ("Petition") by advertisement in a newspaper ofgeneral circulation in the area ofGreifsNaperville plant. In support ofthis filing Greifstates the following: 

### I. Greiffi1ed the Petition with the Clerk ofthe Illinois Pollution Control Board on January 24, 20I 

### 1. 2. Pursuant to the Petition, Greifseeks an adjusted standard from 35 

### lll. Adm. Code 

### § 218.986(a) as it applies to control requirements for emissions ofvolatile {)rganic material at Greifs fiber drum manufacturing facility located in Naperville, Illinois. 3. On January 27,2011, Greifpublished notice ofthe filing ofthe Petition by advertisement in the

### Naperville Sun. a newspaper ofgeneral circulation in Naperville, Illinois. 4. As required by 35 

### Ill. Adm. Code Section 104.408(a), Greifpublished notice of the filing ofthe Petition within 14 days after 

### itfiled 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 ofpublication issued by the publisher ofthe 

### NapervilleSun ce1tifying publication ofthe notice on January 27, 20II is attached as Exhibit 

### 1. The ce_rtificate ofpublication attaches Greifs notice as it appeared in the

### Naperville Sun and states that the 

### Naperville Sun satisfies the requirements ofthe Illinois Notice by Publication Act, 715 ILCS 5/0.01, 

### et seq. The language included in Griefs notice is consistentwith 35 Ill. Adm. Code Section 104.408(b). WHEREFORE, for the reasons stated above, Greifhas satisfied the requirements for providing notice ofthe filing ofits Petition for an Adjusted Standard and for filing proofofsuch notice with the Illinois Pollution Control Board.

Date: February I0, 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 ofits Attorneys

2

### Electronic Filing - Received, Clerk's Office, February 10, 2011
CERTIFICATE OF SERVICE 

### I, the undersigned, certify that on this lOth day ofFebruary, 2011, Ihave served electronically the attachedNOTICE 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 WestRandolph Street, Suite 11-500 Chicago, IL 6060I and 

### by U.S. Mail, first class postage prepaid, to the following persons: Division ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O
..Box 19276 Springfield, IL 62794-9276 /s/ Susan Charles Susan CharlesICE MILLER LLP 104478 V1 GreifASP 

### 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 GreifASP $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 DayofJanuary 2011 A.D.

# ~~J-~ Notary Public 

### Exhibit 1 OFFICIAl SEAL OATiiERINE ACYNCAR NOTARY I'UBUO, IJTAl'E OFIUJNOJS 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, GreifPackaging, LLC. (Greif) filed a petition for an adjusted standard (Petition) pursuant to 35 IlL Adm. Code 

### § I04.400, etseq. Greifseeks an adjusted standard from 35 IlL Adm. Code§ 218.986(a) as it applies to control requirements for emissions ofvolatile organic material (YOM) at Greifs fiber drum manufacturing facility in Naperville, Du Page County. Greifhas requested a hearing to satisfy the State Implementation Plan requirements for Reasonably Available Control Technology. Section 28.1 ofthe Act (415 ILCS 5/28.1 (2008)) and 35 IlL Adm. Code I04.408 require publication ofa notice ofan adjusted standard proceeding in a newspaper ofgeneral 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 I04.408(a). As required by 35JIL Adm. Code 104.410, Greiftimely filed a certificate ofpublication with the Board on February 10, 2011. The notice ofpetition was published in the Naperville Sun on January 27,2011. The Board finds that the notice and petition meet the requirements ofSection 28.1 ofthe Act (415 ILCS 5/28.1 (2004)) and 35 Ill. Adm. Code I04.408 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 ofthe petition. See 35 Ill. Adm. Code 104.416(a). On March 9, 2011, the Agency filed a motion for an extension oftime to file its response. Greifdid not oppose this motion. On March I0, 20II, 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 ofthe Board ofthe time and location ofhearing at least 40 days in advance of hearing so that a 30-day public notice ofhearing may be published. Today's order provides no determination on the informational sufficiency or merits ofGreifs petition. The Board, through orders ofits own or its hearing officer, may direct Greifto provide additional information concerning its request priorto hearing. IT IS SO ORDERED.

### 2 I, John Therriault, Assistant Clerk ofthe Illinois Pollution Control Board, certify that the Board adopted the above order on March 17,2011, by a vote of5-0.

John Therriault, Assistant Clerk Illinois Pollution Control Board/EPA ATTACHMENT NO.

# i_ RECEIVED

CLERK'S OFFICE ILLINOIS POLLUTION CONTROLBOARD March 21,2011 

## MAR 21 2011 STATE OF ILLINOIS**~n** 

### Control

## Board

INTHE MATIER OF: PETITION OFGREIFPACKAGING, LLC., FOR AN ADJUSTED STANDARD FROM 35 ILL. ADM. CODEPART 218 SUBPARTTT ) ) ) ) ) ) AS 11-1 (Adjusted Standard- Air)


### HEARING OFFICER ORDER The hearing officerdirects petitioner to address the pre-hearing questions attached to this order. Written responses to the Board's questions must be filed at least 30days before the hearing. Prefiled testimony must befiled 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. TheIllinois Environmental Protection Agengy's deadline for filing its recommendation is April 11,2011. IT IS SO ORDERED.

BradleyP. Halloran Hearing Officer lllinois Pollution Control Board James 

### R. Thompson Center, Suite 11-500 100West Randolph Chicago, lllinois 60601 312.814.89172 CERTIFICATEOF SERVICE It is hereby certified that true copies ofthe foregoing order were mailed, first class, on March 21, 2011, to each ofthepersons on the attached service list. It is hereby certified that a true copy ofthe foregoing order was hand delivered to the following on March 21, 2011: John T. Therriault Illinois Pollution Control Board James 

### R. Thompson Center 100W. Randolph St., Ste. 11-500 Chicago, Illinois 60601

# ~~-\~~- \ BradleyP. Halloran Hearing Officer lllinoisPollution Cntrol Board James 

### R. Thompson Center 100WestRandolph Street, Suite 11-500 Chicago, lllinoisAS 2011-001 Division ofLegal Counsel IEPA 1021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276

AS 2011-001 Thomas W. Dimond Ice MillerLLP 200 W. Madison, Suite 3500 Chicago, IL 60606 3
AS 2011-001 Susan Charles Ice MillerLLP 200W. Madison, Suite 3500 Chicago, IL 6060635 

### lAC 104.406(g) AS 11-9 GREIF PACKAGING, LLC BOARD QUESTIONS FOR PETITIONER

I. Currently, the Illinois StateImplementation Plan (SIP) relies on Reasonably Available Control Technology (RACT) for 35 lAC 218 Subpart TT sources, like GreifPackaging, that would require 81% capture and control reductions in VOM emissions. As the petition indicates, since Greifis proposing a 55% reduction in lieu of 81%, IEPA would need to submit an SIPrevision to USEPA for approval. Greifindicated it will work with the Agency to submit the SIP revision. Pet. at 23. GreifPackagingprovided a "RACTStudy" dated August 20I 0 addressing various compliance alternatives (Pet. Exh. A), however, the study did notinclude 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.), Greifhas not demonstrated that the proposed adjusted standard will not cause orcontribute to violations ofthe National Ambient AirQuality Standard (NAAQS) for ozone ordelay efforts to attain the NAAQS in a timely manner. The hearing officer directs Greifto provide an Ambient AirQualityImpact Analysis for ozone as part ofits petition to demonstrate that the proposed adjusted standard will not cause or contribute to violations ofthe NAAQS for ozone ordelay efforts to attain the NAAQS in a timely manner. Greifshould consult with the IEPA as to the necessary elements Greifshould provide in the analysis to assure the IEPA has sufficient supporting documentation for the SIP revision request. TheBoard notes that IEPA has previously relied on petitioners to conduct an Ambient Air Quality Impact Analysis for ozone usingthe "Scheffe Method". 

