## Electronic Filing- Received, Clerk's Office, June 17, 2011 IEPA ATTACHMENT NO.

## _k._ BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF: PETITION OF GREIF, INC. AND GREIF PACKAGING, LLC FORAN ADWSTED STANDARD FROM 35 ILLADM. CODEPART218 SUBPART IT ) ) 

### ) ) ) 

### ) ) AS 2011-001 (Adjusted Standard- Air)

NOTICE OFELECTRONIC FILING TO: John Therriault, Clerk Illinois Pollution Control Board James R. Thompson Center 100 West Randolph Street, Suite 11-500 Chicago, IL 60601 Charles Matoesian Division ofLegal Counsel Illinois Environmental Protection Agency 1

02I North Grand AvenueEast P.O. Box 19276 Springfield, IL 62794-9276 PLEASE TAKENOTICEthat I have today electronically filed with the Office ofthe Clerk ofthe Illinois Pollution Control Board,Petitioners' NOTICE OFELECTRONIC FILING, PROOF OFPETITIONNOTICE REQUIREMENTS and CERTIFICATE OF SERVICE, copies ofwhich are attached herewith and servedupon you.

Date: June 17, 2011 Thomas W. Dimond Susan Charles ICE MILLER LLP 200 WestMadison Street Suite 3500 Chicago, Illinois 60606 Respectfully submitted, GREIF, INC. and GREIF PACKAGING, LLC By: 

### Is/ Susan Charles One ofits Attorneys

1

## Electronic Filing- Received, Clerk's Office, June 17, 2011

BEFORE THE ILLINOIS POLLUTION CONTROLBOARD
IN THE MAlTER OF: PETITION OF GREIF, INC. AND GREIF PACKAGING, LLC FOR AN ADJUSTED STANDARD FROM 35 ILL ADM. CODE PART 218 SUBPARTTT 

### ) ) ) ) ) ) 

### ) AS 2011-001 (Adjusted Standard- Air)



### PROOF OF PETITION NOTICE REQUIREMENTS Pursuant to 35 Ill. Adm. Code Sections 104.408 and 104.410, on June 10,2011, petitioners Greif, Inc. and GreifPackaging, LLC ("Greif'') published notice ofthe filing oftheir Amended Petition for an Adjusted Standard ("Petition")by advertisement in a newspaper of general circulation in the area ofGreif's Naperville plant. In support ofthis filing Greifstates the following: I. Greiffiled the Petition with the Clerk ofthe Illinois Pollution Control Board on May 31,2011. 2. Pursuant to the Petition, Greifseeks an adjusted standard from 35 Ill. Adm. Code 

### §218.986(a) as itapplies to control requirements for emissions ofvolatile organic material at Greif's fiber drum manufacturing facility located inNaperville, Illinois. 3. On June 10,2011,Greifpublished notice ofthe filing ofthe Petition by advertisement inthe

### 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 v..ithin 14 days after it filed thePetition. 5. The notice includes the specific language required by 35 Ill. Adm. Code Section 104.408(b).

## ElectronicFiling -Received, Clerk's Office, June 17, 2011

6. As required by 35 

### Ill. Adm. Code Section 104.410, a certificate.ofpublication issued by the publisher ofthe

### Naperville Sun certifyingpublication ofthe notice on June 10, 2011 is attached as Exhibit 1. The certificate ofpublication attaches Greifs notice as it appeared in the

### Naperville Sun and states that the

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

### etseq. The language included in Griefsnotice is consistent with 35 

### Ill. Adm. Code Section 104.408(b). WHEREFORE, for the reasons stated above, Greifhas satisfied the requirements for providing notice ofthe filing ofits Amended Petition for an Adjusted Standard and for filing proofofsuchnotice with the Illinois Pollution Control Board.

Date: June 17, 2011 Thomas W. Dimond Susan Charles ICEMlLLERLLP 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, June 17, 2011 CERTIFICATE OF SERVICE I, the undersigned, certify that on this 17th day ofJune, 2011, I have served electronically the attached NOTICE OF ELECTRONIC FILING and PROOF OF PETITION NOTICE REQUIREMENTS upun the following person: John Therriault, Clerk Illinois Pollution Control Board James R. Thompson Center 100 West Randolph Street, Suite 11-500 Chicago, IL 6060I and by U.S. Mail, first class postage prepaid, to the following persons: Charles Matoesian Division ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276 Is/

### Susan Charles Susan Charles

## Electronic Filing- Received, Clerk's Office, June 17, 2011 ICE MILLER LLP Greif, Inc. Docket Number 2011-001 ADORDERNUMBER: 0000088046-01 PO NUMBER: Greif, Inc. Docket Numbe AMOUNT: $240.00 NO OF AFFIDAVITS:

ICE MilLER LLP 2300 CABOT DR STE 455 LISLE, IL 60532-4613 

### Sun Times Media Sun-Times Media West Certificate of Publication StatG of Illinois**~County** of DuPage Sun-Times Media West, does hereby certify It has published the attached advertlsments in the following secular newspapers. All newspapers meet Illinois Compiled 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. Amende<l by Laws 1959, P1494. EFF. July 17, 1959. Formerly Ill. Rev. Slat. 1991, CH100, Pl. Note: Notice appeared in the following cheeked positions. PUBLICATION DATE{S): 

### 0611012011 Naperville Sun

IN WITNESS WHEREOF, the undersigned, being duly authorized, has caused this CertifiCate to be signed and notarized By

## a"";,A~~ {/ John G. Bieschke Account Manager - Public Legal Notices Subscribe<l and**swo~** to before me this 

### 14: June

### 2011 A.D. 

# &zLzJ.£4/

# a :/JIU<_ Notary Public 

### Exhibit 1 OFACIALSEAl. CATHERINE ACVNCAR NOTARYPUBliC, STATE OF IWNOIS KANE COUN'!Y MY COMMISSION EXPIRES 11/1912014

## ElectronicFiling

- Received, Clerk's Office, June 17, 2011

### Electronic Filing- Received, Clerk's Office, 08/10/2011 

# 7 IEPA ATTACHMENT NO.

__ 

### BEFORETHE ILLINOIS POLLUTION CONTROL BOARD IN THE MATIER OF: PETITION OF GREIF PACKAGING, LLC FOR AN ADJUSTED STANDARD FROM 35 

### ILLADM. CODE PART 218 

### SUBPARTTT ) ) ) ) ) ) 

### AS 2011-01 

### (Adjusted Standard- Air) NOTICE OF ELECTRONIC FILING TO: John Therriault, Clerk Illinois Pollution Control Board James R. Thompson Center 100

### West Randolph Street, Suite 11-500 

### Chicago, IL60601 

### Charles Matoesian Division ofLegal Counsel lllinois Environmental Protection Agency 1021 

### North Grand Avenue East P.O. Box 19276 

### Springfield, IL 62794-9276 

### PLEASE TAKE 

### NOTICE that I have today electronically filed with the. Office ofthe Clerk ofthe Illinois Pollution Control Board, Petitioner's NOTICE OF ELECTRONIC FILING, SECOND AMENDED PETITION FORAN ADJUSTED STANDARD and CERTIFICATE OF SERVICE, copies ofwhich are attached herewith served upon you.

Date: August 10, 2011 

### Thomas W. Dimond Susan Charles ICE MILLER LLP 200 

### WestMadison Street Suite 3500 

### Chicago, Illinois 60606 

### Respectfully submitted, ICE MILLER, LLP By: 

### Is! Susan Charles One ofits Attorneys

### Electronic Filing- Received, Clerk's Office, 08/10/2011

CERTIFICATE OF SERVICE I, the undersigned, certify that on this lOth day ofAugust, 2011, I have served electronicallythe attached NOTICE OF ELECTRONIC FILING and SECOND AMENDED PETITION FORAN ADJUSTED STANDARDupon the following person: John Therriault, Clerk IllinoisPollution Control Board James R. Thompson Center 100WestRandolph Street, Suite 11-500 Chicago, lL6060I andby electronic and U.S. Mail, first class postageprepaid, to the following persons: Charles Matoesian Division ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O. Box 19276 Springfield,IL 62794-9276 

### Is/ Susan Charles Susan Charles

## Electronic Filing- Received, Clerk's Office, 08/10/2011

BEFORE THE ILLINOIS POLLUTION CONTROLBOARD
IN THE MATTER OF: PETITION OF GREIF, INC. AND GREIF PACKAGING LLC FOR AN ADJUSTED STANDARD FROM 35 ILL ADM. CODEPART218 SUBPARTTT 

### ) ) ) ) ) ) ) AS 2011-001 (Adjusted Standard- Air)

SECOND AMENDED PETITION FOR AN ADJUSTED STANDARD GREIF, INC. and GREIF PACKAGING LLC ("Greif'), through counsel and pursuantto 35 Ill. Adm. Code§ 104.400, 

### etseq., submit this Second Amended Petition for anAdjusted 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 the emissions ofvolatile organic material ("YOM") into the atmosphere from Greif's fiber drum manufacturing facility located at 5 S 220 Frontenac Road in Naperville, DuPage County, Illinois. I. INTRODUCTION AND SUMMARY OF PROPOSED ADJUSTED STANDARD Greifoperates a fiber (paper) drum containermanufacturingfacility in Naperville, DuPage County, nlinois. 

### In general, fiber drums are produced bycutting fiber material to the appropriate length, forming the material into a cylinder and attaching a top and bottom to the cylinder. Someofthe fiber drums require the addition ofa polyethylene drumlinerto meet customerspecifications,particularlyfor storage and transport offood-grade products. Greif conducts quality control ("QC") testing ofthe linern ofthese drums by spraying a QC test fluid (a denatured alcohol product, which is a YOM) into the interior ofthe drums atthe QC spray station.



### 1

## ElectronicFiling- Received, Clerk's Office, 08/10/2011

Greifuses an automated system to spraytne interiorofthe drum liners with QC testfluid. As adrum moves along the conveyorbelttoward the QC spray station it triggers a sensoron the guide rail that causes the drum to stop. Amechanical wand then drops down into the drum and sprays the QC testfluid. The wand is calibrated so that each spray releases about the same amount ofQC testfluid into each drum. Once the QC test fluid hasbeen sprayed onto the drum 

### liner, the wandretracts so the drum may continue to move along the conveyor. The drums then are conveyed45 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, enablingthe line inspector to detect thepinhole. The drum nextis conveyed 120 feet to adrying oven where most ofthe remaining test fluid is evaporated. Afterleaving the drying oven anyremaining fluid is vacuumed from the drum and then the drum is wiped dry. VOM is emittedthroughout the QC Test Process as well as inthepaintdrying oven. Greiftracks its VOM emissions on amonthlybasis by calculating themass ofVOMs used and assuming that all usage is emitted to the atmosphere. To calculate mass, Greifrecords the volume ofde!llltured alcohol held as inventory on the first and lastday ofeach month. Greif also tracks thevolume ofany denatured alcohol purchased within each month. The volume of denatured alcohol purchased during amonth is added to the inventoryheld on the ftrst day of that month. The total, less any inventoryremaining on thelast day ofthemonth, equals the volume ofdenatured alcohol used. The volumeis then multiplied bythe VOM content (in pounds per gal) ofthe denatured alcohol to compute the mass (in pounds) ofVOM emitted during themonth.



### 2

## Electronic Filing

- Received, Clerk's Office, 08/10/2011

Air emissions ofVOM and hazardous airpollutants ("HAPs") at Greif's Naperville facility are subject to Federally Enforceable State Operating PermitNo. 9707044 ("FESOP"). 1 

### Condition 3 oftheFESOP limits VOM emissions from the QC TestProeess to 22.8 tons per year ("tpy"). Condition 3 also includesemissionunit specific limitson VOM emissions from the remainder ofthe plant (which includes apaint spray booth, acaulk applicator, and ink printing). The aggregate ofthese limits is 1.4 tpy. TheFESOP 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 ofl.87 tons. On July 5, 2007, the Illinois Environmental ProtectionAgency ("Agency") issued Violation Notice A-2007-00132 ("Violation Notice") to Greifalleging, in relevantpart, that the Naperville fucility exceeded condition 3oftheFESOP, relatingto YOM emissions. Greif reported emissions from the QC TestProcess in 2006, 2007, 2008, 2009 and 2010 of35.2, 46.7, 19.1, 7.7 and 8.95 tons, respectively. The Agency alleges that Greif's VOM emissions now arc subject to the 81 percentcaptureand control requirements of 35111. Adm. Code Part 218, SubpartTI, Section 218.986(a), because emissions in 2006 and 2007 exceededthe 25

### tpy applicabilitythreshold and because SubpartTT is a "once in- always in" regulation. 

### See 35 Ill. Adm. Code Section218.980 (a)- (c). The Board promulgated 35 Ill. Adm. CodePart218 to implementreasonably available control technology ("RACT'') for sources ofVOM emissions within certain areas ofIllinois. 

### See In lheMatter of ReasonablyAvailable Control TechnologyforMajorSources Emitting Volatile

In2006, theFESOP was issued to GreifBros. Corporation, whichhad changed its name to Greif; Inc. Greif, Inc, has lransferred ownership and operation ofthe Naperville plant to its whoUy owned subsidiary, Greif Packaging LLC. When the FESOP ls renewed, it will also betransferred into the name ofGreifPackaging LLC.



### 3

## Electronic Filing Received, Clerk's Office, 08/10/2011 Organic Materials in the Chicago OzoneNonat/ainmentArea: 25 Tons, R93-14, Final Order (January 6, 1994). Section 218.986provides, in relevantpart: Every owner oroperator ofan emission unit subject to [Subpart TI] shall comply with the rtXjuirements ofsubsection (a), (b), (c), (d), or (e) below. a) Emission capture and control tXjUipment which achieves an overall reduction in uncontrolled VOM emissions of at least 81 percentfrom each emission unit .... Greifconducted aRACT Studyto evaluatewhether various emission control options for the QC TestProcess satisfY RACT control rtXj·uirements 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 RACT Studyto the Agency on September 16, 2010. The RACT Study evaluated three capture and control systems: capture plus recuperative thennal oxidizers, captureplus carbon adsorbers and capture plus biofilters and material substitution. TheRACT Study concludes that each option could achieve atleast 81 percent capture and control ofVOM emissions as required under Section 2l8.986(a), but only at acost per tonofVOM emissions controlled ofbetween $11,667- $17,672. These costs exceed whattheBoard typically bas consideredreasonable in adopting RACT regulations. 

### See infra at Section II(H)(l)(d). TheRACT Study also evaluated the 

### technical feasibility and economic reasonableness of two material substitution options: mixingthe 

### QC test fluid with acetone or water. Material substitution using acetone was found to 

### betechnically infeasible because ofproductquality concerns related to the effect ofacetone on theproduct. Acetone in

### the QC test fluid causes the gasketmaterial that seals the drum bottom to the sidewalls to dissolve, which is unaccej)table. However, material substitutionusing a test fluid composed of45 percentdenatured alcohol and 4

## Electronic Filing- Received, Clerk's Office, 08/10/2011

55 percent water achieves a 55 percent reduction in YOM emissions and results in an overall cost reduction. The RACf Study concludes that the material substitution option using 45 percent denatured alcohol and 55 percent water constitutes RACT for Griefs Naperville facility. After determining that the 45/55 QCtest fluid mixture could satisfy appropriate product quality standards, Greifconducted additional tests to determine whether the amount ofQCtest fluid applied to each drumrun through its QCTest Process could bereduced. Based on this testing, Greifdetermined that it could reduce the QCtest 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). IT. 35 ILL. ADM. Code Section 104.406: Petition for Adjusted Standard Theprocedural requirements for submission ofan adjusted standard petition to the Board

are found at 35 Ill. Adm. Code Part 104,Regulatory ReliefMechanisms, SubpartD. Sections 104.406(a)- (I) ofSubpartD specify the information that mustbeincluded in any adjusted standard petition. Therequisite headings and corresponding informationrequired under Subpart D are set forth below. A. Standard From WhichReliefls Sought- Section I04.406(a) Greifseeks an adjusted standard from the requirements of35 Dl. Adm. Code Part218, Subpart TT, Section 218.986(a), Control Requirements, which sets emissionreduction requirements for sources ofYOM emissions not regulated under other subparts ofPart218. Section 218.986became effectiveJanuary 6, 1994. RACT for Chicago Ozone, R93-14. Pursuant to Section 218.980(b )(1), the applicability threshold for SubpartTT is thepotential to emit 25



### 5

## Electronic Filing- Received, Clerk's Office, 08/10/2011 tpy ofYOM, in the aggregate, from emission units at a source otherthan those specifically excluded from Subpart TI. The control requirements for qualifying emission units at sources subject to Subpart TIare set forth in Section 218.986. Section 218.986 provides, in relevant part: Every owner oroperator ofan emission unit subject to (Subpart TI] 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).2 

### As Greifwill demonstrate, achieving capture 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 maypose increased health and safetyrisks. Other alternative control strategies are technically infeasiblebecause 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 limitthe amount ofQC test fluid that willbe sprayed into each drum. Theseproposed modification ofthe QC Test Process will reduce YOM emissions from Greif's QC TestProcess byapproximately 70 percent on aunit basis- to an annual emission level that is below the applicability threshold ofSubpartTI.

2 Subsections (b)- (e) are not applicable to the QCTestProcess atNaperville and thus arc not included in this Petition. See 35 ill. Adm. Code Section 218.986(b)- (e) (applicable to: coating lines (subsection (b)), submission ofan equivalentalternative control plan (subsection (c)),non.;;ontactprocess cooling water (subsection (d)) and specific control measures applicable to leaks from components subjectto the control requirements ofSubpartTI (subsection (c))). 

