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

I EPA ATTACHMENT NO. _k._ 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER OF: 

PETITION OF GREIF, INC. AND 

GREIF PACKAGING, LLC 

FOR AN ADWSTED STANDARD FROM 

35 ILL ADM. CODEPART218 

SUBPART IT 

) 

) 

) 

) 

) 

) 

) 

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 of Legal Counsel 

Illinois Environmental Protection Agency 

1 02 I North Grand A venue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

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

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

FILING, PROOF OF PETITION NOTICE REQUIREMENTS and CERTIFICATE OF 

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

Date: June 17, 2011 

Thomas W. Dimond 

Susan Charles 

ICE MILLER LLP 

200 West Madison Street 

Suite 3500 

Chicago, Illinois 60606 

Respectfully submitted, 

GREIF, INC. and GREIF PACKAGING, LLC 

By: Is/ Susan Charles 

One of its Attorneys 

1 
Electronic Filing- Received, Clerk's Office, June 17, 2011 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

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 Greif Packaging, LLC ("Greif'') published notice of the filing of their 

Amended Petition for an Adjusted Standard ("Petition") by advertisement in a newspaper of 

general circulation in the area of Greif's Naperville plant. In support of this filing Greif states the 

following: 

I. Greif filed the Petition with the Clerk of the Illinois Pollution Control Board on 

May 31,2011. 

2. Pursuant to the Petition, Greif seeks an adjusted standard from 35 Ill. Adm. Code 

§ 218.986(a) as it applies to control requirements for emissions of volatile organic material at 

Greif's fiber drum manufacturing facility located in Naperville, Illinois. 

3. On June 10,2011, Greif published notice of the filing of the Petition by 

advertisement in the Naperville Sun, a newspaper of general circulation in Naperville, Illinois. 

4. As required by 35 Ill. Adm. Code Section 104.408(a), Greif published notice of 

the filing of the Petition v..ithin 14 days after it filed the Petition. 

5. The notice includes the specific language required by 35 Ill. Adm. Code Section 

104.408(b). 
Electronic Filing -Received, Clerk's Office, June 17, 2011 

6. As required by 35 Ill. Adm. Code Section 104.410, a certificate.ofpublication 

issued by the publisher of the Naperville Sun certifying publication of the notice on June 10, 

2011 is attached as Exhibit 1. The certificate of publication attaches Greifs notice as it appeared 

in the Naperville Sun and states that the Naperville Sun satisfies the requirements of the Illinois 

Notice by Publication Act, 715 ILCS 5/0.01, et seq. The language included in Griefs notice is 

consistent with 35 Ill. Adm. Code Section 104.408(b). 

WHEREFORE, for the reasons stated above, Greif has satisfied the requirements for 

providing notice of the filing of its Amended Petition for an Adjusted Standard and for filing 

proof of such notice with the Illinois Pollution Control Board. 

Date: June 17, 2011 

Thomas W. Dimond 

Susan Charles 

ICE MlLLER LLP 

200 West Madison Street 

Suite 3500 

Chicago, Illinois 60606 

Respectfully submitted, 

GREIF, INC. and GREIF PACKAGING, LLC 

By: Is/ Susan Charles 

One of its Attorneys 

2 
Electronic Filing- Received, Clerk's Office, June 17, 2011 

CERTIFICATE OF SERVICE 

I, the undersigned, certify that on this 17th day of June, 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 6060 I 

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

Charles Matoesian 

Division of Legal 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 

OFACIAL SEAl. 

CATHERINE A CVNCAR 

NOTARY PUBliC, STATE OF IWNOIS 

KANE COUN'!Y 

MY COMMISSION EXPIRES 11/1912014 
Electronic Filing - Received, Clerk's Office, June 17, 2011 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

7 

I EPA ATTACHMENT NO. __ 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MA TIER OF: 

PETITION OF GREIF PACKAGING, LLC 

FOR AN ADJUSTED STANDARD FROM 

35 ILL ADM. CODE PART 218 

SUBPARTTT 

) 

) 

) 

) 

) 

) 

AS 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, IL 60601 

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 of the 

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

FILING, SECOND AMENDED PETITION FOR AN ADJUSTED STANDARD and 

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

Date: August 1 0, 2011 

Thomas W. Dimond 

Susan Charles 

ICE MILLER LLP 

200 West Madison Street 

Suite 3500 

Chicago, Illinois 60606 

Respectfully submitted, 

ICE MILLER, LLP 

By: Is! Susan Charles 

One of its Attorneys 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

CERTIFICATE OF SERVICE 

I, the undersigned, certify that on this lOth day of August, 2011, I have served 

electronically the attached NOTICE OF ELECTRONIC FILING and SECOND AMENDED 

PETITION FOR AN ADJUSTED STANDARD upon the following person: 

John Therriault, Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

100WestRandolph Street, Suite 11-500 

Chicago, lL 6060 I 

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

Charles Matoesian 

Division of Legal 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 CONTROL BOARD 

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 pursuant to 

35 Ill. Adm. Code§ 104.400, et seq., submit this Second Amended Petition for an Adjusted 

Standard ("Petition") to the illinois Pollution Control Board ("Board"), seeking an adjusted 

standard from 35 Ill. Adm. Code§ 218.986(a) as it applies to the emissions of volatile organic 

material ("YOM") into the atmosphere from Greif's fiber drum manufacturing facility located at 

5 S 220 Frontenac Road in Naperville, DuPage County, Illinois. 

I. INTRODUCTION AND SUMMARY OF PROPOSED ADJUSTED STANDARD 

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

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

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

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

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

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

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

station. 

1 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

Greif uses an automated system to spraytne interior of the drum liners with QC test fluid. 