### See AS 04-1, In the Matter of: Petition ofCrownlineBoats, 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 ofRoyal Fiberglass Pools, Inc. for an Adjusted Standard from 35 lAC 215.301, Technical DocumentSection 6. 

### See AS 09-4, illinois EPA's Response to Questions posed by the Illinois Pollution Control Board in the Matter ofRoyal Fiberglass Pools' Petition for an Adjusted Standard, October 

### 14, 2009 at 2. 

### See also AS 09-4, lllinoisEPA's Response to FurtherQuestions posed bythe Illinois Pollution Control Board in the Matter ofRoyal Fiberglass Pools' Petition for an Adjusted Standard, October 27, 2009 at 2. The Scheffe method, formally known as "VOC/NOxPoint Source ScreeningTables", 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.docIfGreifapplies the Scheffe Method, Greifshould consider the worst case scenario, using the maximum permitted VOM emissions. The analysis should also quantify the difference in emissions that would occur ifGreifcomplied 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 otherbasis as suggestedby the !EPA) to indicate ifthe 55% reduction would constitute a significant increase over the 81% reduction due to the adjusted standard.
35 lAC 104.406(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 VOMemitted 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 TestProcess.

### Electronic Filing- Received, Clerk's Office, 05/31/2011IEPA ATTACHMENT NO.

# 5 BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MAITER OF: AS 2011-01 PETITION OF GREIF PACKAGING, LLC FOR AN ADJUSTED STANDARD FROM 35 ILL ADM. CODEPART 218 SUBPART IT ) ) ) ) 

### ) ) (Adjusted Standard- Air)
NOTICE OFELECTRONIC FILING TO: John Therriault, Clerk Illinois Pollution Control Board James R. Thompson Center 100West Randolph Street, Suite 11-500 Chicago, IL 60601 Charles Matoesian Division ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand AvenueEast P.O. Box 19276 Springfield, IL 62794-9276
PLEASE TAKE NOTICEthat I have today electronically filed with the Office ofthe Clerk ofthe Illinois Pollution Control Board, Petitioner's NOTICE OF ELECTRONIC FILING,AMENDED PETITION FOR AN ADJUSTED STANDARD and CERTIFICATE OF SERVICE, copies ofwhich are attached herewith served upon you.

Date: May 31,2011 TI1omas W. Dimond Susan Charles ICE MILLER LLP 200WestMadison Street Suite 3500 Chicago, lllinois 60606 Respectfully submitted, ICE MILLER, LLP By: 

### !sfSusan Charles One ofits Attorneys

### Electronic Filing- Received, Clerk's Office, 05/31/2011
CERTIFICATE OF SERVICE I, 

### the undersigned, cettify that on this 31st day ofMay, 2011, Ihave 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 postageprepaid, to the following persons: Charles Matoesian Division ofLegal 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 FORAN 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, 

### etseq., 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 ofvolatile organic material ("YOM") into the atmosphere from Greif's fiberdrum manufacturing facility located at 5 S 220 Frontenac Road inNaperville, DuPage County, Illinois. I. INTRODUCTION AND SUMMARYOFPROPOSEDADJUSTED STANDARD 

### Greifoperates afiber (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 ofthe fiber drums require the addition ofapolyethylene drum liner to meet customer specifications, particularly for storageand transport offood-grade products. Greif conducts quality control ("QC") testing oftheliners ofthese drums by spraying a QC test fluid (a denatured alcohol product, which is aYOM) into the interiorofthe drums at the QC spray station.

### Electronic Filing- Received, Clerk's Office, 05/31/2011
Greifuses an automated system to spray the interior ofthe dn.un liners with QC test fluid. As adrum moves along the conveyorbelt toward the QC spray station it triggers a sensor on the guide rail that causes the drum to stop. Amechanical 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 ofQC 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. Ifpinholes are present, the ethanol causes abrown spot to appear, enabling the line inspector to detect the pinhole. The drum next is conveyed 120 feet to adrying oven where most ofthe remainingtest fluid is evaporated. After leavingthe drying oven any remaining fluid is vacuumed from the drum and then the drum is wiped dry. VOM is emitted throughout the QC TestProcess as well as in the paintdrying oven. Greiftracks its VOM emissions on amonthly basis by calculating the mass ofVOMs used and assuming that all usage is emitted to the atmosphere. To calculate mass, Greifrecords the volume ofdenatured alcohol held as inventory on the first and last day ofeach month. Greif also tracks the volume ofany denatured alcoholpurchased within each month. The volwne of denatured alcohol purchased during a month is added to the inventoryheld on the first day of thatmonth. The total, less any inventory remaining on the last day ofthe month, equals the volmne ofdenatured alcohol used. The volumeis then multiplied by the VOM content (in pounds per gal) 

### ofthe denatured alcohol to computethe mass (inpOlmds) ofVOM emitted during the month.

2

### Electronic Filing- Received, Clerk's Office, 05/31/2011
Air emissions ofVOM and hazardous air pollutants ("HAPs") at GreifsNaperville facility are subject to FederallyEnforceable State Operating Penni!No. 9707044 ("FESOP"). 1 Condition 3 ofthe 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 ofthe plant (which includes a paint spraybooth, a caulk applicator, and ink printing). The aggregate ofthese limits is 1.4 tpy. The FESOP limits HAP emissions to 10 tpy for any single HAP or 25 tpy for any combination ofsuch HAPs. Greifreported 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 Greifalleging, in relevant part, that the Naperville facility exceeded condition 3 ofthe FESOP, relating to VOM emissions. Greif reported emissions fi-om the QC Test Process in2006, 2007, 2008, 2009 and 2010 of35.2, 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 applicabilitythreshold and because Subpart TTis a "once in- always in" regulation. See 35 Ill. Adm. Code Section 218.980 (a)- (c). The Boardpromulgated 35 Ill. Adm. Code Part 218 to implementreasonably available control technology ("RACT") for sources ofVOM emissions within certain areas ofIllinois. See In theMatter of ReasonablyAvailable Control Technology forMajor Sources Emitting Volatile

ln 2006, the FESOP wns issued to GreifBros. Corpomtion, which had changed its name to Greif, Inc. Greif, Inc. has transferred ownership and operation ofthe Napervilleplant to its wholly owned subsidiary, Greif Packaging LLC. When the FESOP is renewed, it will also betransferred into the name ofGreifPackaging LLC.
3