### 6

## Electronic Filing

- Received, Clerk's Office, 08/10/2011

Greifwill not require an adjusted standard from Section 218.108, "Exemptions, Valiations, and Alternative Means ofControl or Compliance Determinations" 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 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 bythe USEPA as a SIP revision. While the Agency will need to request the United States Environmental 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 granting by the Board. See In the Matter of Petition of AlumaxInc.for anAdjustedStandard from 35Ill. Adm. Code Part218, AS 92-13, Slip. Op. at 4 (September 1, 1994); see also, In the Matter of ReasonablyAvailable Control Technology forMajor SourcesEmitting Volatile OrganicMaterials in the Chicago OzoneNonattainment Area: 

### 25 Tons, R93-14, Slip. Op. (Second Notice) at 5-6 (November 18, 1993). 

### B. Nature oftheRegulation ofGeneral Applicability- Section 104.406Cb) TheBoardpromulgated 35 Ill. Adm. Code Part 218 to implement Section 182(b)(2) of the CleanAirAct, 42 U.S.C. §7511a(b)(2), which, among otherthings, requires individual states with severenon-attainment areas to adoptRACfregulations applicable to sources ofYOM emissions within the non-attainment area. See RACT for Chicago Ozone, R93-14, Slip Op. (Final Rule) at 2. As mandatedbythe Clean Air Act, the Boardpromulgated Part 218, including SubpartTI. Id. 7

## Electronic Filing -Received, Clerk's Office, 08/10/2011

C. Level ofJustification- Section 104.406(c) Theregulations ofgeneral applicability fi-om which Greifseeks an adjusted standard do not specify a level of justification for an adjusted standard. Accordingly, the level of jtJStificationis that generally applicable to all adjusted standards. See 

### 415ILCS 5/28.1 (Authorizingthe Board to grant an adjusted standard upon adequateproofofthe following: (1) thefactors relatingto the petitioner are substantially and significantly different from the factors relied upon by theBoard in adopting the general regulation applicable to thepetitioner; (2) the existence ofthose factorsjustifies an adjusted standard; (3) the requested standard will notresult in environmental orhealth effects substantially and significantlymore adverse than the effects considered by theBoard in 

### adopting the rule ofgeneral applicability; and (4) the adjusted standard is consistentwith applicable federal law.). D. Facility and Process Description- Section 104.406(d) Greifoperates afiber drum 

### containermanufa"'turing facility in Naperville, DuPage County,Illinois. DuPage County is part ofthe Metropolitan Chicago InterstateAirQuality Control Region. 40 C.F.R. § 

### 81.14. This area is designated as a non-attainment area for ozone (1-hour and 8-hourstandard) under40 C.F.R. §

### 81.314. The Naperville facility employs about 90hourly and salariedpeople. Fiber drum 

### manufacturingbegan at the Naperville plant in April1988. Greif's Naperville facility manufactures fiber drums ranging in size from six (6) gallons to seventy-five (75) gallons. 

### In. general, fiber dnuns areproducedbycutting fiber material to the appropriate length, forming it into acylinder and attaching atop and 

### bottom to the cylinder. Some ofthe fiber drums require the addition ofapolyethylenedrum liner to meet customer specifications, particularly for storage and transport offood-gradeproducts.

8

## ElectronicFiling- Received, Clerk's Office, 08/10/2011

Greifconducts QC testing ofthe drwn liners as follows: (1) as a drum moves along the conveyorbelttoward the QC spray station it triggers a sensor on the guiderail causingthe conveyorbelt to stop; (2) amechanical wand drops into the drum and releases the QC test fluid; (3) themechanical wand retracts, the conveyor beltis restarted and the drum is conveyed 45 feet to the QC inspection station where the interior is visually inspected for pinholes (ifpinholes arc present, the ethanol causes a brown spot to appear, enabling the line inspectorto detect the pinhole); (4) the drum is conveyed 120 feet to a drying oven where most ofthe remaining test fluid is evaporated; (5) afterleavingthe drying oven any remaining fluid isvacuumed from the drum and the drum is wiped dry. The QCtest fluid evaporates slowly, resulting in VOM emissions throughout the process. 

### See RACT Survey at Section 1.0. Jn addition to the QCTest Process described above, permitted VOM emission sources at theNaperville facility include a caulk applicator, the paint spraybooth and ink printing. Each of these sources hasa source-specific annual VOMlimit in the FESOP, and the aggregate ofthose VOMlimits is 1.4 tpy. Becausetheplant's emissions havehistoricallybeenless than 25 tpy, the facility hasnotpreviouslybeen subject to Subpart TTand does not employ any equipment to capture or destroy VOM emissions. E. Jnvestigation ofCompliance Alternatives: Methods for Reducing VOM Emissions from Greif's Quality Control Testing Process EmissionUnit- Section 104.406(e) Relevant provisions ofSection 218.986 would require Greifto capture and control at least 81 percent ofVOMemissions from the QC TestProcess through the application of emission capture and control equipment. Greifinvestigated multiple compliance alternatives and the correspondingcosts for each alternative. 

### See RACT Study at Section 3. As discussed below, theRACT Studydemonstrates that dilution ofthe QC test fluid with water is the onlytechnically

9

## Electronic Filing -Received, Clerk's Office, 08/10/2011

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. 

### 1. Capture Systems Greif's fiber drums with polyethyleneliners are sprayed with the QC test fluid, conveyed 45 feet to the QC test station for visual inspection and then conveyed 120 feet to the drum paint

oven to evaporate most 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. Anyremaining test fluid is vacuumed orwiped from the drums and to the extent it still contains YOM, maystill be emitting YOM. An effectivecapture system would require a tunnel enclosure coveringthe 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 beneeded for the hood at the QC spray station and the openingofthe 

### drum paintoven to
ensure adequate capture ofemissions. Id. Duelingto the associated control dcvice(s) also would berequired from the QCTest Processhood, the conveyortunnel enclosure and the drumpaint

oven. Id. This type ofcapture system is assumed for each control method discussed below. The capital and annual operatingcosts for the capture system are included within the cost summary for each control system. 

### 2. Control Technologies. Greif's RACT Studyincludes a thorough evaluation ofthe following add-on control technologies: (a) recuperative thermal incinerator; 

### (b) carbon adsorption; and (c) biofilter and material substitution. Id. at Section 3.2. As detailed below, each ofthese potential control

10

## Electronic Filing- Received, Clerk's Office, 08/10/2011

systems are economically unreasonable, have inherent characteristics that could partially offset the environmental benefits ofYOM reduction and/or havepotentially harmful safety impacts. 

### a. Recuperative

### Thermal Incinerators Thermal incinerators heat an exhaust stream to a temperature sufficiently high to oxidize (burn) YOM inthe exhaust. Thermal recuperative oxidizers have aheat exchangerthatpreheats the incoming air by recuperating heat from the exiting air. 

### !d. at Section 3.2.1. As the incoming airpasses on one side ofthe metal tubeorplate, hot clean air from the combustion chamber passesonthe other side ofthe tube orplate. Heatis transferred to the incoming airthroughthe process ofconduction usingthemetal as themedium ofheattransfer. This system hasheat recovery as great as 60percent and therefore requires Jess natural gas than traditional incinerators to boost the combustiontemperatures to 1600°F (therequired temperature to ensure complete destruction ofYOM). Id. While a recuperative thermal incinerator canbe more cost-effective than a traditional incinerator, itrequires a large amount ofnatural gas as compared to othercontrol options (fuel mustbe used even when the QC TestProcess is not operatingto maintain the thermal oxidizer at temperature). 

### !d. Frequent operation cycles inthermal oxiders cause condensation corrosion and thermal deterioration ofthe insulation which requires ongoing maintenance costs. 

### !d. at Section 1.0. In addition, the large amount ofnatural gas required to operate thermal oxidizers generatesNOx and CO emissions and small quantities ofYOM and HAPs, which would partially offset any benefits obtainedfrom the associated YOMreduction. 

### !d. TheRACT Studyconcludes thattotal capital costs ofthe capture system and the recuperative thermal incineratorcontrol technology at Greif'sNapervillefacility would be

11

### ElectronicFiling -Received, Clerk's Office, 08/10/2011 $1,752,000 with annualized capital and operating costs of$17,672perton ofYOM controlled. See RACT Study at Table4-1. 

### b. Carbon Adsorbers Carbon adsorbers are used to control systems with low to medium YOMemission concentrations. See RACT Study at 3.2.2. A carbon adsorber typically consists oftwo ormore beds ofactivated carbon- one treats the exhaust emissions while the other is beingregenerated. 

### Id. Typically, regeneration involves passing steam through the carbon bed to remove the YOM with the steam, leavingthe regenerated carbon to be reused. Carbon adsorbers workbest with insoluble YOM, which simplifies the recovery ofthe YOM from the saturated beds. 

### Jd. In some cases, distillation is required to separatethe YOM materials from the regeneration steam. 

### Jd. The QCtest fluid is water soluble and would bevery expensive to recover from the regeneration fluid. 

### ld. In addition, the regeneration fluid likely could be sentto a local sewage district along with Grief's otherprocess wastewaters. 

### Jd. Most sewerdistricts use equalization basinsto reduce biological oxygen demand loading, which in this context includes YOM, by blowing solvents into the atmosphere; meaningthat YOM emissions maynot trulybereduced by the use ofcarbonbeds. 

### Jd. Fwther, ketones found in thedenatured alcohol present an inherent safetyriskoffires from reactions between theketones and the carbon in the beds. 

### Jd. Although carbonbeds thathandleketones utilize water deluge systems to control bed fires, the increased health and safetyrisks remain. 

### Jd. TheRACT Studyconcludes that total capital costs ofthe capture system andthe carbon adsorbers control technology would be $1,170,000. This control option wouldresult 

### intotal annualized capital and operating costs of$12,594perton ofYOM controlled. See RACT Study at Table4-1.

12

## Electronic Filing- Received, Clerk's Office, 08/10/2011

c. Biofilter and Material Substitution Biofilters can beused to reduce VOM emissions without the use ofnatural gas toburn thehydrocarbons. See RACT Study at Section 3.2.3. Bioren hasproposed to install a biofiltcr

on the Greifdrum plant in Oroille, Ontario, which couldpotentially reduce VOM emissions from that plantby 70percent. 

### !d. AtNaperville, the 8I percent capture and control objective couldbemet onlyby combiningthebiofilter with another control technologyorby considering the reductions in VOM emissions from theuse ofthe water diluted test fluid as a capture and control technology reduction. 

### !d. A biofilter system has loweroperatingcosts, 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 besuppliedby the direct combustion ofnatural gas, steam or electricity. 

### Id. Natural gas used for combustion would increaseNOx emissions from the facility, partially offsetting the benefit from reductions in VOM emissions. 

### !d. Based on theRACT Study, total capital coststo install thecapture system andthe biofiltcr control technology (which includesuscofthe waterdiluted test fluid) is $1,800,000 and annualized capital and operatingcosts are $11,667 pertonofVOM controlled. See RACT Study at Table 

### 4- I. 3. MaterialSubstitution Options 

### a. QC Test Fluid- Dilution with Acetone Greifconsidered dilution ofthe QC test fluid with acetone (a non-VOM material) as a possible alternative. However, dilution ofthe testing fluid with acetone could cause the gasket material sealingthe bottom ofthe drum to the drum walls to dissolve. See RACT Study at 3.3.2.

13

## Electronic Filing -Received, Clerk's Office, 08/10/2011

Dueto the potential for product damage, diluting the QC testing fluid with acetone is considered technically infeasible. 

### I d. b. QC Test Fluid- 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 extentpossible while maintainingthe ubility to visually detectpinholes orother tears or imperfections in the drum linings. The testingprocedure involved intentionallycreatingpinholes in theliners offive drums before sendingthem through the QCTest Process. The drums were sprayed with varying modifications ofthe QC test fluid and visuallyinspected to determineifthe pinholes could be detected within an acceptable timeperiod (here, about 70 seconds). 

### ld. at 3.2.1. Ifthepinholes

were detected, thetest and the associated test fluid were considered acceptable. Id. Ifthe pinholes could not be detected, the fluid was considered a technicallyinfeasible option based on Griefs inabilityto meet its customers' quality assurance standards. Id. Greifexperimented with five potential alternative test fluids. A mixture of80percent denatured alcohol and 20percent water revealed pinholes in each offive test drums within about 5 seconds. Id. Based on this result, Greifnext experimented with a mixture of70percent denatured alcohol and 30percent water. The70/30 mixture revealed pinholes in each offive test drums after 7 seconds; butwith noticeablylighter stainingthanwith the 80/20 mixture. Id. A third test, using a 50percent denatured alcohol and 50percent watermixture identified significantlylighter staining around pinholes ineach test drum within 45 seconds. Jd. The test using40percent denatured alcohol and 60 percent waterfailed to identifyflaws in thelinens 

### 14

## Electronic Filing- Received, Clerk's Office, 08/10/2011

within an acceptable timeperiod. 

### ld. 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 determined that 55 percent dilution with water was thehighest dilution percentagethat would allow theplant to meet its customer's quality assurance requirements. Greifinformed the Agency ofthese test results and began utilizing the diluted QC test fluid in May 2008 to achieve immediate reductions in YOM emissions even though the Agency had not formally approved the substitution. To date, the water-diluted test fluid has allowed the detection ofdrum defects without harmingtheproduct. After determining that the 45/55 QC test fluid mixture could satisfy appropriate QC standards, Greifconducted additional tests to determine whether the amount ofQC test fluid applied to each drum could be reduced. Based on this testing, Greifdetermined that it could reduce the QC test fluid sprayed into each drum to an amount not to exceed 48 grams. Dilutingthe QC test fluid with water and reducing the amount offluid used also has the potential to reduce annual emissions ofVOMfrom the QC Test Processbelow the 25 tpy applicability threshold ofSection 218.980 and below the 22.8 tpy emissions limitin condition 3 ofthe FESOP. Thishas been demonstrated by a significant reduction in overall facility emissionsbetween 2007 and 2008 and the approximate 70% reduction in per drum emissions. In addition, dilutingthe QC test fluid with waterresults in lower operating costs. Total capital costs to dilute the QC test fluid with water would be$0 and annualized capital and operatingcosts are reduced by $541 per ton ofVOC controlled. See RACT Study at Table 4-1.

15

## ElectronicFiling -Received, Clerk's Office, 08/10/2011

4. ComplianceAlternatives Conclusion Three capture and control systems would be technicallyfeasible: captureplus recuperative thermal oxiders, captureplus carbon adsorbers and capture plusbiofilters and material substitution. Whileeach ofthese options could achieve the 8 I percent capture and control objectives ofSubpartTT, the cost/ton ofVOM controlled range from $11,667 to $I7,672. These costs exceedwhat the Boardhas considered reasonable in adopting RACT regulations. See infra at SectionII(H)(I). Material substitutionusing acetone is technically infeasiblebecauseofproduct quality issues. 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 in VOM emissions compared to pre-substitution levels. F. Greif's Proposed Adjusted Standard- Section 1 04.406([) Greifproposes the following adjusted standard for adoptionby the Board: 1. The proposed adjusted standard applies to the emission of VOM into the atmosphere from Greif's fiber 

### drum manufacturing facility located at 

### 5 S 220Frontenac Road inNaperville, DuPage County, Illinois (the Facility). 2. The Facility will reduce VOM emissions from its QC Test Process by using a test fluid composed ofno more than 45 percent denatured alcohol byweight and no less than

### 55 percent waterbyweight. 3. TheFacilitywill calibrate the QC TestProcess equipmentto sprayno more than an average ofno more than 48 grams ofQC test fluid 

### per drum withcomplianceto bemeasured at least onceper calendar quarter by the following procedure. a. Weigh a plasticbag on a gram scale to determine the weight ofthebag. b. Placetheplasticbagover the sprayhead ofthe wand ofthe QC TestProcess and secure it in place with a rubber band orbinder clip. c. Cycle theQCTest Processbypassing a drum through the processin the normal manner ofoperation withtheplasticbag capturing the QC test fluid. Remove theplasticbag from the sprayhead ofthe wand ofthe QC Test Process and weigh it on the same gram scaleused in step a. 16

## Electronic Filing- Received, Clerk's Office, 08/10/2011

d. Calculate the weight ofQC test fluid sprayed as the differencebetween the weight determined in step c and the weight determined in step a. e. Repeat steps a. through d. for five cycles ofthe QC Test Process. Calculate the average weight ofQC test fluid sprayed per cycle and compare that average to the standard ofan average ofno more than 48 grams ofQC test fluid per drum. 4. All records and logs required by this adjusted standard shall be retained at a readily accessible location at the source for at least five years from the date ofentry and shall bemadeavailable for inspection and copyingby the Agency or USEPA upon request. Anyrecords retained in an electronic format (e.g., computer) shall becapable ofbeing retrieved and printed on paper during normal source office hours so as to be able to respond to an Agency or USEPArequest for records during the course ofa source inspection. 5. The Facility will maintainrecords ofits denatured alcohol usage that will allow themonthly calculation ofthe amount ofdenatured alcohol used during the month and the calculation ofVOM emissions on a 12-month rolling total basis for comparison to annual VOMlimitsin the FESOP. To allow these calculations, the Facility will: 

### a Record the volume ofdenatured alcohol held as inventory on the first and last day ofeach month. b. Maintain records ofthe volume ofdenatured alcohol received at the Facility during each month. c. The volume ofdenatured alcohol used for a month shall equal the inventory volume on the first day ofthe month plus the volume received at the Facility during the month, less the volume in inventory on the last day ofthemonth. d. The volume used during amonth calculated in step c shall be multiplied by the VOM content ofthe denatured alcohol (inpoundsper unit ofvolume) to compute the weight (in pounds) ofVOMemitted during the month. e. Using the emissions ofVOM 

### inpounds calculated for each month in step d, the Facilitywill compute the 12-monthrolling VOM emissions for the QC Test Process and report those results to Facility management. 6. Greifwill continue to investigate the availabilityofalternative QCtest fluids with loVfer VOM content. Greifwill incorporate such lowerVOM QC test fluids into its QC Test Process provided that the lower VOM QC test fluids allow visual detection ofpinholes orothertears or imperfections in the drum linings within an acceptable period oftime and does not result in any negativeproductquality impacts.