### Electronic Filing- Received, Clerk's Office, 05/31/2011 Organic Materials in the Chicago OzoneNonattainmenlArea: 25 Tons, R93-14, Final Order (January 6, 1994). Section218.986provides, in relevant pa1i: Every owner or operator ofan emission unit subject to [Subpart IT] shall comply with the requirements ofsubsection (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
....
Greifconducted a RACT Studyto evaluate whether variousemission control options for the QCTestProcess 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 GreifbyThomas C. Ponder, Jr., PE ("RACT Study"). Greifsubmitted the RACf Studyto the Agency on September 16, 2010. TheRACT Studyevaluated three capture and control systems: captureplus recuperative thermal oxidizers, captureplus carbon adsorbers and captureplusbiofilters and material substitution. TheRACT Study concludes that each option could achieve at least 81 percent capture and control ofVOM emissions as required under Section 218.986(a), but onlyat a costperton ofVOM emissions controlled ofbetween $11,667- $17,672. These costs exceed what the Boardtypically has consideredreasonable in adopting RACTregulations. See infra at Section Il(H)(l)(d). TheRACT Study also evaluated the technical feasibility and economicreasonableness of two material substitution options: mixing the QC test fluid with acetone orwater. Material substitution using acetone was fotmd to betechnically infeasiblebecause ofproduct quality
concerns related to the effect ofacetone on theproduct. Acetone in the QCtest fluid causes the gasket material that seals the drum bottomto the side walls to dissolve, which isunacceptable. However, material substitutionusing a test fluid composed of45percent denatured alcohol and
4

### Electronic Filing- Received, Clerk's Office, 05/31/2011
55 percent water achieves a 

### 55 percentreduction 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, Greifconducted additional tests to determine whether the amount ofQC test fluid applied to each drum nm through its QCTest Process could bereduced. Based on this testing, Greifdetermined 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 ofadjusted standard requirements as set forth herein, Greifhas satisfied the conditions for issuing an adjusted standard from the 81 percent capture and control requirement ofSection 218.986(a). 

### II. 35 

### ILL. ADM. Code Section 104.406: 

### Petition for Adjusted Standard Theprocedural requirements for submission ofan adjusted standard petition totheBoard
are folmd at 35 

### Til. Adm. CodePart 104, RegulatoryReliefMechanisms, Subpart D. Sections 104.406(a)- 

### (1) ofSubpart D specifythe information that must 

### be included 

### in any adjusted standardpetition. Therequisiteheadings and corresponding informationrequired under Subpart D ru·e set forth below. A. Standard From Which ReliefIs Sought- Section 104.406(a) Greifseeks an adjusted standard fTOm therequirements of35 TIL Adm. Code Part 218, SubpartTT, Section 218.986(a), Control Requirements, which sets emissionreduction requirements for sources ofVOM emissions not regulated under other subparts ofPart2!8. Section 218.986 became effective January 6, 1994. 

### RACTfor Chicago Ozone, R93-14. Pursuant to Section 218.980(b)(1), the applicabilitythreshold for Subpart TT is thepotential to emit 25

5

### Electronic Filing- Received, Clerk's Office, 05/31/2011 tpy ofYOM, in the aggregate, from emission units at a source other than those specifically excluded from Subpart TT. The control requirements for qualifYing emissionunits at sources subject to Subpart 

### TT are set f01th in Section 218.986. Section 218.986 provides, in relevant part: Every owner or operator ofan emissionunit subject to [Subpart TT] shall comply with the requirements ofsubsection (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
.... Greifseeks an adjusted standard from the 81 percent capture and control requirement ofSection 218.986(a) as itapplies to GriefsNaperville facility. The facility is not seeking an adjusted standard from Section 218.986(b) - ( e

### )_2 As Greifwill demonstrate, achieving capture and control ofat least 81 percent ofYOM emissions from its QC Test Process is not economically reasonable as applied to Greif, could increase emissions ofother pollutants and maypose increased health and safety risks. Other alternative control strategies are technically infeasible because ofnegative impacts on product quality. Instead, Griefproposes to dilute the QC test fluid from 100 percent denatured alcohol to 45 percent denatured alcohol and 55 percent water. Greifalso will limit the amount ofQC test fluid that will be sprayed into each drum. These proposed modification ofthe QC Test Process will reduce YOM emissions from Greifs QCTesl Process by approximately 70percent on a lmit basis- to an armual emission level that is below the applicability threshold ofSubpartTT.

2 Subsections (1>)- (e) arenotapplicable to the QCTestProcess atNaperville and thus are notincluded in this Petition. See 35 Ill. Adm. Code Section 218.986(b)- (e) (applicable to: coating lines (subsection(!>)), submission ofan 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 ofSubpart IT (subsection (e))). 6

### Electronic Filing- 

### Received, Clerk's Office, 05/31/2011
Greifwill notrequire an adjusted standard from Section 218.108, "Exemptions, Variations, and AlternativeMeans ofControl or Compliance Detetminations" for the adjusted standard from Section 218.986(a) to become effective at the state level. Section 218.108 provides: Notwithstanding theprovisions ofany other Sections ofthis Part: a) Any exemptions, variations or alternatives adopted by the Board pursuant to Section 28, 28.1 or 35 ofthe Act to the control requirements, emission limitations, or test methods set forth in this Part shall be effective only when approved bytheUSEP A as a SIP revision.
While the Agencywill need to request theUnited States Environmental Protection Agency's ("USEPA") approval ofanyBoard-approved adjusted standard :from Section 218.986(a) in the form ofa SIP revision, the adjusted standard will beeffective at the state level immediatelyupon granting by the Board. See In the Matter of Petition of AlumaxInc.for anAdjustedStandard from 35Ill. Adm. Code Part 218, AS 92-13, Slip. Op. at 4 (September I, 1994); see also, In the Matter of ReasonablyAvailable Control Technology forMajorSources Emitting Volatile OrganicMaterials in the Chicago OzoneNonattainmentArea: 25 Tons, R93-14, Slip. Op. (Second Notice) at 5-6 (November 18, 1993). B. Nature ofthe Regulation ofGeneral Applicability- Section I04.406(b) TheBoard promulgated 35 Ill. Adm. Code Part 218 to implement Section 182(b)(2) of the Clean AirAct, 42 U.S.C. 

### §7511a(b)(2), which, among other things, requires individual states with severenon-attainment areas to adoptRACTregulations applicable to sources ofYOM emissions within the non-attainment area. See RACTfor Chicago Ozone, R93-14, Slip Op. (Final Rule) at 2. 

### Asmandated bythe CleanAir 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 ofgeneral applicability from which Greifseeks an adjusted standard do not specify a level of justification for an adjusted standard. Accordingly, thelevel of justification is that generally applicable to all adjusted standards. See 415 ILCS 5/28.1 (Authorizingthe Board to grant an adjusted standard upon adequate proofofthe following: 

### (1) thefactors 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 ofthose factorsjustifies an adjusted standard; (3) the requested standard will not result in environmental or health effects substantially and significantly more adversethan the effects considered bytheBoard 

### in adopting therule ofgeneral applicability; and (4) the adjusted standard is consistent with applicable federal law.). D. Facility and Process Description- Section 104.406(d) Greifoperates a fiber drum container manufacturing facility in Naperville, DuPage County, illinois. DuPage County is part ofthe 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) under40 C.F.R. 

### § 81.314. TheNaperville facility employs about 90 hourly and salaried people. Fiber

### drum manufacturingbegan at the Napervilleplant 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 bycuttingfiber material to the appropriatelength, forming it into a cylinder and attaching a top and bottom to the cylinder. Some ofthe fiber drunJs require the addition ofapolyethylene drum liner to meet customer specifications, particularlyfor storage and transport offood-grade products.



### 8

### Electronic Filing- Received, Clerk's Office, 05/31/2011
Greifconducts QC testing ofthe drum liners as follows: (1) as a drum moves along the conveyorbelt toward the QC spray station it triggers a sensor on the guide rail causing the conveyor belt to stop; (2) amechanical 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 (ifpinholes are present, the ethanolcauses a brown spot to appear, enabling the line inspector to detect the pinhole); (4) the drum is conveyed 120 feet to adrying oven where most ofthe 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 throughoutthe process. See 

### RACI' Survey at Section 1.0. In addition to the QC Test Process described above, permitted YOM emission sources at theNaperville facility include a caulk applicator, the paint spraybooth and inkprinting. Each of these sources has a source-specific annual YOM limit in the FESOP, and the aggregate ofthose YOM limits is 1.4 tpy. Becausetheplant's emissions havehistoricallybeen less than 25 tpy, the facility has notpreviously been subject to Subpart TT

### and does not employ any equipment to capture or destroy YOM emissions. E. Investigation ofCon1pliance Alternatives: Methods for Reducing YOM Emissions from Greif's QualityControl Testing Process EmissionUnit- Section 104.406(e) Relevant provisions ofSection 218.986 would require Greifto captnre and control at least 81 percent ofYOM emissions from the QC TestProcess through the application of emission capture and control equipment. Greifinvestigated 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 ofthe QC test fluid with water is the only technically

9

### Electronic Filing- Received, Clerk's Office, 05/31/2011 feasible and economically reasonable alternative. This alternative also can be implemented without increased health and safety risks and without additional emissions that maypotentially offset the benefits ofany 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 evaporatemost ofthe 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 ofthe drumpaint oven to
ensure adequate capture ofemissions. 

### ld. Duelingto the associated control device(s) also would be required from the QC TestProcess hood, the conveyor tunnel enclosure and the drum paint
oven. 

### !d. This type ofcapture 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 ofthe 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 ofthese potential control

10

### Electronic Filing- Received, Clerk's Office, 05/31/2011
systems are economically unreasonable, have inherent charactetistics that could partially offset the environmental benefits ofVOMreduction and/or have potentially h<mnf11l safety impacts.


### a. Recuperative Thermal Incinerators Thennal incinerators heat an exhaust stream to a temperature sufficientlyhigh to oxidize (bum) VOM in the exhaust. Thermal recuperative oxidizers havea heat exchangerthat preheats the incoming air by recuperating heat from the exiting air. 

### ld. at Section 3.2.1. As the incoming airpasses on one side ofthemetal tube orplate, hot clean air from the combustion chamber passes on the other side ofthe tube orplate. Heat is transferred to the incoming air through the process ofconduction using themetal as the medium ofheat 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 I600°F (therequired temperature to ensure complete destruction ofVOM). 

### ld. While a recuperative thermal incinerator can bemore cost-effectivethan a traditional incinerator, it requires a large amount ofnatural gas as compared to othercontrol options (fuel mustbeused 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 ofthe insulation which requires ongoingmaintenance costs. 

### I d. at Section 1.0. In addition, the large amount ofnatural gas required to operatethermal oxidizers generates NOx and CO emissions and small quantities ofVOM and HAPs, which would partially offset anybenefits obtained from the associated VOMreduction. 

### ld. The RACT Studyconcludes that total capital costs ofthe capture system and the recuperative thermal incinerator control technology at GreifsNaperville facility would be



### II

### 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 Table4-1. 

### 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 oftwo ormore beds ofactivated carbon- onetreats the exhaust emissions while the other is beingregenerated. Id. Typically, regeneration involves passing steam through the carbonbed to remove theVOM with the steam, leavingtheregenerated carbon to bereused. Carbon adsorbers work best with insoluble VOM, which simplifies therecovery ofthe VOM from the saturated beds. Id. In some cases, distillation is required to separatethe VOM materials from theregeneration steam. 

### !d. The QC test fluid is water soluble and would bevery expensiveto recover from the regeneration fluid. 

### !d. In addition, the regeneration fluid likely could be sent to a local sewage district along with Grief's otherprocess wastewaters. 

### !d. Most sewerdistricts use equalization basinstoreducebiological oxygen demand loading, which in this context includes VOM,by blowing solvents into the atmosphere; meaningthat VOM emissions maynot trulybereducedby the use ofcarbonbeds. Id. Further, ketones fomd in the denatured alcohol present an inherent safetyrisk offires from reactions between theketones and the carbonin thebeds. 

### !d. Although carbon beds that handle ketones utilize water deluge systems to control bed fires, the increased health and safetyrisks remain. 

### !d. TheRACT Study concludes thattotal 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 perton ofVOM controlled. See RACT Study at Table 4-1.

12

### Electronic Filing- Received, Clerk's Office, 05/31/2011

c. Biofiltcr and Material Substitution 

### Biofilters can be used to reduce VOM emissions without the use ofnatural gas to bum the hydrocarbons. See 

### RACT Study at Section 3.2.3. Bioren has proposed to install a biofilter
on the Greifdrum plant in Oakville, Ontario, which could potentially reduce VOM emissions from that plantby 70 percent. Id. 

### At Naperville, the 81 percent capture and control objective could be met onlyby combining the biofilter with another control technology or by considering the reductions in VOM emissions from the use ofthe water diluted test fluid as acapture and control technology reduction. Id. 

### Abiofilter system has lower operating costs, although the capital costs are comparable to incinerators. 

### !d. Biofilters must beheated to maintain destruction activity during winter months and heat for the filter can be supplied bythe direct combustion ofnatural 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 ofthe 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 QCTestFluid- 

### Dilution with 

### Acetone Greifconsidered dilution ofthe QC 

### test fluid with acetone (anon-VOM material) as a possible alternative. However, dilution ofthe testing fluid with acetone could cause the gasket material sealing the bottom ofthe d.tum to the drum walls to dissolve. See 

### RACT Study at 3.3.2.

13

### Electronic Filing- Received, Clerk's Office, 05/31/2011
Due to the potential for product damage, diluting the QC testing fluid with acetone is considered technically infeasible. 

### !d. b. QC TestFluid- Dilution with Water Griefevaluated the operational impact ofdiluting the QC test fluid with varying amounts ofwater as a means to reduce YOM emissions. Griefexperimented with different ratios ofwater to denatured alcohol to identify the composition able to reduce YOM emissions to the greatest extent possible whilemaintaining the ability to visually detect pinholes or other tears or imperfections in the drum linings. The testingprocedure involved intentionally creatingpinholes in the liners offive drums before sending them through the QC Test Process. The dn1ms were sprayed with varying modifications ofthe QC test fluid and visually inspected to determine ifthe pinholes could be detected within an acceptable time period (here, about 70 seconds). Jd. 

### at 3.2.1. Ifthe pinholes
were detected, the test and the associated test fluic! were considerec! acceptable. 

### Id. Ifthe pinholes could not be c!etected, the fluid was consic!crerl atechnically infeasible option based on Grief's inability to meet its customers' quality assurance standards. 

### !d. Greifexperimented with five potential alternative test fluids. A mixture of80 percent c!enatured alcohol and 20 percent water revealedpinholes in each offive test drums within about 

### 5 seconds. 

### !d. Based on this result, Greifnext experimented with a mixture of70percent denatured alcohol and 30 percent water. The70/30 mixture revealedpinholes in each offive test drums after 7 seconds; but with noticeablylighter stainingthan with the 80/20 mixture. 

### !d. A third test, using a 

### 50 percent denatured alcohol and 

### 50 percent water mixture identified significantlylighter staining aroundpinholes 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 14

### Electronic Filing - Received, Clerk's Office, 05/31/2011
within an acceptable time period. 

### !d. Griefthen evaluated a 45 percent denatured alcohol and 55 percent water mixture. This mixture detected all ofthepinholes within 50 seconds of spraying- although with significantly lighter staining. 