### 17

## Electronic Filing

- Received, Clerk's Office, 08/10/2011

7. The proposed adjusted standard will not affect the calculation ofGreif's potential Emissions Reduction Market System ("ERMS") baseline or its ERMS allotment ifGreif'sNaperville plant should participate in the ERMS program. 8. Environmental staffofGreif's parent will conduct a formal training session for Naperville facility personnel on the requirements ofthe FESOP and the internal procedures for tracking compliance with FESOP conditions. 9. Emissions and operation ofthe QC Test Process shall not exceed the following limits: VOMUsage VOM Emissions CTons/Mo) 2.3 2.3 CTons/Yr) 22.8 22.8 Theselimits are based on the maximum material usage and the maximum VOM content. Compliance with the annual limit for the QC TestProcess shall be determined from a runningtotal of 12 months ofdata. G. Quantitative and QualitativeDescription ofGreif's Impacton the Environment Before and AftertheProposed Adjusted Standard- Section 104.406(g) 

### 1. 

### Air QualityImpactAnalysis of Greif's Operations Application ofthe proposed adjusted standard will allow Greifto reduceVOM emissions from the QC TestProcess by about 70% on aper drum basis comparedto pre-changelevels. Whilethis reductionis less than the 81 percent capture and controlrequirement ofSection 218.986(a), the proposed adjusted standard will allow Griefto reduce VOM emissions below levels required by its FESOP and the threshold for Subpart

### TT applicability. The emissions ofVOM from the QC TestProcess at theNapervilleplant will have a minimal impact on air quality. 1n 2009, state-wide VOMpoint sourceemissions were 54,668 

### tons. See Illinois Annual Air Quality Report2009, Table 

### C-5 (IEPANovember2009) (available at www.epa.state.il.us/air/air-qualitv-report/2009/air-quality-reoort-2009.pdf) (2010 data was not available at the time Greiffiled itsAmendedPetition). Thus, even at themaximum permitted emissions levels for the Napervilleplant (22.8 tpy based on condition 3 ofthe FESOP), VOM

18

## ElectronicFiling

- Received, Clerk's Office, 08/10/2011

emissions from the QC TestProcess would amountto 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.gov to Susan Charles responding to Freedom oflntormation Actrequest, attached**a~** Exhibit B. Assumingmaximum emissions permitted underthe FESOP for theNaperville plant, YOM emissions from the QC TestProcess would amount lo only0.19% ofMetropolitan Chicago point source emissions. TheBoard previouslyhas found that adjusted standards from Subpart 

### TT from sources with muchhigherYOM emissions would have no significant impact on air quality. See, e.g., In the Matter of Petition of FordMotor Co. (ChicagoAssemblyPlant) for anAdjustedStandard from 35Ill.Adm. Code Section 2I8.986, AS 00-6, Slip. Op. at 

### 5(April6, 2000) (uncontrolled emissions of390 tpy would have no significant impact onair quality orhumanhealth);In the Matter of Petition of Alumax, Inc.foranAdjustedStandard from 35Ill. Adm. Code Part218, AS 92-13, Slip. Op. at 

### 9(Sept. 1, 1994) (excess uncontrolled emissions of76tpywould not significantlyimpact airquality). The Board also has shown a pa1iicular concern for capture and control technologies, such 

### as incinerators, that create alternate emissions, e.g., NOx, which also contributeto ozone formation orhazardous waste generation that offset any environmental gains from reducingYOM emissions. See, e.g., Alumax, AS 92-13, Slip. Op. at 

### 7 (Board granted adjusted standard where control technologies created offsetting emissions ofNOx and YOM);In the Matter of JointPetition of Quantum Chemical Corporation, USIDivision (and theIllinois EnvironmentalProtectionAgency)foranAdjustedStandard from Parts of 35I/l.Adm. Code 218.966and2I8.986, AS 92-14, Slip. Op. at 9 (Board granted adjusted standard whereuse of control technology would emitNOxwhich, like YOM, contributes to ozone formation, that would partially offsetthebenefits ofYOMreduction).

19

## ElectronicFiling -Received, Clerk's Office, 08/10/2011

2. Cross-MediaEnvironmentalImpacts Resulting from anAdjusted Standard. 

### None. Greif's waste and wastewater generation is independent ofYOM emissions from the QC Test Process; therefore, no change in the nature or volume ofwaste and wastewater is anticipated. H. Justification- Section I04.406(h) Where, as here, theregulation ofgeneral applicability does not specify alevel of justificationrequired for apetitionerto qualify for an adjusted standard, Section 28.1(c) ofthe TI!inois Environmental Protection Act, 415 ILCS 5/28.l(c), authorizes the Board to grant an adjusted standard upon adequate proofofthe following: (1) 

### the factors relating to thepetitioner are substantially and significantly different from the factors relied upon by theBoard in adopting the general regulation applicable to thepetitioner; (2) the existence ofthose factorsjustifies an adjusted standard; (3) the requested standard willnotresult in environmental orhealth effects substantially and significantly more adverse than the effects consideredbytheBoard in adopting the rule ofgeneral applicability; and (4) 

### the adjusted standard is consistent with applicable federal law. 1. FactorsRelatingto Greif are Substantially 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

### IT. First, the Board did notrely on any specific industry factors in adopting Subpart

### ITand, therefore, the factors associated with Greif's operations are necessarily "substantially and significantly" different. Second, Grief's ability to manage YOM emissionsbydiluting its QC test fluid and limiting the amount ofQC test fluid sprayed into each drum is substantially and significantly different from factors the Boardmay have relied on in deciding to require capture and control

20

## ElectronicFiling- Received, Clerk's Office, 08/10/2011

methods for managing YOM emissions. Third, even ifGreifcould not manageYOM emissions bydilution ofthe QC test fluid, thephysical design ofGreifs operations and the slowevaporation ofits QC test fluid are unique factors impacting and significantly limiting Greifs abilityto 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 costlevel the Boardpreviouslyhas found to be economically reasonable. a. The BoardDid Not Consider Jlactors Involving the Drum ManufacturingBusiness in Adopting SubpartTT. SubpartTT ofPart 218 is essentially a "catch-all" applicable to YOM sources that are not governed by other subparts ofPart 218. In adopting SubpartTT, the Board did not consider factors relating to any specific industry orpractice- includingthe fiber drum 

### manufacturing business. Rather, thepurpose ofSubpartTT was to cover sources that had not otherwise 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 specificto an industryorspecific sourcenot otherwise addressed in Part 218 would be "substantially and significantly different." See FordMotor Company (2000), 

### AS 00-6, Slip. Op. at 5. InFordMotor Company, 

### the Board considered an adjusted standard petition in which Ford sought an altemative emissions control planto address solvent cleanup operations at its Chicago assemblyplant /d. 

### Slip Op. 

### at 1. TheBoard stated that SubpartTT applies to YOM sources with certain characteristics that are not governed byother subparts ofPart 218 and, in adopting SubpartTT, the Board did not consider factors relating to any specific industry or practice. !d. 

### Slip. Op. at 5. The Board then ruled that, because factors relating to Ford's cleaning

21

## ElectronicFiling- Received, Clerk's Office, 08/10/2011 operations were not considered in adopting Section 218.986(a), the requirement to demonstrate significantly different factors "is therefore met." 

### !d. b. Greirs Ability to Manage VOM Emissions Through Dilution ofits OCTest Fluid and Limitations on the AmountofQC TestFluid Used Constitute Substantially and Significantly DifferentFactors. 

### Even ifthe Boardhad considered factors impacting the capture and control ofVOM emissions at drum manufacturers when itpromulgated Section 218.986(a), it did not consider Greif's unique QC Test Process, the particularcomplexity ofconstructing capture equipment over an extended conveyorline orthe ability to manage VOM emissions by diluting the QC test fluid with water and limiting the amount ofQC test fluid applied to each drum. Construction of effective capture equipment is further complicated by the need to maintain physical access to the drums for visual inspection. This means the conveyorline cannotbe totally enclosed to maximize capture. These factors are substantially and significantly different from emission units wherematerial substitution is notpossible and the construction and operation ofemission capture equipment is less extensive. c. Greif's QCTestProcess is Substantially and Significantly Differentfrom Other ManufacturingActivities Consideredby theBoard. 

### In addition, even assuming, arguendo, 

### that capture and control could be an economically reasonable option, Greif's specific system would be complicatedby thephysical location of different production activities within the Naperville plant, the slow evaporation ofthe testing fluid and the need for Greifto inspect drwns visually after the QC test fluid has been sprayed into the drum. The testing fluid begins to evaporate while being sprayed in the QC spray station. Evaporation continues while the drum is being conveyed to and awaiting QC inspection and also as the drums are conveyed from the inspection areato the drum paint oven and, possibly, even

22

## Electronic Filing

- Received, Clerk's Office, 08/10/2011

afterward. Because the lined drums must be accessible for visual inspection byplant staff, complete enclosure ofthe drum conveyor line is 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 likelywas not considered by the Board in adopting SubpartTT 

### and will significantlyimpact Greifs costs to control YOM emissions. See infra at

### Section II(H)(2). d. Costs ofAchieving RACT Control StandardExceed those Considered by

### Board in Setting RACT Standard. In addition, as reflected in the RACT Study, feasible technologies to achieve the 81 percent combined capture and control 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 the Board previously has found to beeconomicallyunreasonabie. SeeIn the Matter of' Petition ofFormelIndustries, Inc./or anAdjustedStandard from 35Ill. Adm. Code. 218.401(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 ofYOMreduced were economicallyunreasonable); FordMotor Company (2000), 

### Slip. Op. at 5 (citingIn re: Petition of LouisBerkman, 

### AS 97-5 (Dec. 4, 1997)aff'dsubnomEPA v. PCB, 

### 308 

### Ill. App. 3d 741, 746 & 

### 752-53,721 N.E.2d 723,726-27 & 

### 731 (2d Dist. 1999) (for proposition that costs exceeding $1,734 in 1996 dollars per ton ofreductions was economicallyunreasonable); In theMatter of' JointPetition of ReynoldsMetals Company andthe Illinois EnvironmentalProtectionAgency for

anAdjustedStandard from 35lAC218.980, 

### AS 91-8 (Sept. 21, 1995) (Board found $40,000per ton ofYOM reduced to beeconomically unreasonable).

23

## ElectronicFiling -Received, Clerk's Office, 08/10/2011

2. The Existence of These Factors Justifies anAdiustedStandard. 

### The intent ofthe regulations promulgated under 3 5TIL Adm. Code Part 218 is to implement RACT for YOM emission sources in the Chicago ozone non-attainment area. See In theMatter of Petition of FordMotor Company (ChicagoAssemblyPlant)for anAdjusted Standard from 35Ill. Adm. Code 218.986,

### AS 02-3, Slip. Op. at 4 (November 21, 2002). Greif's RACT Study demonstrates that use ofthe water-diluted test fluid as an adjusted standard reduces emissions from the QC Test Process below the applicability threshold for Subpart

## 'I"fl and below applicable FESOP limits while reducing costs. The existence ofthese factors demonstrates that dilution ofthe QC test fluid constitutes RACT andjustifiesthe granting ofthe instant request. 3. The RequestedStandard WillNot Result in AdverseHealth Effects. 

### The requested adjusted standard will have little, ifany, adverse impact on human health orthe environment. In 2009, state-wideYOM point source emissions were 54,668 tons. See IllinoisAnnualAirReport

### atTable C-5 (2010 emission data was not available atthe time Greif filed its Amended Petition). Thus, even at the maximum permitted emission levels for the Napervilleplant (22.8 tpybased on condition 

### 3ofthe FESOP), YOM emissions from the QC Test Process would amount to Jess than 0.04% ofstate-widepoint source emissions and only 0.19% ofMetropolitan Chicago emissions. The Boardhaspreviously found that adjusted standards from SubpartTT

### from sources with much higher YOM emissionlevels wouldhave 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.

3 Greifunderntands**th~t** SubpartITis a "once in-always in" rule. 35 lll. Adm. Code Section 218.980(c). However, the fuct that the diluted QC testfluid will bring emissions belowthe applicability threshold is ofsome significance because the Board certainly did not considersources withuncontrolled emissions less than the threshold being subject to SubpartIT. 

### 24

## ElectronicFiling- Received, Clerk's Office, 08/10/2011

The Board has granted numerous exemptions to the 81 percentcapture and control requirement in SubpartTT in cases where the annual VOM emissions that were exempted from Section 218.986(a) were significantly greaterthan those proposedby 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 significantimpact on air quality or human health); Quantum Chemical Corporation, 

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

### 0(Board agreed that operation ofemission units resulting in over 260 tpy 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 impacthuman health). Moreover, the Board previouslyhas found that acontrol planresulting in an overall emissions reduction constitutes apositive

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

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

### at 4. InFord, 

### the Board found that a 50 tpy reduction ofVOM emissions (from 390 tpy to 340 tpy- or 13%) was "significant" and would have a "positive impact on airquality." 

### I d. Here, dilution ofthe QC test fluid and limitation on the amount of QC test fluid used per drum is producingroughly a70% reduction ofVOM emissions- an even greaterreduction on apercentagebasis than what was at issue in the Ford

### petition. 4. The RequestedStandardis Consistentwith FederalLaw. 

### Section 110 ofthe federal Clean AirAct, 42 U.S.C. §

### 7410, grants individual states the authority to promulgate aplan for implementation, maintenance and enforcement ofair quality standards, subjectto approvalby USEPA. 

### Based on the RACT 

### Study, theproposed adjusted standard constitutes RACT

### for the Greiffacility, and is therefore consistent with the federal Clean AirAct. A state may revise its 

### SIP, again subjectto USEPA approval. 42 U.S.C. §

### 7410.

25

## ElectronicFiling

- Received, Clerk's Office, 08/10/2011

Greifwill work with the Agency to submit a SIP revision to USEPA that is consistent with any adjusted standard grantedby the Board. 

### J. Hearing- Section 104.406(j) Greifrequests a hearing in this matter. 

### K. SupportingDocumentation- Section 1 04.406(k) 

### 1. RACT Study, attached to this Petition as ExhibitA. 2. FOIA Response from Illinois Environmental Protection Agency, Bureau ofAir, attached to this Petition as ExhibitB. 

### III. CONCLUSION Greifrequests that the Board grant theproposed adjusted standard as an alternativeto the RACT regulations adopted bythe Board in SubpartTT. To require Greifto comply with the requirements of35 

### Ill. Adm. Code SubpartTT, Section 218.986(a), would result in substantial economichardship to Greifwith no corresponding environmental benefit. Certait1 compliance options examined by Greifcould have the reverse effect ofcreatingincreased emissions ofother pollutants and environmental detriment. Finally, add-on controls areunreasonably expensive, providelittle, ifany, environmentalbenefit and certain control options mayresult inincreased health and safetyrisks.

26

## Electronic Filing -Received, Clerk's Office, 08/10/2011 WHEREFORE, Greif, Inc. requests that the Board grant Greifthe proposed adjusted· standard from 35 lll. 

### 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: /s/ Susan Charles Thomas W. Dimond Susan Charies ICE MILLER LLP 200 WestMadison Street Chicago, illinois 60606 312-726-1567 August 1 0, 2011

27

## Electronic Filing

- Received, Clerk's Office, 08/30/2011 IEPA ATTACHMENT NO.- 

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD IN THE MATTER OF: PETillON OF GREIF, INC. AND GREIF PACKAGING, LLC FOR AN ADJUSTED STANDARD FROM 35 ILLADM. CODE PART 218 SUBPARTTT ) ) ) 

### ) ) 

### ) ) 

### AS 2011-001 (Adjusted Standard- Air)

NOTICE OF ELECTRONIC FILING 

### TO: John Therriault, Clerk lllinois Pollution Control Board James R. 

### Thompson Center 100 West Randolph Street, Suite 11-500 Chicago, IL 60601 Charles Matoesian Division ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O. Box 19276 

### Springfield, IL 62794-9276 

### PLEASE TAKE NOTICE that Ihavetoday electronically filed with the Office ofthe Clerk ofthe Illinois Pollution Control Board, Petitioners' NOTICE OFELECTRONIC FILING, PROOFOFPETITION NOTICE REQUIREMENTS 

### and CERTIFICATE OF SERVICE, 

### copies ofwhich are attached herewith and served upon you.

Date: August 30, 2011 Thomas W. Dimond Susan Charles ICE MILLER LLP 200WestMadison Street Suite 3500 Chicago, lllinois 60606 Respectfully submitted, GREIF, INC. and GREIF PACKAGING, LLC By: /s/ Susan Charles One ofits Attorneys

I

## - Electronic Filing

- Received, Clerk's Office, 08/30/2011

BEFORE 

### 111E ILLINOIS POLLUTION CONTROLBOARD
IN THE MATTER OF:· PETITION OF GREIF, INC. AND GREIF PACKAGING, LLC FORAN ADJUSTED STANDARD FROM 35 ILL ADM. CODE PART 218 SUBPARTTT 

### ) ) ) ) 

### ) ) ) AS 2011-001 (Adjusted Standard- Air)

PROOFOFPETITION NOTICE REQUIREMENTS Pursuantto 35 lll. Adm. Code Sections 104.408 and 104.410, on August 12,2011, petitioners Greif, Inc_ and GreifPackaging, LLC ("Greif'')published notice ofthe filing oftheir SecondAmended Petition for anAdjusted Standard ("Petition") byadvertisementin a newspaper ofgeneral circulation inthe area ofGreif's Napervilleplant. In support ofthis filing Greifstates the following: 

### 1. Greiffiled the Petition with the Clerk ofthe lllinois PollutionControl Board on August 10, 2011. 2. Pursuantto the Petition, Greifseeks an adjusted standard from 35 

### lll. Adm. Code 

### § 218.986(a) as itapplies to controlrequirements for emissions ofvolatile organicmaterial 

### at Greif's fiber drum manufacturing facility locatedin Naperville, Illinois. 3. On August 12,2011, Greifpublished notice ofthe filing ofthe Petitionby advertisementin the

### Naperville Sun, a newspaper ofgeneral circulation inNaperville, lllinois. 4. As requiredby35 Ill. Adm. Code Section 104.408(a), Greifpublished notice of the filing ofthe Petition within 14 days after it filed thePetition. 5. Thenotice includes the specific languagerequired by35 

### Ill. Adm_ Code Section I04.408(b)-

1

## Electronic Filing -Received, Clerk's Office, 08/30/2011

6. Asrequired by 35 Ill. Adm. Code Section I04.410, a certificate ofpublication issued by the publisher ofthe

### Naperville Sun certifyingpublication ofthenotice on August 12, 2011 is attached as Exhibit 1. The certificate ofpublication attaches Greif's notice as it appeared in the

### Naperville Sun and states that the

### Naperville Sun satisfies the requirements ofthe Illinois NoticebyPublication Act, 715 ILCS 5/0.01, 

### etseq. The language included in Grief's notice is consistent with 35 Ill. Adm. Code Section 104.408(b). WHEREFORE, for thereasons stated above, Greifhas satisfied the requirements for providingnotice ofthefiling ofits Second Amended Petitionfor an Adjusted Standard and for filing proofofsuchnotice with the Illinois Pollution ControlBoard.