### !d. Based on these test runs, Greif detennined that 55 percent dilution with waterwas the highest dilution percentagethat would allow theplant to meet its customer's quality assurance requirements. Greifinfonned the Agency ofthese test results and beganutilizing the diluted QC test fluid in May2008 to achieve immediate reductions in VOM emissions even though theAgency bad notformally approved the substitution. To date, thewater-diluted test fluid has allowed the detection ofdrum defects withoutbanningtheproduct. After detennining that the 45/55 QC testfluid mixture could satisfy appropriate QC standards, Greifconducted additional tests to detennine whefuer the amount ofQC test fluid applied to each 

### drum could bereduced. Based on this testing, Greifdetennined that it could reduce the QC test fluid sprayed into each drumto an amount not to exceed 48 grams. Dilutingthe QC test fluid with water and reducingthe amount offluid used also has the potential to reduce annual emissions ofVOM from the QC Test Process below the 25 tpy applicability threshold ofSection 218.980 and below the 22.8 tpy emissions limit in condition 3 oftl1e F.ESOP. This has been demonstrated bya significantreduction in overallfacility emissionsbetween 2007 and 2008 and the approximate 70% reduction in per drum emissions. In addition, diluting the QC test fluid with waterresults 

### in lower operating costs. Total capital costs to dilute the QC testfluid with water would be $0 and annualized capital and operatingcosts are reduced by $541 per ton ofVOC controlled. 

### See RACT Study atTable 4-1.

15

### Electronic 

### Filing- Received, Clerk's Office, 05/31/2011
4. ComplianceAlternatives Conclusion Three capture and control systems would be technically feasible: capture plus recuperative thennal oxiders, captureplus carbon adsorbers and captureplus biofilters and material substitution. While each ofthese options could achieve the 

### 81 percent capture and control objectives ofSubpart TT, the cost/ton ofYOM controlled range from $11,667 to $17,672. These costs exceed what the Board has considered reasonable in adoptingRACT regulations. See infra at Section TI(H)(l). Material substitution using acetone is technically**infea~ible** because ofproduct qualityissues. Material substitution using 55 percent water and 45 percent denatured alcohol combined with reducing the amount ofQC test fluid applied to each lined drum that is tested results in an overall reduction in costs while achieving an approximately 70% reduction inYOM emissions compared to pre-substitution levels. F. Greif's Proposed Adjusted Standard- Section 

### 104.406(f) Greifproposes the following adjusted standard for adoption bythe Board: 

### 1. The proposed adjusted standard applies to the emission ofYOM 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 of45 percent denatured alcohol and 55 percent water. 3. The QC TestProcess equipment will be calibrated to sprayno more than an average of48 grams ofQC test fluid per drum to bemeasured as foilows: onceperquarterGreifwill conduct a test to verifythat the average amount ofQC test fluid sprayed into at least five dnm1s meets this condition. 4. All records and logs required bythis adjusted standard shall be retained at areadily accessible location at the source for at least five years from the date ofentry and shall bemade available for 

### inspection and copyingby theAgency or USEPA upon request. Any records retained in an electronic format (e.g., complJter) shall be capable ofbeing retrieved and printed onpaper duringnormal source office hours so asto be able to

16

### Electronic Filing- Received, Clerk's Office, 05/31/2011 respond to an Agency-or USEPA request for records dming the course ofa source inspection. 5. Greifwill maintain records ofits denatured alcohol usage that will allow the monthly calculation ofthe amount ofdenatured alcohol used dming the month and the calculation ofVOM emissions on a 12-monthrolling total basis for comparison to annual VOM limits in the FESOP. 6. Greifwill continue to investigate the availability ofalternative QC test fluids with lowerVOM content. Greifwill incorporate such lower VOM QC test fluids into its QC Test Process provided that the lower VOM QC test fluids allow visual detection ofpinholes or other tears or imperfections inthe drwn linings within an acceptableperiod oftime and does not result in any negativeproduct quality impacts. 7. Greifwill coordinate with the Agency to submit to USEPA a request for revision ofthe SIP consistent witl1 this proposed adjusted standard requiring use ofthe diluted QCtest fluid and limiting the amount ofQC test fluid sprayed per drum as an alternative to capture and control technology. 8. Theproposed adjusted standard will not affect the calculation ofGreif's potential Emissions Reduction Market System ("ERMS") baseline or its ERMS allotment ifGreif's Naperville plant should participate in the ERMS program. 9. Environmental staffofGreif's parent will conduct a formal training session for Naperville facility personnel onthe requirements ofthe FESOP and the internal procedures for tracking compliance with FESOP conditions. 10. Greifwill continue to implement an improved system for monthlytracking and calculations ofVOM emissions and monthly comparison ofthe calculations to VOM limits contained in the FESOP. The results ofthe comparison will continue to bereported to Greif's facility management monthly so that any deviations orcxceedances ofFESOP conditions can be ideotified and timelyreported to the Agency as required by FESOP condition 6.



### 17

### Electronic Filing - Received, Clerk's Office, 05/31/2011 G. Quantitative and Qualitative Description ofGreif's Impact on the Environment Before and After the Proposed Adjusted Standard- Section 1 04.406(g) 

### 1. Air QualityImpactAnalysis ofGre(fs Operations 

### Application ofthe proposed adjusted standard will allow Greifto reduce YOM emissions from the QC Test Process by about 70% on aper drum basis compared to pre-change levels. While this 

### reduction is less than the 81 percent capture and control requirement ofSection 218.986(a), the proposed adjusted standard will allow Griefto reduce YOM emissions below levels required byits FESOP and the threshold for Subpart TT applicability. The emissions ofYOM from the QC TestProcess 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 Greiffiled its Amended Petition). Thus, even at the maximum permitted emissions levels for the Napervilleplant (22.8 tpybased on condition 3 ofthe FESOP), YOM emissions from the QC Test Process would amount to about 0.04% ofstate-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.govto Susan Charles responding to Freedom ofInfonnation Actrequest, attached as Exhibit B. Assuming maximum emissions permittedunder the FESOP for the Naperville plant, YOM emissions from the QC Test Process would amountto only 0.19% ofMetropolitan Chicago point source emissions. The Boardpreviously has found that adjusted standards from Subpart TT from sources with muchhigherYOM emissions would haveno significant impact on air quality. See, e.g., In theMatterof Petition of FordMotor Co. (Chicago AssemblyPlant) for an AdjustedStandard from 35R/. Adm. Code Section 218.986, 

### AS 00-6, Slip. Op. at 5 (April6, 2000) (uncontrolled


### 18

### Electronic Filing- Received, Clerk's Office, 05/31/2011
emissions of390tpy would haveno significant impact on air quality orlnunan health); In the Matter of Petition of Alumax, Inc.for anAdjustedStandard 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 aparticular concern for capture and control technologies, such as incinerators, tlmt create alternate emissions, e.g., NOx, which also contribute to ozone formation orhazardous 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 theMatter of JointPetition of Quantum Chemical Corporation, US! Division (and theJllinois EnvironmentalProtectionAgency) for anAdjustedStandard from Parts of35Ill. Adm. Code 

### 218.966and

### 218.986, AS 92-14, Slip. Op. at 9 (Board granted adjusted standard where use of control technology would emitNOx which, likeYOM, contributes to ozone fonnation, that would partially offset tl1e benefits ofYOMreduction). 

### 2. Cross-Media EnvironmentalImpactsResulting from an Adjusted Standard. None. Greifswaste and wastewater generation is independent ofYOM emissions from the QCTest Process; therefore, no change in the nature or volume ofwaste and wastewater is anticipated. H. Justification- Section 1 04.406(h) Where, as here, theregulation ofgeneral applicabilitydoes not specify a level of justification required for a petitionerto qualifyfor an adjusted standard, Section28.1 (c) ofthe lllinois Environmental Protection Act, 415 ILCS 5/28.1(c), authorizes the Board to grant an adjusted standard upon adequate proofofthefollowing: (1) the factors relating to iliepetitioner
are substantially and significantly different from ilie factors relied uponbythe Board 

### in adopting

19

### Electronic Filing- Received, Clerk's Office, 05/31/2011
the general regulation applicable to the petitioner; (2) the existence ofthose factorsjustifies an adjusted standard; (3) the requested standard will not result in environmental orheallh effects substantially and significantly more adverse than the effects considered bythe Board in adopting the mle ofgeneral applicability; and (4) the adjusted standard is consistent with applicable federal law. 

### 1. FactorsRelating to Grei(are Substanlial/v andSignificantlyDi([erent. The factors relating to Greif's abilityto reduce VOM emissions are substantially and significantlydifferent from any the Board mayhave relied on in adopting Subprut TT. First, the Boru·d did not relyon any specificindustry factors in adopting Subpart TT ru1d, therefore, the factors associated with Greif's operations arenecessarily "substantially and significantly" different. Second, Griefs ability to manageVOM emissions bydiluting its QC test fluid and limitingthe amount ofQC test fluid sprayed into each drum is substantially and significantly different from factors tl1e Board mayhave relied on in deciding to require caph.ire and control methods for managing VOM emissions. Third, even ifGreifcould not manage VOM emissions by dilution oftheQC test fluid, thephysical design ofGreif's operations and the slowevaporation ofits QC test fluid areunique 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 previouslyhas found to be economicallyreasonable.


### a. TheBoardDid Not Consider Factors Involving theDrum ManufacturingBusiness in 

### AdoptingSubpartTT. Subpart TT of

### Part 218 is essentially a "catch-all" applicable to VOM sources that are not governed by other subparts ofPart218. In adopting Subpart IT, the Board did not consider factors relating to any specific industry orpractice- includingthe fiber drmn manufacturing


### 20

### Electronic Filing- Received, Clerk's Office, 05/31/2011
business. Rather, the purpose ofSubpart

### TI**wa~** to cover sources that had notothc1wise 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 SubpartTT, virtually any factors specific to an industry or specific source not otherwise addressed in

### Part 218 would be "substantially and significantly different." See FordMotor Company (2000), AS 00-6, Slip. Op. at 

### 5. In FordMotor 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 assemblyplant. 

### ld. Slip Op. at 

### 1. TheBoard stated that Subpart

### TI applies to YOM
sources with certain characteristics that are not governed by other subparts ofPart 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 werenot considered in adopting Section 218.986(a), the requirement to demonstrate significantly different factors "is therefore met." 

### Jd. b. Greirs Ability toManage VOMEmissions Through Dilution ofits QC Test Fluid and Limitations on theAmountofQC TestFluidUsed Constitute Substantially and Significantly Different Factors. Even ifthe Board had considered factors impacting the capture and control ofYOM emissions at drum manufacturers when itpromulgated Section 218.986(a), it did not consider Greif's unique QC Test Process, the particular complexity ofconstmcting capture equipment
overan extended conveyor line orthe ability to manage YOM emissionsby diluting the QC test fluid with water and limiting the amount ofQCtest fluid applied to each drum. Construction of effective capture equipment is further complicated bytheneed to maintain physical access to the drums for visual inspection. This means theconveyor line cannot be totally enclosed to

21

### Electronic Filing- Received, Clerk's Office, 05/31/2011 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 QCTestProcess is Substantially and Significantly Different from OtherManufacturingActivities 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 withinthe Napervilleplant, the slow evaporation ofthe testing fluid and the need for Greifto inspect drums visually afterthe 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 ofthe drum conveyorlineis notpossible. These factors would require large capture systems, including ahood at the QC spray station, at the opening ofthe drum paint oven and along the conveyorused 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 SubpartTT 

### and will significantly impact Greif's costs to control VOM 

### emissions. See irifra at 

### Section II(H)(2). 

### d. Costs ofAchieving RACT Control StandardExceed those Considered byBoard in SettingRACT Standard. 

### In addition, as 

### reflected in the RACT Study, feasible technologies to achieve the 81 percent combined capture and control objective ofSection 218.986(a) would require costs per
22

### Electronic Filing- Received, Clerk's Office, 05/31/2011
ton ofannual VOM removed ranging from $11,667 to $17,672. These costs exceed the threshold cost level the Board previously has found to be economicallyunreasonable. See In the Matter of Petition of Forme/Industries, Inc.for anAdjustedStandard from 35Ill. 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 ofYOM reduced were economically unreasonable); FordMotor 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) (forproposition that ccsts exceeding $1,734 in 1996 dollars perton ofreductions was economically unreasonable); In the Matter of JointPetition of ReynoldsMetals Company and theIllinois EnvironmentalProtectionAgency for
an AdjustedStandard from 351AC2I8.980, 

### AS 91-8 (Sept. 21, 1995) (Board found $40,000 per ton ofYOM reduced to be economicallyunreasonable). 2. The Existence o(TheseFactors Justifies anAdjustedStandard. 

### The intent ofthe 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 FordMotor Company (ChicagoAssemblyPlant) 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 ofthe water-diluted test fluid as an adjusted standard reduces emissions from the QC Test Processbelow the applicability threshold for SubpartTT3 

### and below applicable FESOP limits while reducing costs. The 

### existence ofthese factors demonstrates that dilution ofthe QC test fluid constitutes RACT andjustifies the granting ofthe instant request.

3 Greifunderstands that SubpartlT is a "once in-always in" rule. 35 Ill. Adm. Code Section218.980(c). However, the fact that the diluted QC test fluid will bring emissions below the applicability threshold is ofsome significance because the Board certainly did not consider sources with uncontrolled emissions less than the threshold being subjectto SubpartTI. 

### 23

### Electronic Filing- Received, Clerk's Office, 05/31/2011
3. The RequestedStandard WillNotResult inAdverseHealth Effects. 

### The requested adjusted standard will have little, ifany, adverse impact on humanhealth
or the cnvir01m1ent. In 2009, state-wide VOM point source emissions were 54,668 tons. See IllinoisAnnualAirReport 

### 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 3ofthe FESOP), VOM emissions from the QC Test Process would amount to less than 0.04% of

### state-widepoint source emissions and only 0.19% ofMetropolitan Chicago emissions. The Board has previously fotmd that adjusted standards from Subpmt TT 

### from sources with much higher VOM emission levels would have no significantimpact on air quality. See, e.g.,Alumax, 

### AS 92-13, Slip. Op. at 9; FordMotor 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

### TTin 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 humanhealth); Quantum Chemical Corporation, 

### AS 92-14, Slip. Op. at 10 (Board agreed that operation ofemission units resulting in over260 

### 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 humanhealth). Moreover, the Board previously has found that a control plan resulting in an overall emissions reduction constitutes apositive 

### environmental impact. See FordMotor Company



### 24

### Electronic Filing- Received, Clerk's Office, 05/31/2011 (2002), AS 02-3, Slip. Op. at 4. InFord, the Board fotmd that a 50 tpy reduction ofVOM emissions (from 390tpy to 340 tpy- or 13%) was "significant" and would have a "positive impact on air quality." 