Date: August 30, 2011 Thomas W. Dimond Susan Charles ICE MILLER LLP 200 WestMadison Street Suite 3500 Chicago, Illinois 60606 Respectfully submitted, GREIF, INC. and GREIF PACKAGING, LLC 

### By: 

### !sfSusan Charles One ofits Attorneys



### 2Public Notices Public Notices Not!Cl);or Second Amonded**Petltlo~~d** Gn:ll · ·**.·~;ta~kaglng** U.C toran Adjusted '!/:1'0/HC 1 - . . the Illinois Polwtkmc • On Augus110, 2011, Groll, Inc. and Grolf Packaging LlC (Grell) 

## Ifiled a SecOnd Amended Pctitl:m IOJ an**A!~Justed** Standard (Petl· lion) w11h th& ·lll'nols PoUuUoo Control Bixlrd (Board), DOckot ' Number 2011·001 :seeking an adjusted standard from 35 rn. · ! Ad'n. CoQe' § 218.-966(e) as It applies to control requlrement1llor 1emlss!Ons ot_.yolaltto organic mErterial {VOM) at Gralf'slacillty lo-- ' cnted at 5**~th** 220 Frontenac Road, Naperville; Illinois 60563. ; Grerrs. Napeiv111& fatllttv menufa.ctums fiber (!f:a r) Qrums. Groff ; condvi.:ts quality control (OC) tasHng of polye ene lnera inelud- ' eel In some dft.l1lS by spraying a QC test fllld adanatured alec- : hol product, whictl Is a VOM) ifl!o tho drum ir.tcriof. Tho drums : aro convoyed to an lnapeclloo station for VIsual lrnlPCCtlon and**~** lhon COfl'leYBd to a thln:t: location kx' ovaporntiOn end removal of j the QC lest flu1d. VOM is emitted throughoul the CX: k"A Proc· 

## Iess, including drum conveyanco. Section 21B.986(a) wctld re- quire Grell-to install capture and control COJlpmenl vthlch acfl·

, !eves an**CIV'Cr<~n** reductiOn- In OfiControllad 1/0M emissions ol at

least 81% thmu{tlOUI Gfeif's OC Test Process.. Greirs**<~mended** proposed 80jus1ed standard provides the following: 1. The proposed adlusted standard oppOes to the emleston of · VOM ·Into**t~** atmosphCIT.l from Gn:til's fiber chrm manutacturlng**~** facility tocafed at 5 S 220 Fronlcnac Road in Napervllle1**O~e** , Courtly, llllrroi9 (lhe_Fecffily).**~** 2. Tha Fed\lty wi'lredtlc& VOM atYIISsiOns from h3 OC Test Pft>c·**~JGS** by U!littg o. t8SI fluid oompoood of no more 'than 45 percont . denatured alc<ltlcd by weight and no loss than 55 porcenl walef . b}'wcight. 3. The Feemty win cellbmte tho QC Test Prooe:-.3 equipment to spray no more than on ovornge of n;) more lhOfl**~grams** of OC test fluid por drum with oon1>llance to be moa&urerllrtleast onco perculendar quortcr bythe following procedure. · a. Weigh a. plasfc bag 011 a gram scalo to da$ermlne the wei!tlt ofthe bag.· b •.Piaoe the l)lastic bEiil over the spray head of ihe wand ofthe OC Toil Proooss and securo n In place wiUl a rubber band Of binder clip.

. . c. Cycle the QC Test Process by passing a drum**~** !he i process In ·fhe normal manner of operation -with the· plashc bag 1 1 capeurtng the OC test ftlld. Remove the plllstlc bag from tho

spmy head ol t..'l& wand ot the OC Test Process and welgh It on the same gram scale used ih slep a. · tl. Ca.lcultrlo the welght of ac test RuXJ spmyod as the dillerllr'IOO botween tha walgh1 delermined In step c and the weight_ detormlned in step B. ' B. Repoat stopsn. throu{tl d. for !Iva**~es** oftho 0CTest Proc· ess. Celcufat(l the averaQCl weklhl of ac test fluid apmyed par cycle and oompara that average 1o the standard of an EWemge of no mom ltmn 48 gtams ofac test fluid perdrum. 4. All records n k>os**re~lrod** by thls adjusted standard shall be retained ala reality accessible tocatloo at lhe·source for at least live years !rom the date of !ntly and shall be made avaBa· bla tor Inspection and copying bythe Agency or USEPA upon ro-**quo~.** Any rec:on:f::; rotalned fn an etectror'llo fofmat (e.Q., comput· , or) shall be-capable ol belng re1r!eved and prlnted on paper during normal oouroo ofllce hours GO as to be able to rnspoocl1o en Agency or USEPA mqtJeSt for records durlr,g 1ha ooumo of a source**l~ctlon.** 5. The Facllity will maintain records of Ita denatuied alcohol us- age that wiU allow the**month~** calculatloo of tho amount ot**~~~~~~nu:e1d2=ffi 'roclmon1Jru~~~Watl~S::**  to annual VOM llmlta In lho FESOP.,.o alo'N th&Se**~ions,** the Facilitywill:

. a. Ftooord tho volume Of d91)alumd a/00001 hGfd as lrwentory oo ttmfirst and**~a~Js**ot eactl montl't b. Melntaln s of tho volume Of dr:naturl!'d a1cohol recei\led atthe FaciAty during cnch montll. c. TheYOilino- of donatur!Kl oltohol usod tor o mOOth**~** oquat tho IIW001ory volJme on the fimt day olth9 month plua the vol· ume racelved at lila Fadlity durWlg the month, IEm tho vollii'IEI in iwontotyon tho lastday of the month. d. Tho volume used during a month calculated ln step c :shan be multiplied

.by lho VOM con\8:'11 o1 lhe denatured alcohol (In pourd!l per mit**o~** volume) to compute·tho weight (In pounds) Qf VOM e:n!tted during lha month. - . · ·e. Using the emissions of VOM In poonds e<11ctdated for each month in step_ df the Facility will**com~fl** the 12·tll0111h roDing

. VOM emlssloris or th&QC test Pnx::e!IS o:nd rnport those msulls to Fecilty rnanagamlll'll. 6. Grell wil conllnuo to lnveatigate tho avallablrrty ol allemolivtt QC test· flUids with tower. VOM content: Greif Will loc:otporale**Stl~** 1awer VOM 0C I6SI flUids IntoIts QCTest Procoss provided that the lower VOM QC test fk.lids l'llloW visual delecdon ot pill· hole!l or other tea!"B or lrnporfocHons Intho wum linings wilhfn an accoptable period ot time and doGs not result In any**n~nfiVC** prodwtQUO:Hty li'nJKlo1$,

. 7. The propoSed**a~usk!:i** standard will nolalfacttho catcul£tion of Grelfs potential EmiSsions Redlctlon Merkel Systam- ("ERMS") btJSallne or Its 'ERMS _e!lolmcnt If Greif's NapeM!Ie plenlshould part!clpatoJn the EAMS prorgram. ·

. 8. Environmental sli!fl of Grell's paron! 'l'o'in cortduct a fonniJitraln1lng session fOI' Naperville facilty personnel en ihe roqui'ements of !ho FESOP·ond the tnternaf_procedums fQr li'acldng Q:)fllpl· : , ance With FESOP condilions.- 9. Emissions anD oporntiorr of tho QC Tesl Proocss shal**not~­**

. ooodthe foiOY.rln[t limits: (Tona/Mo) (Toos/Yi) .VOM U!lage 2.3 22..8 I VOM Emissions 2.3 · 22.8 · Theso limlls aro-bas«ion the maximum millorlal usage and tha 1tMxlmum YOM contenl CO:npllance with the arr.ual imlliOr the

ac Test Proccss shall bo determined lrom a r\II'II'WI(J total of 12 months ofdata. Griefs Pelitioo tustlfles adOption of tho adjusted standard bnsed on the lollm.11'11f:· (1) the factors re!atng**~** Greif, partiCularly Griofs**abi~ty** to redu:::e VOM**emission~** by tilutlng Its 00test flu- Id and rod.Jclna the quarrtlty used per drvm, and the eng\leerlng Complexities tF ocnstrucllnQ capture eqlit>menl averan extended CO!'!WYO' lne,ara substanlialtv and sJgnRicall!ly tifferent from 'lac· tors rellsd on by lhe Bo.·mf 51 adOPii'lg Soctlon.21B.98G(n); (2) thecost; of**IXli'TIPivi~** with Sectloo 218.986(&) ro:t:eed 1hoseccn- skicred by the llOOnf In sslUng tho requl!armm1B oltl'et section; 

## ! 3) the requested slllndard will no1 msu1t ln adverse lteallh ef· ects; and (4) lha requested standam- Is conslsiDnt w11h federal taw. . Any person may cause a pu'olk: heer1ng to be hald In the above- """"bed adjuo;!ed ""odanl proooedlng by ""' • hearing ,.. quest with Ute IIDn(JI$ Pollutkm Comrci BOard WlthFn 21 da)'S after the da\a· of tho publlcotlon ot thiS noticG. Tho hearing request should cloorly indlcalll: the docket number for tho adjusted &land· ard procEieclng, [1:S found ·m this noice, and must be maitod to the .Clerk ol tho Bootd, Jl'il"'IOs Pollutlcr1Control Boertl. 100 W. Randolph Street, &its 11-.500, Chicago, Dinols 60001. · Ad 117235 Pub: ALigtlSI 12, 2011 

## iling -Received,**C~e,** 

## 08/30/2011 

# SUN-TIMES ·MEDIA Certificates ofPublication State oflllinois- 

### County of Ocook 

## 0 Kane 0Lake 0 

### McHenry**~DuPage** 

## DWill 

## DDeKalb 

## D Kendall 

## 0 Grundy Sun-Times Media, does hereby certify it has published the attached advertisements in the following secularnewspapers. All newspapers meetlllinois Compiled Statue requirements for publication ofNotices per Chapter715 ILCS 5/0.01 et seq. R.S. 1874, P728 Sec I, EFF. July 1, 1874. Amended By Laws 1959, P1494, and EFF.July 17, 1959. Formerly Ill. Rev. Stat. 1991, CHIOO, Pl.. Note: Legal Notice appeared in the following checked positions. PUBLICATION DATE(S): 

## -----"-fll-i..LI..:::W"--f-..J.I...L!
_ _;__

## /~) 0 TheBeacon News 

## 0 The CourierNews 

# 0 TheHerald News 

# 0 TheLake County News-Sun

### ~The NapervilleSun 

# 0 The SouthTownStar 

## 0 The Chicago Sun-Times 

# 0 PioneerPress/The Doings 

## 0 Job Posting on Monster.com



## mWITNESS WHEREOF, the undersigned, being duly authorized, has caused this Certificate to be signed and its official seal affixed at Aurora, lllinois

David Fontechin OFRC\AlSEAL CATHERINEACYNCAR NOTAIW PUBUC, STATE OF IWNOtS KANE COUNTY MYCOMMISSION EXPIRES 11/1:9/2014 Public Legal Notices AccountExecutive Subscnbed and sworn to before me this ..),.

# '? Day of

# -h-

A. D. 

## eJ {) 

## /J

# ~d:bl~ By· 

### EXHIBIT 1

## Electronic Filing -Received, Clerk's Office, 08/30/2011

CERTfFICATE OF SERVICE 

### I, theundersigned, certify that on this 30th day ofAugust, 2011, Ihave served electronically the attachedNOTICE OF ELECTRONIC FILING and PROOF OF PETITION NOTICE REQUIREMENTS upon the following person: John Therriault, Clerk TI!inois Pollution Control Board James R. Thompson Center 100 West Randolph Street, Suite 11-500 Chicago, IL 60601 and 

### by U.S. Mail, first class postage prepaid, and electronic mail to the following persons: Charles Matoesian Division ofLegal Counsel lllinois Environmental Protection Agency I021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276 

### lsi Susan Charles Susan Charles

1

## Electronic Filing -Received, Clerk's Office, 10/11/2011 IEPA ATTACHMENT NO BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: PETITION OF GREIF PACKAGING, LLC FOR AN ADJUSTED STANDARD FROM 35 ILL ADM. CODE PART 218 SUBPARTTT ) ) ) ) ) AS 11-01 Air

TO: John Therriault, Acting Clerk lllinois Pollution Control Board James R. Thompson Center I00 W. Randolph St., Suite 1I-500 Chicago, lllinois 60601-3218 Susan Charles Tom Dimond 

### Icc Miller LLP 200 W. Madison Street, Ste. 3500 Chicago, IL 60606-3417 NOTICE Bradley Halloran, Hearing Officer Illinois Pollution Control Board James R. Thompson Center 100 W. Randolph St., Suite I 1-500 Chicago, IL 60601-3218

PLEASE TAKENOTICE that I have today filed with the Office ofthe Pollution Control Board the RECOMMENDATION ofthe Illinois Environmental Protection Agency a copy ofwhich is herewith served upon you.

DATED: October II, 2011 I021 North Grand Avenue East P.O. Box 19276 Springfield, Jllinois 62794-9276 217.782.5544 217.782.9143 (TOO) ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By: /s/ Charles 

### E. Matoesian Charles E. Matoesian Assistant Counsel Division ofLegal Counsel

THIS FILING IS SUBMITTED ON RECYCLED PAPER 

# ·-

## ElectronicFiling- Received, Clerk's Office, 10/11/2011

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: PETITION OF GREIF PACKAGING, LLC FOR AN ADJUSTED STANDARD FROM 351LL ADM. CODE PART 218 SUBPARTTT ) ) ) ) )

RECOMMENDATION AS 11-01 (Adjusted Standard -Air)

The lllinois Environmental Protection Agency ("Illinois EPA") hereby submits its Recommendation in the above captioned matter pursuant to the regulations ofthe Illinois Pollution Control Board ("Board") at 35 Ill. Adm. Code 104.416. The Illinois EPA recommends that the Board GRANT the Second Amended Petition ofGreif, Inc., and GreifPackaging, LLC, ("Greif') subject to the terms and conditions contained in this Recommendation. In support of this Recommendation, the Illinois EPA states as follows: BACKGROUND 1. Greifoperates a fiber (paper) drum container manufacturing facility located at 5 S 220 Frontenac Road in Naperville, DuPage County, Illinois. (Second Amended Petition at 1). Fiber drums are generally produced by cutting fiber material to the appropriate length, forming the fiber into a cylindrical shape and attaching a top and bottom to the cylinder. Id. Some drums require the addition ofa polyethylene liner due to customer specifications, such as when the drum is needed for storage offood-grade products. !d. The quality control ("QC") system in Greifs plant involves testing the liners ofdrums by spraying a test fluid into the interior ofthe

## ElectronicFiling- Received, Clerk's Office, 10/11/2011

drums. ld. The test fluid is a denatured alcohol product which is a volatile organic material ("YOM"). Id. 2. For the process at issue in this Adjusted Standard proceeding, Greifuses an automated system to spray the interior ofthe drum liners with QC test fluid. Id. at 2. The drums move along a conveyor belt and at the proper moment a spray wand descends and sprays the interior of the drum with the YOM--containing test fluid. I d. After the spray wand retracts, the drum

moves along the conveyor belt to an inspection station where the drums are visually inspected for pinholes. !d. The ethanol in the test fluid causes a brown spot to appear wherever a pinhole exists. !d. Ifno pinholes are present, the drum moves along to the drying oven where remaining fluid is evaporated. !d. YOM is emitted throughoutthe quality control check and in the drying

oven. ld. 3. Greifstatesthat it tracks YOM emissions on a monthly basis by "calculating the mass of VOMs used and assuming that all usage is emitted to the atmosphere." !d. Greifasserts that it calculates the volume ofdenatured alcohol held as inventory on both the first and last days ofthe month. Id. Greifnotes that it also tracks the volume ofdenatured alcohol purchased within each month. !d. The difference in volume "isthen multiplied by the YOM content (in pounds per gal) ofthe denatured alcohol to compute the mass (in pounds) ofYOM emitted during the month." 

### Id. 4. The Naperv.ille plant is subject to a Federally Enforceable State Operating Permit ("FESOP") (No. 9707044). Condition three ofthe FESOP limits YOM emissions ofGreifs QC test process to 22.8 tons peryear. !d. This condition also limits the YOM emissions from the remainder ofthe plantto 1.4 tons peryear. !d. The FESOP generally limits Hazardous Air

## Electronic Filing- Received, Clerk's Office, 10/11/2011

Pollutants ("HAPs") from the Naperville plant to 10 tons per year ("tpy") ofany single HAP or 25 tpy for any combination ofHAPs. Jd. at 3. Greifreported 2010 emissions from the Naperville facility as 9.95 tons ofVOM plant-wide and total combined HAP of 1.87 tons. ld. However, in previous years the YOM emissions climbed to as high as 46.7 tons. On July 5, 2007, the Illinois EPA issued Violation Notice A-2007-00132 alleging, in part, that Greifs Naperville facility exceeded condition three ofthe FESOP, relating to YOM emissions. Greif asserts that the QC test process had emissions in 2006, 2007, 2008, 2009 and 2010 of35.2, 46.7, 19.1, 7.7 and 8.95 tons, respectively. Id. These years ofhigh emissions are the subject ofthe Illinois EPA's Violation Notice, A 2007-00132. ld. After reviewing the matter, the Illinois EPA agreed that Greifwould make changes to the process, as noted elsewhere in this document, and file a Petition for an Adjusted Standardto resolve the alleged violations. 5. Greiffiled its Petition for Adjusted Standard on January 27,2011, pursuant to Section 28.1 ofthe Illinois Environmental Protection Act ("Act"), 415 ILCS 5/28.1, and the regulation of the Board at 35 III. Adm. Code 104.402. An amended petition ("Amended Petition") was filed

on May 31, 2011. On August 10, 2011, a Second Amended Petition for an Adjusted Standard

was filed with the Board. 6. Greifproperly filed a ProofofPublication ofNoticewith the Board for each ofthese Petitions, stating that the various notices appeared in the Naperville Sun on January 27, June I0, and August 12,2011. 7. Pursuantto 35 III. Adm. Code Section I04.416, the Illinois EPA is required to file a response to a Petition for Adjusted Standard within 45 days offiling. 8. However, as aresult ofongoing discussions, Greiffiled an Amended Petition and a

### Electronic Filing- Received, Clerk's Office, 10/11/2011

Second Amended Petition. In return, due to ongoing discussions and new information provided by Greif, the Illinois EPA filed several motions to extend the time for filing a response and all of these motions were granted by the Board. 9. This Second Amended Petition covers Greifs fiber drum manufacturing facility in Naperville. THE REGULATION AT ISSUE I0. The Second Amended Petition requests that the Board grant Greifan adjusted standard from 35 Ill. Adm. Code 218.986(a). This subsection states: 

### Section 218.986 Control Requirements Every owner or operator ofan emission unit subject to this Subpart 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 ofat least 81 percent from each emission unit, or (Board Note: Forthe purpose ofthis provision, an emission unit is any part or activity at a source ofa type that by itselfis subjectto control requirements in other Subparts ofthis Part or40 CFR 60, incorporated by reference in Section 218.112, e.g., a coating line, a printing line, a process unit, a wastewater system, or other equipment, oris otherwise any part or activity at a source.) 

## *** II. Duringthe years 2006 and 2007, the Illinois EPA alleges Greifbecame subject to the 81 percent capture and control requirements ofSubpartTT. ld. Section 218.986 (a) to (c) are part ofSubpart TT which is a "once in-always in" regulation, which is why Greifis still subject to the provision despite reducing its plant-wide emissions to a level belowthe applicability threshold.

## Electronic Filing -Received, Clerk's Office, 10/11/2011

STANDARD OF REVIEW 12. Section 28.1 ofthe Act states that the Board may grant individual adjusted standards from rules ofgeneral applicability whenever the Board detennines that an applicant canjustify an adjustment. In adopting a rule ofgeneral applicability, the Board may specify the level of justification required ofa petitionerfor an adjusted standard. Ifa rule ofgeneral applicability

. does not contain a level of justification that the petitioner must meet to obtain an adjusted standard, the requirements ofSection 28.1 (c) ofthe Act apply. Section 28.1 (c) states that the Board may grant individual adjusted standards whenever the Board determines that: (I) Factors relating to that petitioner are substantially and sufficiently different from the factors relied upon by the Board in adopting the general regulations applicable to that petitioner; (2) The existence ofthose factorsjustifies an adjusted standard; (3) The requested standard will not result in environmental or health effects substantially and sufficiently more adversethan the effects consideredbythe Board in adopting the rule ofgeneral applicability; and (4) The adjusted standard is consistent with any applicable federal law. 13. The regulation ofgeneral applicability from which Greifseeks an adjusted standard, 35 Ill. Adm. Code 218.986(a), does not specify a level of justification that Greifmust satisfy to obtain an adjusted standard. Therefore, Greifmust satisfy the level of justification set forth in Section 28.1 (c) ofthe Act. As summarized below, the requested adjusted standard for Greifs drum manufacturing operations presents facts sufficiently different from Subpart TTwhich the Agency agreesjustifiesthe Adjusted Standard . COMPLIANCE ALTERNATIVES 14. Greifasserts in its Second Amended Petition that its operations were not contemplated

## ElectronicFiling -Received, Clerk's Office, 10/11/2011 by the Board when it passed Subpart TT, Section 21 8.986(a). Greifcompleted a Reasonably Available Control Technology ("RACT") study in August 20 I0, revised March 20 II,to evaluate compliance alternatives to meet the Section 218.986(a) requirement to reduce VOM emissions by 81%. Id. at 4. Greifstates that one complicating factor for any capture system is that a tunnel enclosure would be needed for the entire length ofthe QC process. !d. at I0. The QC process is long, and completed at several points in the factory. !d. As Greifmust have access to the drums for inspection, the tunnel system would be more complex than a normal system. I d. Greif asserts the RACT studycompared three capture and control systems: capture plus recuperative thermal oxidizers, capture plus carbon adsorbers and capture plusbiofilters and material substitutions. I d. That is, a capture system is assumed for all add-on control technologies. !d. 15. Concerningthe three add-on control options, recuperative thermal oxidizers, carbon adsorbers, and biofilters and material substitutions, Greifasserts that all will be prohibitively expensive. !d. at I0- II. In addition, some will "have potentially harmful safety impacts." !d. A recuperative thermal incinerator requires large amounts ofnatural gas for fuel and according to Greif, "[f]requentoperation cycles in thermal oxiders cause condensation corrosion and thermal deterioration ofthe insulation which requires ongoing maintenance costs." !d. at II. Carbon adsorbers use two or more beds ofactivated charcoal with one treating emissions while the other is regenerating. Jd. at I2. Greifstates that these work best with insoluble YOM as the recovery process uses steam to recover VOM from the carbon beds. Jd. In Greifs case, however, the QC test fluid is water soluble so recovery ofthe VOM would be more expensive. ld. The regeneration fluid would,in Greifs estimation, likely be sent to the local sewage treatment facility which often results in the VOM still entering the atmosphere. Jd. The creation of

## Electronic Filing- Received, Clerk's Office, 10/11/2011

ketones would create another safety hazard. I d. 16. Biofilters and material substitution presents its own set ofproblems. First, Greifasserts that a biofilterproposed to be installed at another Greiffacility would only reduce YOM emissions by 70%. Thus either another technology must also be used or "the reductions in YOM emissions from the use ofthe water diluted test fluid" would have to be considered "as a capture and control technology." Jd. at 13. Biofilters must also be heated during winter months, thus increasing usage ofelectricity, natural gas or steam. Id. 17. Greifalso attempted to dilute the QC test fluid with acetone. Jd. Dilution with acetone, however, can "cause the gasket material sealing the bottom to the drum walls to dissolve." !d. This results in damage to the product and is considered technically infeasible by Greif. Id. at 14.

Water was then tested to see ifdiluting the QC fluid with water would work. Jd. Varying combinations ofQC fluid and water were tested. Id. Greifasserts that the maximum amount of water that allowed Greifs employees to properly check the quality ofthe drums was a dilution of 55% water, 45% QC fluid. Id. at 15. Greifthen tested to see ifthe amount ofdiluted QC fluid could be reduced. Based on testing, Greifdetermined that at least 48 grams oftest fluid can be used during the QC process. Jd.ENVIRONMENTAL IMPACT 18. Greifasserts that the granting ofthe petition will have minimal impact on air quality. !d. at 18. Greifstates thateven atthe highest emissions level allowed Greifby its FESOP,emissions from the QC process would only equal 0.04% ofthe state-wide point source emissions. ld. at 19. It should be noted that the Agency does not acceptthis argument on its face, as almost any individual

source could make the same claim, and it is the aggregate ofsources in the area that causes ozone

## Electronic Filing- Received, Clerk's Office, 10/11/2011

nonattainment. However, thetechnical factors in this instance and the emission reductionsGreifhas already made offset the Agency's concern in this regard. 19. Greifthen notes that the Board has granted adjusted standards from Subpart IT where the emissions were much higher than at Greifs plant. !d. 20. Greif asserts that no cross-media impact is expected from the granting of the adjusted standard. !d. at 20. CONSISTENCY WITH FEDERAL LAW 21. The Board may grant the proposed adjusted standard consistent with federal law under Section 110 ofthe Clean Air Act, 42 U.S.C. §7410, which grants the individual states the authority to promulgate a plan for the implementation, maintenance, and enforcement ofair quality standards, subject to approval by the United States Environmental Protection Agency ("USEPA"). Pursuant to federal law, states also have the authority to revise such a plan, subject to USEPA approval. By following its adjusted standard procedure with respect to the Board's federally authorized and approved air emission regulations, the Board is exercising the authority granted to the states through Section 110 ofthe Clean Air Act. Ifthe requested adjusted standard is adopted by the Board, lllinois EPA has the authority and will submit the adjusted standard to USEPA as a State Implementation Plan revision, thus complying with federal law. Illinois EPA and Greifhave discussed thisproposed adjusted standard with USEPA, and USEPA has provided comments.

PROPOSEDADJUSTED STANDARD 22. Greifhas requested an Adjusted Standard from the Board's air pollution control

## ElectronicFiling- Received, Clerk's Office, 10/11/2011 requirements found at 35 Ill. Adm. Code 218.986(a), insofar as that regulation applies to the YOM emissions from the automatic QC test line at Greifs manufacturing facility in Naperville, Illinois. The lllinois EPA recommends that the Board GRANT Greifs Second Amended Petition as its factors are sufficiently different from the factors in Section 28.1 (c), and requests that the Board allow Greifto operate its facility subject to the following conditions: I. The proposed adjusted standard applies to the emission ofYOM into the atmosphere from the automated QC Test Process line at Greifs fiber drum manufacturing facility located at 5 S 220 Frontenac Road in Naperville, DuPage County, Illinois (the Facility). The Facility manufactures fiber drums. Some ofthe fiber drums are lined with polyethylene to meet customer specifications, particularly for storage and transport offood-grade products. Lined drums must be tested to ensure the integrity ofthe polyethylene lining. That testing is performed at the QC Test Process, which consists ofthe following equipment and steps: a. An automated, mechanical wand is lowered into each lined drum on a conveyor system. The wand is calibrated so that each sprayreleases about the same amount of QC test fluid into each drum. b. The drums then are conveyed to the QC inspection station where the interior ofthe drum is visually inspected for pinholes. c. The drum next is conveyed to a drying oven where most ofthe remaining QC test fluid is evaporated. After leaving the drying oven any remaining QC test fluid is vacuumed from the drum and then the drum is wiped dry. YOM in the QC test fluid is emitted throughout the QC Test Process as well as in the drying oven. 2. The Facility will reduce YOM emissions from its automated QC Test Process by using a test fluid composed ofno more than 45 percent denatured alcohol by weight and no less than 55 percent water by weight. 3. The Facility will calibrate the automated QC Test Process equipmentto spray an average ofno more than 48 grams ofQC test fluid per drum with compliance to be measured at least once per calendar quarter by the following procedure. a. Weigh a plastic bag on a gram scale to determine the weight ofthe bag. b. Place the plastic bag overthe spray head ofthe wand ofthe QC Test Process and secure it in place with a rubber band orbinderclip. c. Cycle the QC Test Process by passing a drum through the process in the normal manner ofoperation with the plastic bag capturing the QC test fluid. Remove the plastic bag from the spray head ofthe wand ofthe QC Test Process and weigh it on the same gram scale used in step a. d. Calculate the weight ofQC test fluid sprayed as the difference between the weight determined in step c and the weight determined in step a.

## Electronic Filing- Received, Clerk's Office, 10/11/2011

e. Repeat steps a. through d. for five cycles ofthe QC Test Process. Calculate the average weight ofQC test fluid sprayed per cycle and compare that average to the standard of an average ofno more thim 48 grams ofQC test fluid per drum. 4. All records and logs required by this adjusted standard shall be retained at a readily accessible location at the source for at least five years from the date ofentry and shall be made available for inspection and copying by the Illinois EPA or USEPA upon request. Any records retained in an electronic format (e.g., computer) shall be capable ofbeing retrieved and printed on paper during normal source office hours so as to be able to respond to an Illinois EPA or USEPA request for records during the course ofa source inspection. 5. The Facility will maintain records ofits QC test fluid usage that will allow the monthly calculation ofthe amount ofQC test fluid used during the month and the calculation ofYOM emissions on a 12-month rolling total basis for comparison to annual YOM limits in the FESOP. To allow these calculations, the Facility will: a. Record the volume ofQC test fluid held as inventory on the first and last day ofeach month. b. Maintain records ofthe volume ofQC test fluid received atthe Facility during each month. c. The volume ofQC test fluid used for a month shall equal the inventory volume on the first day ofthe month plus the volume received at the Facility during the month, less the volume in inventory on the last day ofthe month. d. The volume used during a month calculated in step c shall be multiplied by the YOM content ofthe QC test fluid (in pounds per unit ofvolume) to compute the weight (in pounds) ofYOM emitted during the month. e. Using the emissions ofYOM in pounds calculated for each month in step d, the Facilitywill compute the 12-month roUing YOM emissions for the QC Test Process and report those results to Facility management. 6. Greifwill continueto investigate the availability ofalternative QC testfluids with lower YOM content. Greifwill incorporate such lower YOM QC testfluids into its automated QC Test Processprovided that the lower YOM QC test fluids allow visual detection ofpinholes or other tears or imperfections in the drum linings within an acceptable period oftime and does not result in any negative product quality impacts. 7. The proposed adjusted standard will not affect the calculation ofGreifs potential Emissions Reduction Market System (''ERMS") baseline or its ERMS allotment ifGreifsNaperville plant should participate in the ERMS program. 8. Environmental staffofGreifsparent company will conduct a formal training session for Naperville facility personnel on the requirements ofthe FESOP and the internal procedures for tracking compliance with FESOP conditions.

## Electronic Filing- Received, Clerk's Office, 10/11/2011

9. Emissions and operation ofthe QC Test Process shall not exceed the following limits: VOM Usage VOM Emissions (Tons/Mo) 2.3 2.3 (Tons/Yr) 22.8 22.8 These limits are based on the maximum material usage and the maximum VOM content. Compliance with the annual limit for the QC Test Process shall be determined from a running total of 12 months ofdata. 23. Although the Illinois EPA believes that the alternative compliance methods and add-on options investigated by Greifhave costs which are not RACT, the Illinois EPA strongly disputes Greifs definition ofRACT. The Petitioner relics upon the case ofIn re: Petition of Louis Berkman, AS 97-5 (Dec. 4, 1997) aff'dsub nomEPA v. PCB, 308 Ill. App. 3d 741, 746 & 752- 53, 72I N.E.2d 723, 726-27 & 731 (2"d Dist. 1999) for the proposition that costs exceeding $1,734 (in 1996 dollars) perton ofreductions were economically unreasonable. In addition, in its RACT study, Greifgoes so far as to say that the "Board'sRACTcostthreshold was a maximum of$1,734 per ton ofVOM controlled" (I996 dollars). Reasonably Available Control Technology Study, p. 4- 5. 24. However, in Berkman, the Board clearly stated that the $1,734 figure represents an average figure based upon certain factors, and that "costs cannot be deemed unreasonable simply because they exceed the average." Berkman, AS 97-5, December4, 1997, p 10. The $1,734 figure is nowhere listed as the maximum cost for RACT. The Board even noted that as an average figure, it assumes that some facilities will exceed the cost. Id. It is also worth pointing outthat the costs at issue in the Berkman case greatly exceeded the average figure of$1,734 (the costs were over five times the $1,734 figure in 1996 dollars). ld. Finally, the Board was

## Electronic Filing- Received, Clerk's Office, 10/11/2011 discussing the figure in the context ofvarious miscellaneous metal parts and products coating facilities cases. !d. at 10-11. It is not clear ifthe figure should be used to calculate RACTfor every category ofsources. Berkman's relevance to this proceeding is therefore questionable at best. 25. More importantly, the $1,734 figure is not even relevant or accurate for this matter. The $1,734 figure was derived from an original figure of$1,032 perton in 1980 dollars and was for facilities located in attainment areas. Berkman, 10. Greifis located in a non-attainment area. The proper average figure at the time for a non-attainment area was $1,434.70 in unadjusted dollars. In the Matter of RACTIIRules, Chapter 2, AirPollution, R80-5, Proposed Opinion for Second Notice ofOctober 5, 1982, at 19; adopted as the Final Opinion in the order ofDecember 30, 1982. This figure has not been updated to 1996, let alone 2011, dollars, and the cost of RACT has continuedto increase as tighter control requirements have been required. The $1,734 figure is thus not even relevant to the present matter. 26. Just as important, RACT is not a cost issue alone. Each case has unique factors which are part ofthe conditions. Similarly, each adjusted standard is case specific. Two plants may both produce the same product in the same quantity but RACT will be different for each. The conditions ateach plant guide the Board in determining RACT. In addition, Subpart TI is different from the regulations at issue in the othercases cited. The particulars ofeach regulation help to determine RACT. The Illinois EPA believes that Greifqualifies for an adjusted standard based upon its calculation ofRACT, but it is the RACTfor this facility, not RACT for all

sources which have the same costs. A specific dollar figure for RACT is also unwarranted. Any dollar figure would only obscure the site-specific nature ofeach RACT decision.

## ElectronicFiling- Received, Clerk's Office, 10/11/2011

HEARING 27. Greifhas requested a hearing before the Board.

WHEREFORE, the Illinois EPA recommends that Greifs Second Amended Petition for Adjusted Standard be GRANTED, and an order be entered adopting the adjusted standard with the specific language presented in this Recommendation.

Dated: October II, 201 I I020 North Grand Avenue East P.O. Box 19276 Springfield, Illinois 627949276 (2I7)782-5544 (217)782-9807 Facsimile Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By:ls/ Charles E Matoesian Charles E. Matoesian Assistant Counsel Division ofLegal Counsel

## Electronic Filing- Received, Clerk's Office, 10/11/2011

STATE OFILLINOIS COUNTY OFSANGAMON ) ) ) 

## ss CERTIFICATE OFSERVICE I, the undersigned, an attorney, state that I have served electronicallythe attached, RECOMMENDATJON upon the following persons: John Therriault, Acting Clerk Illinois Pollution Control Board James R. Thompson Center I00 W. Randolph St., Suite 11-500 Chicago, Illinois 60601-3218 Susan Charles Tom Dimond Ice Miller LLP 200 W. Madison Street, Ste. 3500 Chicago, IL 60606-3417

Dated: October II, 2011 I021 North Grand Avenue East P.O. Box 19276 Springfield, Illinois 62794-9276 217.782.5544 217.782.9143 (TDD) Bradley Halloran, Hearing Officer Illinois Pollution Control Board James R. Thompson Center 100 W. Randolph St., Suite 11-500 Chicago, IL 60601-3218

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY, 

### Is/Charles E. Matoesian Charles E. Matoesian Assistant Counsel Division ofLegal Counsel

## Electronic Filing- Received, Clerk's Office, 11/01/2011

# I~ IEPA ATTACHMENT NO._ BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THEMATTER OF: PETITION OF GREIF, INC. AND GREIF PACKAGING, LLC FOR AN ADJUSTED STANDARD FROM 35 ILL ADM. CODE PART218 SUBPARTTT ) ) ) ) ) ) ) AS 2011-001 (Adjusted Standard- Air)



### NOTICE OF ELECTRONIC FILING TO: John Therriault, Clerk Illinois Pollution Control Board James R. Thompson Center 100 West Randolph Street, Suite 11-500 Chicago, IL 60601 Charles Matoesian Division ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276 PLEASETAKE NOTICE that I have today electronically filed with the Office ofthe Clerk ofthe Illinois Pollution Control Board, Petitioners' 

### NOTICE OF ELECTRONIC FILING, SUBMISSION OF AIR QUALITY IMPACT ANALYSIS and 

### CERTIFICATE OF SERVICE, copies ofwhich are attached herewith and servedupon you.

Date: November 

### I, 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: /s/ Susan Charles One ofits Attorneys

I

## ElectronicFiling- Received, Clerk's Office, 11/01/2011

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF: PETITION OF GREIF, INC. AND GREIF PACKAGING, LLC FORAN ADJUSTED STANDARD FROM 35 ILL ADM. CODE PART 218 SUBPART IT 

### ) ) ) ) 

### ) ) ) AS2011-00I (Adjusted Standard- Air)



### SUBMISSION OFAIR QUALITY IMPACTANALYSIS Pursuant to the March 21,2011 Hearing Officer Order ("Order"), petitioners Greif, Inc. and GreifPackaging, LLC ("Greif'') hereby submit the attached "Final Air Quality Impact Analysis ofthe VOC Emissions from the GreifPackaging Facility in Naperville, Illinois, Using the Scheffe Tables." In support ofthis filing Greifstates the following: I. The Order directed Greifto provide an Ambient Air Quality Impact Analysis ("Air Quality Analysis") for ozone as part ofits Petitionfor Adjusted Standard. The Order provides that Air Quality Analysis would be used by the Illinois Pollution Control Board in evaluating whetherthe proposed adjusted standard will "cause or contribute to violations ofthe [National Ambient Air Quality Standards ("NAAQS"] for ozone or delay efforts to attain the NAAQS in a timely manner." The Order further directed Griefto "consultwith the [Illinois Pollution Control Agency ("Agency")] as to the necessary elements Greifshould provide in the analysis" to insure that the Agency has "sufficient supporting documentation" for the Agency's request to revise the State Implementation Plan. 2. Greifhaspresented the Air Quality Analysis to the Agency for review and comment.

I

## Electronic Filing- Received, Clerk's Office, 11/01/2011

3. Counsel for the Agency represented to counsel for Griefthat the Agency has no comments to the Air Quality Analysis. 4. Greif's Air Quality Analysis is attached to this tiling as Exhibit I. WHEREFORE, for the reasons stated above, Greifhas satisfied the requirement ofthe March 21, 2011 Hearing Officer Order to file its Air Quality Analysis with the Illinois Pollution Control Board.