### Id. Here, dilution oftheQC test fluid and limitation on the amount of QCtest fluid used per drum is producing roughly a 70% reduction ofVOM emissions- an even greaterreductionon a percentagebasis than what was 

### at issue in theFordpetition. 

### 4. The RequestedStandard is Consistent with FederalLaw. Section 110 ofthe federal Clean AirAct, 42 U.S.C. 

### §7410, grants individual states the authority to promulgate

### a planfor implementation, maintenance and enforcement ofair quality standards, subject to approval byUSEPA. Based on theRACT Study, the proposed adjusted standard constitutes RACT for the Greiffacility, and is therefore consistent with the federal Clean AirAct. A state may revise its SIP, again subject to USEPA approval. 42 U.S.C. 

### § 7410. Greifwill work with the Agency to submit a SIP revision to USEPA that is consistent with any adjusted standard granted bythe Board. 

### J. Hearing-Section 104.4060) Greifrequests 

### aheruing in this matter. K. SupportingDocumentation- Section!04.406{k) 

### 1. RACT Study, attached to this Petition 

### as ExhibitA. 2. FOIA Response from illinois Environmental ProtectionAgency, Bureau ofAir, attached to this Petition 

### as Exhibit B. 

### III. CONCLUSION Greifrequests thattheBoard grant the proposed adjusted standard 

### as an altemative to the RACTregtJlations adopted bythe Board in Subpart

### IT. To require Greifto comply with the requirements of35 

### ill. Adm. Code Subpart TT, Section 218.986(a), would resultin substantial economichardship to Greifwith no corresponding environinental benefit. Certain compliance

25

### Electronic Filing - Received, Clerk's Office, 05/31/2011 options examined by Greifcould have the reverse effect ofcreating increased emissions ofother pollutants and envirorunental detriment. Finally, add-on controls arc unreasonably expensive, provide little, ifany, envirorunental benefit and certain control options may result in increased health and safety risks.
WHEREFORE, Greif, Inc. requests that the Board grant Greifthe proposed adjusted standard from 35 Jll. Adm. Code, Subpart IT, Section 218.986(a), as that rule applies to the emissions ofVOM from GreifPackaging LLC's operations inNaperville, 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: 

### RevisedMarch 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 ThermalIncinerators
.......................................................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 

### QCTestFluid- Dilution with Water
.....................................................3-2 3.3.2 

### QCTestFluid- 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 ProjectNo. 8003 

### CAPITAL AND ANNUAL COSTS FOR THERMAL OXIDIZER WITH RECUPERATIVE HEAT EXCHANGER CAPITAL AND ANNUAL COSTS FOR CARBON ADSORBER

iiR bl 

### Flectronic FJ"Iina -1

### Received, Clerk's Office, 05/31/2011 easona jAvm?abfe-contra 1eCHno ogy study August2010: RevisedMarch 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 studywas undertaken to evaluate the reasonably available control technologies (RACT) options that couldbe implemented at the quality control (QC) testing process emission unit ofthe GreifPackaging LLC (Greif) fiber container facility in Naperville, Illinois. The options arebeing considered to dete1minc ifthe 81% combined capture and control requirement of35 IAC 218.986 is technically achievable and economically reasonable for the QC testing process emission unit and, ifnot, to identifyequivalent 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 ofat least·81 percent through the application ofemission capture and control equipment. Capture technologywould involve a combination ofpen11anent total enclosures and exhaust hoods designed to achieve at least 90percent capture ofVOM at the QC testingprocess. The following control equipment options were eval?ated forpotential implementation in connection with 90 percent capture methodology:
• Recuperative them1al incinerator
• Carbon adsorber
• Biofilter In addition, the following methods ofVOM emissionreduction were evaluated as possible equivalent alternative controlplans:
• Dilution ofthe QC testing process fluid (amixture ofsolvents, primarily denatured alcohol) with water
• Dilution ofthe QC testingprocess fluid with acetone (a non-VOM material) Therecuperative thermal incinerator, biofilter, carbon adsorption, and QC testing fluid dilution options were completely evaluated. Dilution ofthe testing fluid with acetone was determined to beteclmically infeasible. Acetone, does not work at Naperville since it causes the gasket material which seals thebottom ofthe drum to the drum walls to dissolve. Due to this problemwithproduct damage, diluting the QC test ·fluid with acetone was detem1ined to be infeasible. Capture ofemissions from the QC test process is complicatedbyslowly evaporating solvents in the testing fluid and theneed for employees to inspect each drum visually
TCP ProjectNo. 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 QCtest station. Thenthe 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 ofemissions at the QC test station, itself, the conveyors, and the dnnnpaint oven. This is a very complicatedcapture system that requires tunnel enclosures arotmd the conveyors. The QC test process station must be enclosed and tbe opening to dmm paint oven mustbereduced to ensure the desired 90 percent capture of the emissions. The control system requires both enclosures ofthe 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- 3,000ACFM
• Tutmel to Inspection Station- 2,000 ACFM
• Inspection Station- 5,000 ACFM
• Tunnel to Drying Oven- 5,000 ACFM
• Drying Oven- 5,000 ACFM Thetotal flow to the control deviceis estimated to be 20,000ACFM to ensure adequate capture to meet the overall 81% control objective. Each ventilation system was designed for a face velocity of 150 feet perminuteto attain adeqtlate capture. The spraystation would have an opening offourfeet byfive feet on the hood overthe spray station. The inspection station would bave an opening ofsixfeet byfive and balffeetto allow access bythe inspectors. The conveyorfrom the spray stationto theinspection boothis 45 feet. Asstuning a hood clearance oftwo inches on each side ofthe dnun requires 2,000 ACFM ofventilation to maintain the 150 feet perminute face velocity. Theconveyor from the inspection station to theovenis 120 feet. A ventilationrate of5,000 ACFM will maintain a face velocity of150 feet perminute. The ventilation rate ofthe drying oven is 5,000 ACFM. Because ofthe difficttlties with the capture system, the air flow rate to the control device will necessarilybehigh. This creates the need for larger control systems, which impacts costs. As reflected inTable 1-1, the costs ofVOM control stated in terms ofdollars per ton ofannual VOMreduction range from $11,167 to $17,672. Thisrange ofcontrol costs is higherthan the level ofcosts considered to be economicin adopting RACT controls.

TCP ProjectNo. 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 theenvirornnental benefits ofVOM reduction. Thermal oxidizers use large quantities ofnatural gas. Fuel will beused even when the QC testprocess is not operating to maintain thethennal oxidizer attemperature. Frequent operation cycles in thennal oxidizers cause condensation corrosion and thermal deterioration ofthe insulation. Thennal oxidizers emit NOx and CO and small quantities ofVOM and HAPS are also emitted. These emissions will partially offset anybenefits obtained from VOMreduction. Carbon adsorbers also have drawbacks. Since all ofthe solvents usedin the QC test process are water soluble, the used solvents can notbe recovered from the carbon adsorbers without an elaboratedistillation system. Given these difficulties, the condensed regeneration fluid is commonly discharged with wastewater to the sewers. Depending on the type oftreatment system at the municipal treatment facility, theVOMmaynotbebiodegradedbut simplyblown into the atmosphere in an equalizationbasin, In that case, VOM emission reductions at thefacility will be offsetby higher emissions at the treatment facility. Biofilters mustbeheated to maintain destruction activityduring wintermonths. Heat for thebiofilter can be suppliedbythe direct combustion ofnatural gas, steam, orelectricity. Natural gas combustion would increaseNOx emissions from thefacility. Inaddition, the large size oftheseunits may limit feasible locations at a facility. Also, the biofilter cannot achieve the 81% control objectiveby itselfand would require an additional control system orthe counting ofthe QC test fluid dilution as a control technology to achieve that objective. In contrast, diluting the QC test fluid with water hasbeen calculated to reduce annual emissions ofVOMbelow the 25 tons peryear (tpy) threshold for applicabilityofSection 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 inplace ofthe 81% capture and control requirement ofSection 218.986(a).

TCP ProjectNo. 8003 4

### Electronic Filing- Received, Clerk's Office, 05/31/2011

2.0 FACILITY INFORMATION

Greifoperates a fiber container manufacturing facility in Naperville, Illinois. The primary activity involves the cutting offiber material into appropriate lengths, molding the shapes into a drum and connectingtops and bottoms to the dmm sides. YOM emissions are minimal in the actual drum making operation. Emissions occur during the application ofcaulk, silk screening ofinf01mation onto the drum, and in drum painting
.. Combined YOM emissions from all these units are currentlypennitted at amaximum of 1.4 tpy, and Greifhas proposed increasing the emissions from thoseunits to an aggregate of2.6tpy. Under 35 IAC 218.980(d), theseunits·are exempt from the requirements ofSection 218.986 becatJse no single unit emits greaterthan 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 requiredby customers to have polyethylene liners, primarily to comply with requirements for food grade containers. Drums with these liners mustbe tested to ensure that the liner is free from pinholes orothertears or imperfections. The QC TestProcess emission unit involves the spraying ofa YOMcontaining liquid onto thepolyethylene liner, which causes imperfections in the liner to become visibleto thenaked eye and detectable to plantpersonnel who inspect each ofthe lined drums as itproceeds through the process on a conveyorbelt. Atthe Naperville plant, onlythe QCTest Process emissionunitemits significant quantities ofYOM emissions. Emissions from the QCTest Process are currentlypermitted at 22.8 tpy, and Greifhas proposed to reduce those emissions to a maximum of21 tpy. Accordingly, tllis study only assesses RACT options for the QCTest Process emission unit.

TCP Project No. 8001 I

### Electronic Filing- Received, Clerk's Office, 05/31/2011
3.0 CONTROL TECHNOLOGIES 

### Briefdescriptions ofthe capture and control systems evaluated for this study are given inthe following sections. 

### 3.1 Capture Systems Due to the slow evaporation rate ofthe 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 ofthe 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 ofthe VOMs. This system has heat recovery as great as 60%. The primary advantages ofthis control system are lower annual costs relative to other incinerators and flexibility in handling arange ofVOM materials. The primary disadvantages of this control system relative to other control options are higher operating costs due to the amount ofnatural 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 oftwo or more beds of activated carbon. One bed is treating the exhaust emissions while the otherbed is being regenerated. Large systems mayhave several beds on stream while a bed is being regenerated. Carbon adsorbers work best with insoluble VOMs, which simplify the recovery ofthe 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 offires 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 Greifdrum 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 bemet only by combining the biofilter with another control technology orby considering the reductions in YOM emissions from the use ofthe 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 ofnatural 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 ofdenatured alcohol and water. The goal ofthe 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 offive 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 ifthe 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. Ifthe 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 of70% denatured alcohol and 30% water. As with the first test fluid, this second mixture allowed the detection ofall 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 ofthe pinholes were not visible when the drums reached the inspector station. Continued observation ofthese dmms from the inspector station to the drying oven revealed that the pinholes did not even become visibleby 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 ofdrums with defects in the polyethylene liner. TI1is diluted test fluid is less expensive than the previously used test fluid consisting of I00% 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 ofthe fiber drum to the walls ofthe 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 ofeach ofthe 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 costperton ofVOM controlled. 

### 4.1 Capital Costs Theprocedures 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 ofAir Pollution Control"byWilliam 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 ofthe 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 costfor 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 ofmoney used to finance the project and detennining the depreciation ofthe equipment. Although there are other methods for determining these costs, capital recovery is usedbyEPA in RACT analysis in dete1111ining the cost per ton ofpollutants 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 ofat least 81 percent through the application of emission capture and control equipment. In adoptingthat requirement, the Illinois Pollution Control Board considered a level ofcostperton ofestimated VOM reductions that would typically beincurred to achieve the 81% standard. In 1996 dollars, the Board's RACT cost threshold was a maximwn of$1,734 per ton ofVOM controlled. Inre: Petition ofLouis 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 perton ofVOM controlled. In addition, all control systems for thereductionofVOM emissions have inherent characteristics that would patiially offset the enviromnental benefits ofVOM reduction. Thermal oxidizers use large quantities ofnatural gas. Fuel will beusedeven when the QC testprocess is not operating to maintain the thermal oxidizer at temperature. Frequent operation cycles in thermal oxidizers cause condensation corrosion and thermal deterioration ofthe insulation. Thermal oxidizers emit NOx and CO and small quantities ofVOM and HAPS are also emitted. These emissions will partially offset anybenefits obtainedfrom VOM reduction. Carbon adsorbers also have drawbacks. Since all ofthe solvents used in the QC test process are water soluble, theused solvents cannot berecovered from the carbon adsorbers without an elaborate distillation system. Given these difficulties, the condensed regeneration fluid is commonly discharged with wastewaterto the sewers. Depending on the type oftreatment system at the municipal treatment facility, the VOM may not bebiodegradedbut simply blown into the atmosphere in an equalizationbasin. In that case, VOM emission reductions at the facility will be offset by higher emissions at the treatment facility. Biofilters mustbe heated to maintain destruction activity during winter months. Heat for the biofilter canbe supplied bythe direct combustion ofnatural gas, indirect steam heat, or electricheaters. Natural gas combustion would increaseNOx emissions fi·om the facility. In addition, the large size ofthese units may limit feasible locations at a facility. Also, the biofiltercannot achieve the 81% control objective by itselfand would

TCP Project No. 8003 5

### Electronic Filing- Received, Clerk's Office, 05/31/2011 require an additional control system or the counting ofthe QC test fluid dilution as a control technology to achieve that objective. In contrast, diluting the QC test fluid with waterhas 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,$ CosI, 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 forThermal oxidizers with Recuperative Heat Exchangers

### Electronic Filing- Received, Clerk's Office, 05/31/2011 Recuperative Incinerator Costs - 20000 acfm (All costs are in, orhave been adjustedto, 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 Ifflow 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 ofAir Pollution Control--calculated] -Fan: -Enclosure: -Ductwork:

- Instrumentation: 32,354 [Estimating Costs of Air Pollution Control-calculated] 129,417 (Estimating Costs ofAir Pollution Control-calculated) 64,709 (Estimating Costs ofAir Pollution Control-calculated] 48,532 [Estimating Costs ofAir 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 ofAir Pollution Control-calculated) Indirect installation costs: $ 117,951 [Estimating Costs ofAir 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 ofVOC controlled Cost per ton ofVOC 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, orhave 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 ofAir Pollution Control-calculated] 81,623 [Estimating Costs of Air Pollution Control--calculated] 40,812 [Estimating Costs ofAir 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 ofVOC controlled 36.39 Cost per ton ofVOC 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 ofAir 

### 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 ofAir- 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) ofVolatile 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 request

### ExhibitB 1124/2011