Date: November I, 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, 11/01/2011 CERTIFICATE OF SERVICE I, the undersigned, certify that on this Ist day ofNovember, 2011, I have served electronically the attached NOTICE OF ELECTRONIC FILING and SUBMISSION OF AIR QUALITY IMPACT ANALYSIS upon the following person: John Therriault, Clerk Illinois Pollution Control Board James R. Thompson Center I

### 00 West Randolph Street, Suite 11-500 Chicago, IL 60601 and by U.S. Mail, first class postage prepaid, and electronic mail to the following persons: Charles Matoesian Division ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276 

### Is/Susan Charles Susan Charles

I

### ElectronicFiling- Received, Clerk's Office, 11/01/2011

August II, 2011 Mr. Scott S. Mounts P.E. .EHS Manager- Notih America GreifInc. 366 GreifParkway Delaware, OH 43015 Thomas C. Ponder, Jr. PE Consulting Engineer 56 Bay Drive Itasca, IL 60143

Subject: Final Air Quality Impact Analyses Dear Scott: The final air quality analyses report entitled "Air Quality ImpactAnalysis ofthe VOC Emissions from the GreifpackagingFacilityin Naperville, IJlinois Usingtlte ScheffeTables"is attached. Ifyouhave any questions concerning this report, pleasecall me at (630) 699-7665. Sincerely,

Thomas C. Ponder, Jr. PE



### EXHIBIT 1 Telephone 630-699-7665 email: alponder@comcast.net

### ElectronicFiling- Received, Clerk's Office, 11/01/2011 Air Quality hnpactAnalysis ofthe VOC Emissions from the Greif Packaging Facility in Naperville, Illinois Using the Scheffe Tables Prepared by Thomas C. Ponder, Jr. PE Themostrecent three years ofhighest values for 1-hour ambient ozone data and 8-hour average ambient ozone data (in palis perbillion or ppb) for themonitoring station located in Lisle in Du Page Countyis shownbelow. TheLisle station data was chosen for this analysis becauseitis themonitoring station closest to the GreifPackagingNaperville facility. These data were obtained from TableB-2 in the lllinois Annual Air QualityReports for each of2007, 2008 and 2009. These are thethree mostrecent years for which Illinois haspublished the informationin an Annual Air QualityReport. Highest 1-hourAmbient Ozone Measurements Year

## ~ 2nd 

### 3rd 4th 2009 70 67 66 66 2008 

### 77 70 66 66 2007 99 86 81 80 Highest 8-hourAverage Ambient Ozone Measurements Year 1st 2nd 

### 3rd 4th 2009 61 60 60 59 2008 65 62 58 57 2007 84 75 

### 72 72 1-hour Ozone NAAQS Analysis The 1-hourozone NAAQS is 0.12 parts per million (120 ppb) and the standard is considered attained when the expected number of exceedances is equal to or less than 1 per calendar year, as determined in accordance with Appendix H to 40 CFR Part 50. 40 CFR 50.9(a). Appendix H indicates that in its simplest form, attainment ofthe standard would be demonstrated by computing the number of exceedances at a monitoring site for each calendar year and then averaging the number of exceedances overthe pastthree calendar years. 40 CFR 50, Appendix H, 1. The procedure in the September 1988 report entitled "VOC/NOx Point Source Screening Tables" by Richard D. Scheffe ofthe USEPA Office of Air Quality Planning and Standards (hereafter, "Scheffe 1988") was used to evaluate the air quality impact associated with the proposed adjusted standard forthe Naperville facility. Scheffe 1988 is a screening tool that is intended to allow a simplified calculation ofestimated ozone increments caused by emissions from facilities where VOC emissions exceed NOx emissions and to avoid the need for more resource-intensive modeling. The estimated 1

## Electronic Filing- Received, Clerk's Office, 11/01/2011

ozone increments calculated using Scheffe 1988 are conservative. That is, the estimates are expected to exceed ozone formation that would actually be produced by episodic events. Scheffe 1988 requires only two facility-specific inputs to calculate the conservative estimated impact on ozone air quality: the level ofvolatile organic compound (VOC or sometimes referred to as non-methane organic compounds, NMOC) emissions and the level of NOx emissions. Because this analysis is intended to compute the air quality impact associated with the differential between the adjusted standard proposed for the Naperville facility and compliance with subpart TT, it is appropriate to calculate the VOC input for Scheffe 1988 based on the differential. The maximum difference in VOC emissions from compliance with the proposed adjusted standard versus compliance with subpart TT is 6.7 TPY. This was computed based on the Naperville facility's maximum permitted VOC emissions from the QC Test Process (22.8 TPY) and the different emission reduction rates (73.1% actually achieved during 2009 and 2010 for the adjusted standard and 81% for subpartTT). [22.8/(1-73.1%)*(81%-73.1%)=6.7 TPY] The other input into the analysis is the Naperville facility's NOx emissions, which are 0.1992 TPY based on the facility's 2009 emission inventory. Applying Scheffe 1988 to these inputs, the annual VOC to NOx ratio is 6.7/0.1992 or 33.63. According to Scheffe 1988 Table 2 "Urban based ozone increment as a function of NMOC emissions and NMOC/NOx ratios", the increment for the Naperville facility would be 11 ppb (1.1 pphm x 0.01 pphm/ppb) ifthe facility had 50 TPYof NMOC emissions. This is based on the Table 2 value of 50 TPY NMOC underthe column labeled >20.7 NMOC/NOx ratio. Using linear interpolation per Scheffe 1988, the conservative ozone increment estimate associated with an increase of 6.7 TPY in VOC emissions is 1.47 ppb [11 ppb*(6.7 TPY/50 TPY) =1.47 ppb]. The baseline 1-hourambient ozone measurementto which this estimated ozone increment should be added to demonstrate compliance is unclear. Some EPA guidance suggests that the baseline should be based on the highest of"the fourth highest ambient 1-hour measurements observed over a continuous 3-year period. Guidance forthe 1- hour Ozone Non-attainment Areas that Rely on Weight-of-Evidence for Attainment Demonstrations, page 12, fn.10 (EPA 2002) (available at www.epa.gov/ttn/scram/guidance_sip.htm). In this case, selection ofthe baseline measurement does not matter. Whether one uses the highest ofthe fourth highest measurements at the Lisle station overthe last 3 years (80 ppb) or simplythe highest ozone concentration measured overthose same 3 years (99 ppb), adding the conservative increment estimate forthe Naperville facility would not result in any exceedances ofthe 120 ppb 1-hour standard at that monitoring station. Accordingly, the proposed adjusted standard should not interfere with Illinois' ability to attain the 1-hourozone NAAQS. 8-hourAverage Ozone NAAQS Analysis The 8-hour average ozone NAAQS is 0.75 parts per million (75 ppb). 40 CFR 50.15(a). This standard is considered to be met when the average ofthe annual fourth-highest 2

## Electronic Filing- Received, Clerk's Office, 11/01/2011 daily maximum 8-hour average ozone concentrations for the three most recent, consecutive years is less than or equal to 75 ppb. 40 CFR 50.15(b) and Appendix P, 2.2. This approach is also consistent with "Guidance on the Use of Models and Other Analyses for Demonstrating Attainment ofAir Quality Goals for Ozone, PM2.5 and Regional Haze (EPA April 2007). The baseline 8-hour average ozone concentration is the average ofthe fourth highest values for 2007-2009 for the Lisle station or 62.7 ppb [(72+57+59)/3=62.7]. Adding this baseline to the conservative estimated ozone increment for the Naperville facility (1.47 ppb, see above calculations based on Scheffe 1988) yields a conservative estimated ozone concentration of 64.17 ppb. This conservative estimate for the proposed difference between the adjusted standard and the Subpart TT is less than the 8-hour average ozone standard of 75 ppb established in 2008. Accordingly, the proposed adjusted standard should not interfere with Illinois' abilityto attain the 8-hour average ozone NAAQS.

3ILLINOIS POLLUTION CONTROLBOARD November 8, 2011 IN THEMATTER OF: ) 

### RECEIVED 

# If**CLE~OFFICE** MATTACHMENTNO 

## NOV- 82011 ·- STATE OF 

### ILLINOIS Pollution Control Board ) ) PETffiON OF GREIF PACKAGING, LLC., )**~** . 

# :... DRIGINAt FOR AN ADJUSTED STANDARD FROM ) AS 

### Il-l 

# --- 35 

### ILL. ADM. CODE 218 SUBPART

### TT ) (Adjusted Standard- Air)

place: ) ) ) NOTICE OFHEARING A hearing in the above-captioned matteris scheduled at the following date, time, and

ITIS SO ORDERED. December20, 2011 J:OOp.m. James 

### R. Thompson Center Room 11-512 100West Randolph Street

Chicago, lllinois 60601

BradleyP. Halloran Hearing Officer lllinois Pollution Control Board James 

### R. Thompson Center, Suite 11-500 100W. Randolph Street Chicago, lllinois 6060I 312.814.8917

In .;<)rnplii'llli.'C" with llll· Am..:rit:arh Wllh [)i,;rhilirit:s Ac1 and otherappliC' .. ahk fcJcr.d and State laws, tht. ht;uing will be accc..,...ihh: l('**imli~·idu:.tb** with**<lisahilitic~.** Persons requiring :luxlli<uy ilids and service." .shnuld ccml3cl Dc:.,rmhy (iunn. Ckrl. ofthe- Oo:ml. at 100 Wt·.;;r Ran<lnlph St.. Suire 11-500. !'hicagu, Illinois fl0601. <ll !Lkphonc**number~** I:VSI.l-6Y31, fm; numht.•r ::12/81**~**..\(lfi9, or Tl)l) mrmher 3I**~/S14-61).n.** fh**~·Jay<.,** pril\J' to thchearing.2 CERTIFICATE OF SERVICE It is hereby certified that true copies ofthe foregoing order were mailed, first class, on November 8, 2011, to each ofthe persons on the service list below. 

### It is hereby certified that a true copy ofthe foregoing order was hand delivered to the following on November 8, 20II: John Theniault Illinois Pollution Control Board James R. Thompson Center 100 W. Randolph St., Ste. 11-500 Chicago, Illinois 60601

# ~**?.\~Q>~-** \ Bradley

### P. Halloran Hearing Officer Illinois Pollution ControlBoard James 

### R. Thompson Center 100 W. Randolph Street, Suite 11-500 Chicago, illinois 6060I 312.814-8917

SERVICE LIST

AS 2011-001 Division ofLegal Counsel !EPA 1021 North Grand AvenueEast P.O. Box 19276 Springfield,

# n.. 62794-9276

AS 2011-001 ThomasW. Dimond Ice MillerLLP 200W. Madison Suite 3500 Chicago,

# n.. 60606 AS 2011-001 Susan Charles Ice Miller LLP 200W. Madison Suite 3500 Chicago,

# n.. 60606

## ~

## R~NO._ ILLINOIS POllUTION CONTROLBOARD November 8,. 2011 

## NOV 

# -8 2011 STATE OF IWNOIS 

## FGIIUIIon

## eootrolBoiilftl IN THEMA ITER OF: PETITION OFGREIFPACKAGING, llCFOR ANADJUSTED STANDARD FROM 35 ILL. ADM. CODE 218 SUBPARTIT ) ) ) ) ) ) 

### • AS 11-1 

# (_. C.!RIGINjj! (Adjusted Standard- Air)



### ...... :.. .

HEARING OFFICER ORDER On November 8, 2011, all parties participated in a telephonic status conference with the hearing officer. December 20, 2011, was the date agreed to for the hearing in the abovecaptioned petition. Thetime and location ofthe hearing will be noted in thenotice ofhearing. Thehearing officer directs the petitioner to address the pre-hearingquestion attached to this order. A written response must be filed 10 days before the hearing. The parties ortheir legal representatives are directed to appear at a telephonic status conference with the hearing officeronDecember I,2011, at 11:00 a.m. Thetelephonic status conferencemustbe initiated by the petitioner, but each party is nonethelessresponsible for its own appearance. Atthe conference,theparties mustbe prepared to discuss the status ofthe above-captioned matter and theirreadiness for hearing. IT IS SO ORDERED.

BradleyP. Halloran Hearing Officer lllinoisPollution Control Board James 

### R. Thompson Center, Suite 11-500 100 West Randolph Chicago, lllinois 60601 312.814.8917

### AS 11-1 GREIF PACKAGING,LLC HEARING QUESTIONS FORPETITIONERAND IEPA 35 lAC 104.406(g) On November 1, 2011, GreifPackaging submitted its "Final Air Quality Impact Analysis ofthe YOC Emissions from the GreifPackagingFacility in Naperville, Illinois, Using the Scheffe Tables" (Air Quality Impact Analysis or Analysis) in response to the March 21,2011 Hearing Officer Order. The following questions pertain to the calculations provided in the analysis. 

### A. Calculation ofYOCEmissions for the Air Quality Impact Page 2 ofGreif'sAnalysis explains that the Analysis "is intended to computethe airquality impact associated with the differential between the adjusted standard proposed for the Naperville facility and compliancewith subpart TT..." (Air Quality Impact Analysis at 2.) The analysis used the following equation to arrive at the differential: [22.8/(1-73.1%)] 

## * (81%- 73.1%) 

### =

### 6.1 tons per year (tpy) where 22.8 

### = 73.1% 

### = 81% 

### = Maximum permitted YOC emissionsfrom the QC test process at the GreifNaperville facility reduction rate actually achieved during 2009 and 2010for the adjusted standard ' reduction rate required by SubpartIT Basedon a review ofthe information provided, it appears that the differential couldbe calculated as follows, producing aresult that is closerto 1.8 tpy, which is Jess than 6.7 tpy: [22.8 tpy (1-.731)]- [22.8 tpy (1-.81)] 

### = 1.8 tpy where [22.8 tpy (1-0.731)] =YOM emissions with the proposed adjusted standard [22.8 tpy (1-0.81)] 

### = YOMemissions based on the SubpartTTreductions

• Would you pleaseclarify the differential YOM emissions to be used to computethe air quality impact? 

### B. Application ofthe Scheffe Tables

1TheAir Quality Impact Analysis relies on the "VOC/NOx Point Source ScreeningTables" by Richard D. Scheffe, September 1988 (Scheffe Method). 1 Page 7 ofthe Scheffe Method ·lists three steps for determining an ozone incrementfor the screening estimate: 1- Determinewhich column ofthe screening tables is applicable. Greif's Analysis relied on the ''Table 2. Urban based ozone increment (pphm) as a function ofNMOC [nonmethane hydrocarbon] emissions and NMOC/NOx ratios." Greif's Analysis calculated the annual VOC to NOx ratio as 6.7 I 0.1992 = 33.63, where 0.1992 is the 2009 annual NOx emissions. Under ScheffeTable 2, the Analysis determined the column labeled"> 20.7" NMOCINOx ratio was applicable. (Analysis at 2.) 

### Ifthe revised differential of 1.8 tpy calculated above is used, the NMOC/NOx ratio appears to be 1.8 tpy I 0.1992 

### = 9.036. Based on this, the column in Table 2labeled "5.2

- 20.7" appears to be applicable instead. 2- Calculate annual NMOC emissions rates in tpyfrom maximum daily rate. Greif's Naperville facility maximum permitted annual VOC emissions is 22.8 tpy. No maximum daily rate is indicated, so the maximum permitted annual rate is used. (Analysis at 2.) 3- Interpolatelinearly to produce an interpolatedozoneincrement. Page 2 ofGreif's Analysis used linearinterpolation to calculate an ozone increment of 1.47 ppb associated with the increase of6.7 NMOC tpy byusing the"> 20.7" column ofthe Scheffe Table 2 and the following equation: (1.1 pphrn 

## *O.Dl pphm/ppb)*(6.7 tpy I 50tpy) 

### = 1.47 ppb Consistent with the Scheffemethod, it appears the linearinterpolation couldbecalculated as follows::

where the x-axis is the NMOC Emissions (tpy) and the y-axis is the Ozone Increment (pphm) Graphed below is the Scheffe Table2,demonstrating that each columnhas a different slope.

1http://ndep.nv.gov/bapc/oermitting/downloadlmodel!scheffe.doc 2Table and Graph based on the Scheffe Table 2: Urban based ozone increment (pphm) as a function of NMOC emissions and NMOC/NOx ratios.

Ozone Increment (pphm, parts per hundred million) NMOC/NOx {tonsNMOC /tons NOx, >20.7

Multiply pphm by 0.01 to obtain ppm

25 ,-------· 

# l i 2C· 

### +-----

1 

### ! lS

# i 110

# -~--' I r I • 

### I ! 

# I,

# f--

I 

### I 

## I G ----------·-r-··---- 5.2 to 20.7



## l 0 2000**~000** 6000 BJOO 10000 12000

-·---·-·-··-·----·----- 

### 3 <5.2

->20.7 NMOC/NCx -5.2 to 20.7 NMOC/NOx -<5.21'1MOC(N.OxTheex:ample on page 9 ofthe Scheffe Method linearly interpolates the ozone increment from the two closet points as graphed from Table 

### 2. However, Grief's emissions differential is lowerthan the lowest point in the table oron the graph. The Scheffe Table 

### 2 and the resulting graph do not go to zero for eitherthe NMOC emissions or the ozone increment, but a 

### 0 pphm ozone increment would correspond to a 

### 0 tpy NMOC emission. Therefore, for the purposes ofa linearinterpolation, the twocloset points to the 1.8 tpy revised value above would be 0 and 50 NMOCEmissions, with an ozone increment between 0 and 1.1 pphm under the "5.2

- 20.7" column. Basedon this, the following equation couldbe used to linearly interpolate the ozone increment associated with 1.8 tpy NMOC emissions and 9.036 NMOC/NOx: ratio:

where:

yields: YI =0 

### y 2 = 

### ? (ozone increment associatedwith NMOC emissions) 

### y 3 

### = 1.1 XJ

# = 0 X 2

# = 1.8 

# x,= 50

{[(1.8-0)(1.1-0)]/ (50-0)} 

### +0 

# = 0.0396pphm 0.0396 pphrn 

## *0.01 

### = 0.000396ppm 0.000396 ppm

# * 1000ppb I ppm=0.396 ppb Itappears that the ozoneincrement associated with an increase of 1.8 tpydifferential ·couldbe closerto 0.396 ppbratherthan the 1.47 ppbthat Greifassociated with an

increaseof6.47 tpy in its Analysis.

• Would you please clarify your analysis ofthe ozone increment? 

### C. Impacton Illinois Ability toAttain the 1-hourand 8-hour OzoneNAAQS Pages 2 and 3 ofthe analysis conclude that adding 1.47 ppbtothe highest ofthe fourth highest ozone measurements wouldnotresultin any ex:ceedances ofthe 120 ppb !-hour standard or75 ppb8-houraverage ozone national Ambient AirQuality Standards (NAAQS). 

### 4• Based on yourcomments regarding the revised calculations postulated above, would you please restate whether the impact ofGreif's proposed adjusted standard would cause orcontribute to violations ofthe NAAQS for ozone ordelay efforts to attain the NAAQS in a timely manner?



### 56 CERTIFICATE OF SERVICE It is hereby certified that true copies ofthe foregoing order were mailed, first class, on November 8, 2011, to each ofthe persons on the service list below. It is hereby certified that 

### a true copy ofthe foregoing order was hand delivered to the following on November 8, 2011: John Theniault Illinois Pollution Control Board James R. Thompson Center 100 W. Randolph St., Ste. 11-500 Chicago, Illinois 60601

# ~?.\~o,_- \ BradleyP. Halloran Hearing Officer Illinois Pollution Control Board JamesR. Thompson Center 100W. Randolph Street, Suite 11-500 Chicago, lllinois 60601 312.814-8917

SERVICELIST

AS 2011-001 Division ofLegal Counsel !EPA 1021 North GrandAvenue East P.O. Box 19276 Springfield,

## n.. 62794-9276

AS 2011-001 Thomas W. Dimond Ice MillerLLP 200 W. Madison Suite 3500 Chicago, 

## n.. 60606 AS 2011-001 Susan Charles Ice Miller

### LLP 200W. Madison Suite 3500 Chicago, 

## n.. 60606POLLUTION CONTROL BOARD, ILLINOIS Pub Hrg 1212012011 AOOROERNUMBER: 0000176522-01 PO NUMBER: Pub Hrg 1212012011 AMOUNT: $26

## .4° NO OF AFFIDAVITS:

POLLUTION CONTROL BOARD, ILLINOIS 100W RANDOLPH ST 11-500 DON BROWN CHICAGO, IL 60601-3218 

# 13 Sun Times Media Sun-Times Media West Certificate of Publication IEPA ATTACHMENT NO.-

State ofIllinois- County of DuPage Sun-Times Media West, does hereby certify it has published the attached advertisments in the following secular newspapers. All newspaperS meet Illinois Compiled Statue requirements for publication of Notices per Chapter 715 ILCS 5/0.01 et seq. R.S. 1874, P728 Sec 1, EFF. July 1, 1674. Amended by Laws 1959, ?1494. EFF. July 17, 1959. Formerly Ill. Rev. Stat. 1991, CH100, Pl. Note: Notice appeared in the following checked positions. PUBLICATION OATE(S): 11/13/2011 Naperville Sun

IN WITNESS WHEREOF, the undersigned, being duly authorized, has caused this Certificate to be signed and notarized By {,i;::J**-:!i~=-** David Fontechla Account Manager- Public Legal Notices

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No " . OFFICIAL SEAL TAMMYALBANOS NOTARY PUBLIC, STA1tOF IWNOIS MY COMMISSION EXPIRES 2-22-2015iEPA ATTACHMENT

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### ILLINOIS POL.LUTION CONTROL BOARD IN THE MATTER OF: ) 

### PETITION OF GREIF No. AS 11-1 

# l PACKAGING, LLC, FOR AN ) 

### (Adjusted Standard

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### ~ ADJUSTED STANDARD FROM "'Ji**~** 

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### OFFICE 

### 35 ILL. ADM. CODE 218 

## JAN 0

## 52012 SUBPART TT ) 

### STATE OF ILLINOiS •.:>ollution Control Board



### RECORD OF PROCEEDINGS had before Kari Wiedenhaupt, taken at James R. Thompson Center, 

### ( Room 11-512, 100 West Randolph Street, Chicago, Illinois on Tuesday, December 20, 2011, commencing at 1:00p.m. in reference to the above-entitled cause.Page 2 1 

## APPEARANCES: 2 

## ILLINOIS POLLUTION CONTROL BOARD 3 

## Bradley P. Halloran

- Hearing Officer 4 

## Anand Rao

- Senior Environmental 5 

## Scientist 6 

## Alisa Liu

- Environmental Scientist 7 

## Jennifer Burke

- Member 8 

## Daniel Robertson

- Staff Attorney 9 10 

## ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 11 

## Yoginder Mahajan

- EPA Bureau of Air 12 

## Charles E. Matoesian 13 14 

## ALSO PRESENT: 15 

## ICE MILLER, LLP 16 

## THOMAS W. DIMOND 17 

## SUSAN CHARLES 18 

## 200 WEST MADISON STREET 19 

## SUITE 3500 20 

## CHICAGO, IL 60606 21 

## (312) 726-7146 22 

## Representing Greif. 23 24 l

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### Page 3 1 2 3 

### I N D E X 4 

### WITNESS EXAMINATION 5 

### THOMAS C. PONDER 6 

### By THOMAS C. DIMOND 17 7 8 

### KHAALIS D. RAHMAN 9 

### By THOMAS C. DIMOND 21 10 11 12 

### E X H I B I T S 13 

### NUMBER MARKED FOR ID 14 

### Petitioner's Exhibit 15 

### No. 1 18 16 

### No. 2 19 17 

### No. 3 20 18 19 

### E X H I B I T S 20 

### NUMBER ADMITTED INTO EVIDENCE 21 

### Petitioner's Exhibit 22 

### Nos. 1-3 21 23

### ( Page 4 1 

### REPORT OF PROCEEDINGS 2 

### TUESDAY, DECEMBER 20, 2011 3 

### MR. HALLORAN: Hi. Good afternoon. My name 4 

### is Bradley Halloran. I am a hearing officer s with the Illinois Pollution Control Board. I am 6 

### also assigned to this matter. It's entitled, in 7 

### the matter of: Petition of Greif, Inc. and 8 

### Greif Packaging, LLC, for an adjusted standard 9 

### from 35 Illinois Administrative Code Part 218, 10 

### Subpart TT. It's an adjusted standard. our 11 

### docket is 2011-001; again, adjusted standard, 12 

### and it's for air. 13 

### Today is Tuesday, December 20th, 2011. 14 

### It's approximately 1:00 p.m. I note except for 15 

### some of the representatives from our office, 16 

### there are no members of the public present. 17 

### This hearing of today is being held pursuant to 18 

### Section 104.400, Subpart D of the Board's 19 

### procedural rules regarding adjusted standards. 2o 

### The hearing will be governed in 21 

### accordance with the Illinois Environmental 22 

### Protection Act, the Board's procedural rules; 23 

### specifically Section 101, Subpart F, and it has 24 

### been noticed up appropriately.

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## I note that this hearing is intended to develop a record for review by the entire Board. I'm not going to make the final decision in this matter. It's up to the five esteemed members of the Pollution Control Board. They will take a look at the record, the transcript, and any post-hearing briefs, exhibits and then make their decision. Before we go any further, there is a procedural matter I think we should note for the record. In response to questions earlier posed by our technical staff, petitioner filed an application for treatment as non-disclosable information pursuant to Section 130.406 of the Board's procedural rules. And this is in regards to answers to our questions. To that end, the application itself will be taken with the case, and the information ; sought to remain confidential will not be divulged during this hearing. I also want to introduce members of our Pollution Control Board. We have member, Jennifer Burke, here. We have our scientists Anand Roa and Alisa Liu, who will be doing aPage 6 1 

### good portion of the questions. We also have 2 

### Daniel Robertson, a staff attorney. 3 

### With that said, Mr. Dimond, would you 4 

### like to introduce yourself? 5 

### MR. DIMOND: Certainly. I'm Tom Dimond from 6 

### Ice Miller representing Greif, and I'm 7 

### accompanied here today by my colleague, Sue 8 

### Charles, and Tom Ponder, our technical expert, 9 

### and Khaalis Rahman, who is the plant manager for 10 

### the Naperville Plant. 11 

### MR. HALLORAN: Thank you. Greif. I always 12 

### pronounce that incorrectly, thanks. 13 

### Mr. Matoesian? 14 

### MR. MATOESIAN: My name is Charles Matoesian 15 

### appearing for the Illinois Environmental 16 

### Protection Agency, and here with me to answer 17 

### any questions is Yoginder Mahajan, who is an 18 

### Environmental Protection Engineer. 19 

### MR. HALLORAN: Thank you. And again, Mr. 2o 

### Dimond, you introduced Ms. Charles, right? I'm 21 

### sorry. 22 

### MS. CHARLES: Yes. 23 

### MR. HALLORAN: Okay. Thank you. Do you want 24 

### to give a brief opening?1 ( 2 3 4 5 6 7 8 9 10 11 12 

### ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 7 

### (Whereupon, a discussion was had

off the record. 

### l MR. HALLORAN: All right. Mr. Dimond, did you want to give an opening, please? MR. DIMOND: Thank you. I do have an opening statement, Mr. Hearing Officer. First of all, I would like to thank the Board for its time and effort on this Adjusted Standard Petition. We would also like to thank Mr. Matoesian and the numerous Illinois EPA staff who reviewed our proposal. They offered good, constructive comments on it so that it could ultimately

-- that they could recommend that it be granted. They were also very helpful in facilitating early discussions with U.S. EPA to address their concerns, because I think as anyone who is familiar with the filings in the case is aware, ultimately if the Board approves the adjusted standard, it will be submitted as a SIP Revision to EPA. So we appreciate all the effort that Illinois EPA has put into that. I would like to summarize the context and the proposal set forth in the Second AmendedPage 8 1 

### Adjusted Standard Petition. As background, 2 

### Greif's plant in Naperville is a fiber drum 3 

### manufacturing plant. It employs approximately 4 

### 90 people: It is a synthetic minor source for 5 

### volatile organic material emissions or what we 6 

### may sometimes abbreviate as VOM. And it has a 7 

### federally enforceable state operating permit, 

### a which we will frequently refer to as a FESOP 9 

### that makes it a synthetic minor source for the 10 

### VOM materials. 11 

### In general, the process of 12 

### manufacturing fiber drums is pretty 13 

### straightforward. You have a sheet of corrugated 14 

### fiber drum or fibers. You roll it into a 15 

### cylindrical shape. You attach a top and a 16 

### bottom, and you have got a drum. Many of the 17 

### drums that are manufactured in our Naperville 18 

### plant need a polyethylene liner, typically 19 

### because customers either want to put a liquid or 2o 

### food grade product in it. 21 

### In the process of applying the 22 

### polyethylene to the inside of the fiber drum, 23 

### you can develop small imperfections in the 24 

### polyethylene liner, and because of that, we need , ; 

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### ( Page 9 1 

### to test that polyethylene liner to make sure 2 

### that those imperfections have not arisen during 3 

### the manufacturing process. 4 

### To do that we have

-- the plant has s what is called a QC test process, and basically 6 

### it involves this. The drums are on a conveyer 7 

### line, which is typical for many manufacturing 8 

### plants. It goes down the line. There is a 9 

### mechanical wand that is triggered to actually 

## 1o move down inside the drum, and it sprays a 11 

### certain amount of a liquid material on the 12 

### polyethylene liner on the interior of the drum. l3 

### And if the imperfections exist, the 14 

### liquid will get through the polyethylene on to 15 

### the fiber and will make spots appear on the 16 

### fiber drum so that you can visually see those 17 

### spots as a darker spot on the fiber drum. 18 

### Historically, the Naperville plant has 19 

### used a 100 percent denatured alcohol as the test 20 

### fluid for this test process. In 2008

-- and I 21 

### should note that the denatured alcohol is a 22 

### volatile organic material by definition. In 23 

### 2007 and 2008 the emissions from the Naperville 24 

### facility were large enough on an annual basisPage 10 l 

### that they exceeded the threshold for coverage 2 

### under the Board'.s Subpart TT regulations. 3 

### The Subpart TT regulations are a part 4 

### of the Board's RACT regulations for the Chicago 5 

### metro area, and in particular, Subpart TT is the 6 

### subcategory for sources that are not covered by 7 

### any more specific category within the RACT 

### a regulations. So it's sort of a catchall 9 

### category. 10 

### There are two particularly relevant 11 

### aspects of Subpart TT for this proceeding. One 12 

### is that if you trigger the applicability, there 13 

### is in general an 81 percent capture and control 14 

### requirement set forth in the regulations. And 15 

### the other particularly important aspect of those 16 

### regulations for our purposes, is that the 17 

### regulations are what are generally called in the 18 

### industry, once in always in regulations. 19 

### So if 

### you trip the applicability 20 

### threshold once, you are in, and in general, you 21 

### can't get out. So those are two particularly 22 

### important aspects of those regulations. 23 

### As I mentioned, in 2007 and 2008 the 24 

### Naperville plant did exceed that threshold, andPage 11 1 

## so it triggered the applicability of the Subpart 2 

## TT. There are two or three aspects of the 3 

## operations at Naperville that make complying 4 

## with Subpart TT difficult. 5 

## Installing control equipment is 6 

## difficult in part because of the nature of the 7 

## characteristics of the denatured alcohol and in 8 

## part because of the configuration of the test 9 

## process. The denatured alcohol itself 1o 

## evaporates relatively slowly, and so it's not as 11 

## if when you are on the production line and the 12 

## drums are moving along on the conveyer belt that 13 

## all the emissions will occur at a single point. 14 

## They will begin to occur as soon as the 15 

## liquid is sprayed inside the drum, but as the 16 

## drum continues down the conveyor line to the 17 

## spot on the line where the visual inspection for 18 

## the imperfections actually occurs, that takes 19 

## about 40 seconds, and I think it's about 40 feet 20 

## or so. We have got that number in the petition. 21 

## And then even after they are inspected, those 22 

## drums continue to be conveyed on a conveyor line 23 

## eventually to a drying oven that, you know, 24 

## heats up the material inside the drum trying to

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## get more evaporation. 2 

## And then even after the drying of it, 3 

## in some instances employees have to get in 4 

## well, they have to reach their arm inside the 5 

## drum with a towel and dry out the remaining test 6 

## fluids. So it's a slow evaporating material, 7 

## and that means that if we were going to capture 8 

## all the VOM emissions, we would have to have 9 

## tunnel like structures that go around the 1o 

## conveyor belts. We would also have to leave 11 

## some spot for the visual inspection to occur, 12 

## because the employees actually have to be able 13 

## to get up next to the drum to be able to see the 14 

## imperfections. 15 

## And for the

-- you know, for the 16 

## purposes of trying to achieve an 81 percent 17 

## capture and control, it means that you have got 18 

## to capture a lot of air. That, in turn, means 19 

## that you have to build a fairly a larger size 2o 

## piece of control equipment, and with larger size 21 

## in your control equipment comes added cost. So 22 

## those are factors that make capturing the 23 

## emissions and achieving 81 percent capture and 24 

## control rather difficult for our kind of1 2 3 4 5 6 7 8 9 10 11 12 ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 13 

### facility.As we were addressing this issue with the Agency, we recognized that we would need to do a RACT study as is commonly done when adjusted standards are due, done or when someone seeks an adjusted standard from a RACT regulation. We asked Mr. Ponder to prepare that for us, and he did, and that was attached to our first petition that we filed I want to say in January of 2011. Essentially the RACT study looked at three different post emission control alternatives and looked at two what I would call**material~** 

### substitution options. The three back-end control options

-- one was a recuperative thermal oxidizer, second was a carbon absorber, and the third was a bio-filter. And Mr. Ponder looked at those and estimated a cost per ton of VOM reduced that ranged between 11,667 and $17,672 per ton. Each of those alternatives had some drawbacks associated with them as well. Those are details in the RACT study, and I'm not going to go over them here, but those are addressed in the 1**""-"="""-..,~-=--.........-...-** ...**~~~**

### ( 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 14 

### details of the RACT study. As I mentioned, we also looked at two material substitution alternatives. One was to replace the denatured alcohol with a test fluid that is not a volatile organic material. The material that we looked at there was acetone, which while it's a volatile organic, it's not a volatile organic material under the Clean Air Act. We tested that and found that it had a problem. When you are sealing up a fiber drum, you have to put a gasket at the bottom of the drum so that you have a tight seal between the bottom and the drum and the cylinder that goes on top of it. The acetone unfortunately causes that gasket material to degrade, and that's just

-- you know, if you have got a drum that leaks at the bottom, that's not really a drum that any of our customers want to buy. So we tested the acetone. That did not work. The other material substitution option we looked at was diluting the denatured alcohol with water. We tested that at a variety of different combinations. I think we went as high

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### as either 60 or 70 percent water content. That 2 

### detail is in our Adjusted Standard Petition and 3 

### in the RACT study itself. 4 

### What we found is that when we went that 5 

### low, you it did not cause spots to develop on 6 

### the drum in sufficient time that our workers 7 

### could identify it visually on the conveyor line. 8 

### You

-- you know, it takes about 40 seconds for 9 

### the drums to get to the spot in the line before 1o 

### they go into the oven. So you need to be able 11 

### to detect the imperfections by then. 12 

### What we did is we set up a test where 13 

### we intentionally created imperfections in some 14 

### drums. We sprayed the test fluid in at 15 

### different dilution levels and ultimately found 16 

### that at about a 55 percent water, 45 percent 17 

### denatured alcohol

-- and that's not by volume 18 

### but by weight

-- there we could still detect the 19 

### imperfections, but if we put more than 2o 

### 55 percent water in, we were not able to detect 21 

### the imperfections in sufficient time. 22 

### And the RACT study concludes that for 23 

### this

-- for this process, we concluded that the 24 

### Board should consider that RACT. Based on thePage 16 1 

### information that I have summarized here today 2 

### and that is explained in more detail in the RACT 3 

### study and in our Second Amended Petition that 4 

### was filed in August, we believe that Greif has 5 

### met the standards in Section 28.1 of the 6 

### Illinois Environmental Protection Act for having 7 

### an adjusted standard granted by the Board. 8 

### After the filing of our second Amended 9 

### Petition in August, we did continue to work with 1o 

### Illinois EPA to address concerns that either 11 

### they or u.s. EPA had with the precise wording of 12 

### the adjusted standard that we had put in our 13 

### Second Amended Petition. 14 

### The Agency's recommendation that was 15 

### filed in October, they had slightly different 16 

### language than we had in our Second Amended 17 

### Petition in August. We have reviewed the 18 

### language that is in the Agency's recommendation, 19 

### and we find that language satisfactory and would 2o 

### accept that as the Board's

-- as an adjusted 21 

### standard from the Board. So we are in agreement 22 

### with the language that was submitted by the 23 

### Agency in their recommendation. 24 

### In closing, again, I would like to1 2 3 4 5 6 7 8 9 10 11 12 

### ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 17 

## thank the Agency and the Board for their efforts to review our adjusted standard proposal. I do want to put on a couple of witnesses today. I want to put on Mr. Ponder to authenticate some of the documents in the record as exhibits, and I also would like to put on Mr. Rahman to put in some evidence regarding the confidential information that we submitted that can be taken with the case. And then, of course, if Board members or their technical advisors have questions, myself and Ms. Charles, Mr. Ponder and Mr. Rahman will be here, and we will be available to answer those. Thank you. MR. HALLORAN: Thank you, Mr. Dimond. You may proceed and call one of the your witnesses or both

-- Mr. Ponder, I guess, first. MR. DIMOND: Okay. Mr. Ponder. (Whereupon, the witness was duly

sworn.) THOMAS C. PONDER, Jr., having been first duly sworn, was examined and testified as follows: EXAMINATIONPage 18 1 

### BY MR. DIMOND: 2 

### Q. 

### Mr. Ponder, can you please state your 3 

### name for the record? 4 

### A. My name is Thomas C. Ponder, Jr. 5 

### Q. And do you have any degrees or 6 

### accreditations? 7 

### A. I have a BS in chemical engineering 8 

### from the University of Texas. I have six 9 

### professional engineering licenses including 10 

### Illinois, and I'm also a certified cost 11 

### engineer. 12 

### Q. Thank you. Were you asked to prepare a { 

### '· 13 

### study for Greif in connection with this 14 

### proceeding? 15 

### A. Yes, I was. 16 

### Q. 

### Okay. I'm going to hand you a document 17 

### that I would like to have marked as Exhibit 1. 18 

### (Whereupon, Exhibit No. 1 was 19 

### marked for identification.) 20 

### BY MR. DIMOND: 21 

### Q. Could you identify for the record what 22 

### Exhibit 1 is? 23 

### A. It's the Reasonably Available Control 24 

### Technology RACT Study for the Greif Naperville1 

### facility. 2 

### Q. 3 

### A. 4 

### Q. 

### And did you prepare that? Yes, I did. Okay. Thank you. That's all the 5 

### questions I have got regarding that. Page 19

6 

### I'm now going to distribute a second 7 

### document, which I would request be marked as 8 

### Exhibit 2. 9 

### (Whereupon, Exhibit No. 2 was 10 

### marked for identification.) 11 

### BY MR. DIMOND: 12 

### Q. 

### And again, Mr. Ponder, I would ask you 13 

### if you could identify what we have had marked as 14 

### Exhibit 2 for the record? 15 

### A. 

### This is an Air Quality Impact Analysis 16 

### of the VOC emissions from the Greif Packaging 17 

### facility in Naperville. 18 

### Q. And did you prepare that as well? 19 

### A. Yes, I did. 20 

### Q. Describe for us in

-- at a high level 21 

### what the what analysis is performed in the 22 

### Air Quality Impact Analysis. 23 

### A. Well, this is an analysis based on the 24 

### method by a gentleman named Shafe (phonetic) 

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## \ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 

### Page 20 

### where you compare the 

## voc emissions from the facility to the nitrogen oxide emissions, you get a ratio, and then based on the quantity, you determine how much impact it's going to have on the ambient ozone levels. MR. DIMOND: Thank you. And then I have a third document that I would like to have marked as Exhibit 3. (Whereupon, Exhibit No. 3 was marked for identification.} BY MR. DIMOND: Q. And again, Mr. Ponder, if you could identify what Exhibit 3 is? A. Well, this is a response to some questions from the Illinois Environmental Protection Agency on the Air Quality Impact Analysis. Q. Okay. And did you prepare that

-- those response questions to the questions as well? A. Yes, I did. MR. DIMOND: All right. Mr. Hearing Officer, we would request that Exhibits 1, 2 and 3 be received into the record. 

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### Page 21 

### MR. HALLORAN: Mr. Matoesian, any objection? MR. MATOESIAN: None. MR. HALLORAN: Petitioner's Exhibits 1, 2 and 4 

### 3 are admitted into evidence. 5 

### (Whereupon, Petitioner's Exhibit 6 

### Nos. 1-3 were admitted into 7 

### evidence. ) 8 

### MR. DIMOND: And that's all the questions I 9 have for Mr. Ponder. 10 

### MR. HALLORAN: Terrific. You may step down. 11 

### MR. DIMOND: Next, I would like to call Mr. 12 

### Rahman. 13 

### (Whereupon, the witness was duly 14 

### sworn.) 15 

### KHAALIS RAHMAN, 16 

### having been first duly sworn, was examined and 17 

### testified as follows: 18 

### EXAMINATION 19 

### BY MR. DIMOND: 20 

### Q. Thank you, Mr. Rahman. can you give us 21 

### your full name? 22 

### A. Khaalis Rahman. 23 

### Q. Okay. And what is your current 24 

### position?**~** . 1

### Page 22 1 

### A. Plant manager in Naperville. 2 

### Q. 

### Are you employed with Greif? 3 

### A. Yes. 4 

### Q. 

### How long have you been employed by 5 

### Greif? 6 

### A. About sixteen years. 7 

### Q. 

### How long have you been the plant 8 

### manager at Naperville? 9 

### A. One year and one month. 10 

### Q. 

### I will note for the record, Mr. 11 

### Rahman's testimony is primarily related to our 12 

### Application For Treatment of Confidential ( 13 

### Information. We did not submit an affidavit 14 

### with that, and his testimony here today is meant 15 

### to fill in any perceived holes in that. 16 

### Are you familiar with the Federally 17 

### Enforceable State Operating Permit for the 18 

### Naperville facility and the conditions that it 19 

### places on the Naperville plant? 20 

### A. Yes, I am. 21 

### Q. 

### Does your -- if I use the acronym 22 

### FESOP, you will recognize that, correct? 23 

### A. Yes. Q. 

### Does the FESOP require the plant to 

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## maintain data on the number of line drums 2 

## produced per month or per year? 3 

### A. 

## No. 4 

### Q. 

## Does the FESOP 

## require the plant to s report data on the number of line drums produced 6 

## per month or per year to Illinois EPA 

## or any 7 

## other regulatory agency? 8 

### A. 

## No, it does not. 9 

### Q. 

## Does the FESOP 

## require the company to 1o 

## maintain or report data on the amount of 11 

## denatured alcohol used per line drum? 12 

### A. 

## No. 13 

### Q. 

## Is the information on the number of 14 

## line drums produced by month maintained by 1s 

## Greif? 16 

### A. 

## Yes, it is. 17 Q. 

## Is that information that is treated by 18 

## the company as confidential information that is 19 

## not disclosed outside the company? 20 

### A. 

## Yes, it is. 21 

### Q. 

## Is access to that information 22 

## restricted to certain company employees? 23 

### A. 

## Yes, it is. 24 

### Q. 

## And how does the company restrict1 2 3 4 5 6 7 8 9 10 11 12 

### ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 24 

### access to that information? A. By database form and by administrative levels and making the accessible levels by password. Q. 

### And so when you say it's in database form, you mean it's accessible through a computer terminal? A. 

### Yes. Q. 

### And so the only people who can get access to it are people who have the right password; that's correct? A. 

### And the correct administrative level. Q. 

### Thank you. If a competitor of Greif's knew the amount of denatured alcohol used per line drum, could they calculate the number of line drums produced based on Naperville's reported emissions? A. 

### Yes. Q. 

### And how could a competitor use that information to Greif's disadvantage? A. Primarily by ascertaining the amount of volume that we have going to that particular market. It's a fairly closed market. We know our suppliers

-- or we know our competitors who '

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### supply those markets. They know the customers that we supply, and they can gain certain market information from that. MR. DIMOND: All right. That's all the questions I have. MR. HALLORAN: Thank you, Mr. Rahman. Mr. Matoesian, anything? MR. MATOESIAN: I have no questions. MR. HALLORAN: Okay. We are off the record. (Whereupon, a discussion was had

off the record.) MR. HALLORAN: All right. We are back on the record. And I think

-- I'm sorry. Go ahead, Mr. Dimond. MR. DIMOND: Do you think he can step down? MR. HALLORAN: Yes, he can step down, correct. And I think what we will do

-- unless anybody else has any questions at this moment, I think we will swear Mr. Matoesian and the !EPA's witness in as well. And then Ms. Liu at this point will ask questions, and I guess I'm not sure who it will be directed to, I assume ' 

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### ( 13 14 15 16 17 18 19 20 21 22 23 24

.........**~** ..... Page 26 

### Petitioner's experts for now. MS. LIU: And the IEPA. MR. HALLORAN: I'm sorry? MS. LIU: And the IEPA. MR. HALLORAN: And the IEPA. In any event, if you raise your right hand, Kari will swear you in. (Whereupon, the witnesses were

duly sworn. ) MR. HALLORAN: Just keep your voices up unless you want to move up, but Ms. Liu will commence her questioning. MS. LIU: Good afternoon. The first two questions I have are directed at Greif packaging. In Greif's filing from December 8th, 2011, in response to Hearing Officer ordered questions served on November 8th, 2011, on Page 2, Mr. Thomas Ponder states, quote, "The maximum tons of 

# voc usage that would need to be controlled if the facility complied with Subpart TT would be approximately 84.8 tons per year," end quote. This is the first time that Greif uses

### (

( 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 27 

### this figure of 84.8 tons per year in the record. In the Second Amended Petition Greif states that it, quote, "Does not employ any equipment to capture or destroy VOM emissions," end quote. Is the 84.8 tons per year figure based on the maximum line drum production before the adjusted standard initiatives are put into practice?**~** l 

### MR. PONDER: I think it is. How much solvent 

# l**~** 

### we would use is based on the

-- the potential ' 

### solvent we would use based on this production. MR. DIMOND: Could you repeat the question, please, or have it read back? MS.**LIU~** 

### Is the 84.8 tons per year figure based on the maximum line drum production before the adjusted standard initiatives are put into practice? MR. DIMOND: I think the answer to that question is no. It's a theoretical calculation of

-- it's a theoretical calculation of how much VOM could be used if you were achieving reductions from that level as a post -- as a post control. The facility has never actually had that much emissions or used that much VOM. j L.,._,.

...,o:;.;;o ..

### .,o;,,.,._,._,_=·=··="""'=-"'-""·==-==

..·="'-==· ==========""·**=="'·==~··**Page 28 1 

### It's a theoretical calculation. 2 

### MR. PONDER: Basically, if you use the 3 

### emission level of 22.8 and divide by the control 4 

### efficiency, that's how you get, the 84.8. 5 

### MS. LIU: So is that the maximum? 6 

### MR. PONDER: That's the maximum you could use 7 

### if 

### you don't -- 

### if 

### you limit your emissions to 8 

### 22.8. 9 

### MR. DIMOND: As it explained in the response, 10 

### the way you get to the 84.8 is you take 22.8, 11 

### and you divide it by 1 0.731. 

### So it's a 12 

### theoretical calculation. The facility has never ( \ 13 

### actually used that much. 14 

### MS. LIU: And that theoretical calculation is 15 

### based on -- 16 

### MR. PONDER: The emission limit. 17 

### MS. LIU: In your redacted information and 18 

### I won't mention those numbers

-- you have a 19 

### maximum line to drum production number per year 20 

### and an amount of solvent that is an amount of 21 

### VOM's that are used per drum. When you multiply 22 

### those two numbers, you come up with 84.8, 23 

### correct? 24 

### MR. PONDER: I don't know that off the top of

### Page 29 1 

### my head. 2 

### MR. HALLORAN: You know what? I think what 3 

### we are going to have to do

-- if the two 4 

### witnesses can sit up here, because the voices 5 

### keep dropping. And I was kind of afraid of 6 

### that. Sorry. 7 

### MS. LIU: I do have the un-redacted version. 8 

### MR. PONDER: Yes. Give me the un-redacted 9 

### version, and I can tell you if that's the right 

### 1o number. 11 

### It comes out that way, because this is 12 

### the theoretical. They don't make that many 13 

### drums, but that's how many they could. 14 

### Yes, you get the 22.8 that way. The 15 

### number that's in this redacted version, that's 16 

### the maximum number of drums they could make in 17 

### the facility. I don't believe it's 8760, but 18 

### they can't run 8760, because there is changes in 19 

### downtime and stuff like that, but that's the 20 

### maximum they could make. They don't make 21 

### anywhere near that many. 22 

### MS. LIU: Okay. But if they do, then the 23 

### maximum VOM usage would be 84.8? 24 

### MR. PONDER: Yes, it would be.1 2 3 4 5 6 7 8 9 10 ll 12 

### ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 30 

### MS. LIU: And then does the 84.8 ton per year figure represent the maximum potential to emit before the adjusted standard practices are initiated? MR. PONDER: I believe so. MS. LIU: Those are all the questions I have for you. So thank you for clearing that up. MR. DIMOND: The only qualification I would make on that statement is that potential to emit as a regulatory concept is allowed to consider limitations that are placed on the facility by permit. By permit the facility has a limit of 22.8 tons of emissions. Technically, I think in a potential to emit calculation made for new source review purposes, you would be allowed to take the limitation that is in the federally enforceable state operating permit and consider that to be the potential to emit for the facility; but again, if you don't consider that, then, yes, the 84.8 might be considered the maximum potential to emit. MS. LIU: Thank you. Thank you, Mr. Ponder. The next few questions I have are directed primarily at the Agency.

# ' Page 31 

# ! 1 

## Mr. Ponder calculated the difference in 2 

## VOM emissions between the proposed adjusted 3 

## standard for a 73.1 reduction to the Subpart TT 4 

## requirements for an 81 percent reduction at s 6.7 tons per year. Based on this Mr. Ponder 6 

## calculated an ozone increment of 1.47 parts per 7 

## billion. 8 

## Greif asserted that the granting of 9 

## this petition would have minimal impact on air 1o 

## quality. However, the Agency stated, quote, "It 11 

## should be noted that the Agency does not accept 12 

## this argument on its face as almost any 13 

## individual source could make the same claim, and 14 

## it is the aggregate of sources in the area that 1s 

## causes ozone non-detainment. However, the 16 

## technical factors in this instance and the 17 

## emission reductions Greif has already made 18 

## offset the Agency's concerns in this regard. " 19 

## Previously in Adjusted Standard AS 09-4 2o 

## for a company called Royal Fiberglass, the 21 

## agency stated that an increase of two parts per 22 

## billion is quote, "potentially significant", end 23 

## quote. l 

# i 

# ! ! 

# i 1 1



## In this case we are looking at ;**~** 24

# u~~~

## ( 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 32 

### 1.47 parts per billion. My first question is, does the Agency believe that an increment of 1.47 parts per billion is potentially significant? MR. MATOESIAN: I think we would like to answer that in writing, if possible. MS. LIU: Okay. And the second question is, does the Agency believe the granting of this proposed adjusted standard will cause or contribute to the violations of the National Ambient Air Quality Standards for ozone or delay efforts to attain the NAAQS, N-A-A-Q-S, in a timely manner? MR. MATOESIAN: We can answer that in writing, too. MS. LIU: I would appreciate that, thank you. MR. HALLORAN: Anybody else have any questions for the witnesses at this time? MR. DIMOND: None here. MR. HALLORAN: All right. Let's go off the record for a minute. (Whereupon, a discussion was had

off the record. ) MR. HALLORAN: Back on the record. Mr. 

# l '**~.........._--~=>0:~-~·==~..__...,.........,._,,=--~-=-=-~-"""-=-"'=......,..·""""""'-""""""'""""'~**

### Page 33 1 

### Dimond would like to respond to one of the 2 

### questions Ms. Liu posed, and you may proceed, 3 

### Mr. Dimond. 4 

### MR. DIMOND: Sure. It's not technically a 5 

### response since the questions were directed to 6 

### the Agency, but in connection with the question 7 

### of whether or not the incremental emissions from 8 

### the Greif facility as they were calculated 

### in 9 

### the filings that were made by Greif and its 10 

### representatives, as I mentioned at the 11 

### beginning, if this adjusted standard is approved 12 

### by the Board, it will ultimately have to be { 

### ' 13 

### submitted to U.S. EPA as a SIP Revision. 14 

### In the discussion

-- in the three-way 15 

### discussions that occurred between Greif, 16 

### Illinois EPA, and U.S. EPA, U.S. EPA raised 17 

### certain concerns regarding whether or not the 18 

### proposal was consistent with Section 110 of the 19 

### Clean Air Act, which in general they described 20 

### as an anti-backsliding provision related to SIP 21 

### revisions. 22 

### In discussions with them, they 23 

### ultimately were satisfied in that regard by the 24 

### addition to the adjusted standard of an( 

### ' 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 34 

## additional condition. I would like to indicate for the record what it is, but I need to look at it and be sure. We added

-- if you will

-- on this Second Amended Petition on Page 16 of the Second Amended Petition is where we start the adjusted standard language, and then on Page 19 is Item No. 9 that sets monthly and annual limits and tons per month or tons per year for emissions from the facility. Those limits are identical to what is currently in the facility's federally enforceable state operating permit. U.S. EPA considered the addition of that condition into the adjusted standard sufficient to address the section 110 issue under the Clean Air Act, and I think that that issue is

-- you know, is essentially similar to the issue of whether or not the incremental emissions from complying with the adjusted standard versus Subpart TT would be considered to delay or cause a violation of the National Ambient Air Quality Standards. So I just wanted to point out for the 

# ' 1 

### ' ' i 

### '**·~** 

## '---,_

...**.,_,_,,_=~="'·"'-~=-"'-""-="'~ ~""'"''-"'-=·=-=··-""-="-=·-""-"'-"'-="'~-=-""-=·-=·**  

## ""·=·**·07;-=.===""-"'=""~·~=~**1 I I 2 3 4 5 6 7 8 9 10 11 12 { \ 13 14 15 16 17 18 19 20 21 22 23 24 Page 35 

### Board that that is a condition that was not in our original adjusted standard petition that was filed in January. It was in the Second Amended Petition filed in August, and that was inserted specifically to address that concern of 

## u.s. EPA. So I just

-- I thought the Board should be aware that that issue was addressed with EPA in that manner. MR. HALLORAN: Thank you, Mr. Dimond. Counsel has indicated that they are going to reserve their closing statements/arguments for their post-hearing brief, and while off the record, we discussed the post-hearing briefing schedule. We came up with I think the transcript should be due by January 2nd, 2012. on January 11th, 2012, the IEPA is to respond to Ms. Liu•s questions posed during this hearing. Grief's opening brief is due January 26th, 2012, and IEPA's response, if any, will be due February 9th, 2012. And Mr. Dimond, Greif's reply, if any, is due February 16th. Mr. Matoesian has indicated that he will let me know whether or not they intend toPage 36 

### file a response on February 9th, and then I will get a written order out advising everyone of such and the Board as well. I set public comment for January 17th. Did I forgot anything? I just want to thank everybody present. Thank you for your civility and professionalism, and happy holidays and happy near year. (FURTHER DEPONENT SAITH NOT.)1 2 3 4 5 6 7 8 9 10 11 12 

### ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 37 

## I, KARI WIEDENHAUPT, do hereby certify that the foregoing was reported by stenographic and mechanical means, which matter was held on the date, and at the time and place set out on the title page hereof and that the foregoing constitutes a true and accurate transcript of same. I further certify that I am not related to any of the parties, nor am I an employee of or related to any of the attorneys representing the parties, and I have no financial interest in the outcome of this matter. I have hereunder subscribed my hand on the day of ;-.,.,""' "'/

KARI WIEDENHAUPT, CSR

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