As a drum moves along the conveyor belt toward the QC spray station it triggers a sensor on the 

guide rail that causes the drum to stop. A mechanical wand then drops down into the drum and 

sprays the QC test fluid. The wand is calibrated so that each spray releases about the same 

amount of QC test fluid into each drum. Once the QC test fluid has been sprayed onto the drum 

liner, the wand retracts so the drum may continue to move along the conveyor. 

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

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

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

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

drying oven any remaining fluid is vacuumed from the drum and then the drum is wiped dry. 

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

Greif tracks its VOM emissions on a monthly basis by calculating the mass ofVOMs 

used and assuming that all usage is emitted to the atmosphere. To calculate mass, Greif records 

the volume of de!llltured alcohol held as inventory on the first and last day of each month. Greif 

also tracks the volume of any denatured alcohol purchased within each month. The volume of 

denatured alcohol purchased during a month is added to the inventory held on the ftrst day of 

that month. The total, less any inventory remaining on the last day ofthe month, equals the 

volume of denatured alcohol used. The volume is then multiplied by the VOM content (in 

pounds per gal) of the denatured alcohol to compute the mass (in pounds) ofVOM emitted 

during the month. 

2 
Electronic Filing - Received, Clerk's Office, 08/10/2011 

Air emissions ofVOM and hazardous air pollutants ("HAPs") at Greif's Naperville 

facility are subject to Federally Enforceable State Operating Permit No. 9707044 ("FESOP").1 

Condition 3 ofthe FESOP limits VOM emissions from the QC Test Proeess to 22.8 tons per year 

("tpy"). Condition 3 also includes emission unit specific limits on VOM emissions from the 

remainder of the plant (which includes a paint spray booth, a caulk applicator, and ink printing). 

The aggregate of these limits is 1.4 tpy. The FESOP limits HAP emissions to 10 tpy for any 

single HAP or 25 tpy for any combination of such HAPs. Greif reported 2010 emissions from its 

Naperville facility of9.95 tons ofVOM (plant-wide) and total combined HAPs ofl.87 tons. 

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

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

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

reported emissions from the QC Test Process 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 percent capture and control requirements of 35111. Adm. Code Part 218, 

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

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

Adm. Code Section218.980 (a)- (c). 

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

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

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

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

Greif, Inc, has lransferred ownership and operation of the Naperville plant to its whoUy owned subsidiary, Greif 

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

3 
Electronic Filing Received, Clerk's Office, 08/10/2011 

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

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

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

with the rtXjuirements of subsection (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 percent from each emission unit .... 

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

the QC Test Process satisfY RACT control rtXj·uirements in Section 218.986(a). See Exhibit A, 

Reasonably Available Control Technology Study, dated August 2010, revised March 2011, 

prepared for Greif by Thomas C. Ponder, Jr., PE ("RACT Study"). Greif submitted the RACT 

Study to the Agency on September 16, 2010. The RACT Study evaluated three capture and 

control systems: capture plus recuperative thennal oxidizers, capture plus carbon adsorbers and 

capture plus biofilters and material substitution. The RACT Study concludes that each option 

could achieve at least 81 percent capture and control ofVOM emissions as required under 

Section 2l8.986(a), but only at a cost per ton ofVOM emissions controlled of between $11,667-

$17,672. These costs exceed what the Board typically bas considered reasonable in adopting 

RACT regulations. See infra at Section II(H)(l )(d). 

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

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

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

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

gasket material that seals the drum bottom to the side walls to dissolve, which is unaccej)table. 

However, material substitution using a test fluid composed of 45 percent denatured 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 QC test fluid mixture could satisfy appropriate product 

quality standards, Greif conducted additional tests to determine whether the amount of QC test 

fluid applied to each drum run through its QC Test Process could be reduced. Based on this 

testing, Greif determined that it could reduce the QC test fluid sprayed to an amount not to 

exceed 48 grams. 

Based on the RACT Study and the analysis of adjusted standard requirements as set forth 

herein, Greif has satisfied the conditions for issuing an adjusted standard from the 81 percent 

capture and control requirement of Section 218.986(a). 

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

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

are found at 35 Ill. Adm. Code Part 104, Regulatory ReliefMechanisms, Subpart D. Sections 

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

standard petition. The requisite headings and corresponding information required under Subpart 

D are set forth below. 

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

Greif seeks an adjusted standard from the requirements of 35 Dl. Adm. Code Part 218, 

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

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

Section 218.986 became effectiveJanuary 6, 1994. RACT for Chicago Ozone, R93-14. Pursuant 

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

5 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

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

excluded from Subpart TI. The control requirements for qualifying emission units at sources 

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

part: 

Every owner or operator of an emission unit subject to (Subpart TI] shall comply 

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

a) Emission capture and control equipment which achieves an 

overall reduction in uncontrolled YOM emissions of at 

least 81 percent from each emission unit .... 

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

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

standard from Section 218.986(b)- (e).2 

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

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

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

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

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

45 percent denatured alcohol and 55 percent water. Greif also will limit the amount of QC test 

fluid that will be sprayed into each drum. These proposed modification of the QC Test Process 

will reduce YOM emissions from Greif's QC Test Process by approximately 70 percent on a unit 

basis- to an annual emission level that is below the applicability threshold of Subpart TI. 

2 Subsections (b)- (e) are not applicable to the QC Test Process at Naperville 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 

of an equivalent alternative control plan (subsection (c)), non.;;ontact process cooling water (subsection (d)) and 

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

(subsection (c))). 

6 
Electronic Filing - Received, Clerk's Office, 08/ 10/2011 

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

Valiations, and Alternative Means of Control 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 of any other Sections of this Part: 

a) Any exemptions, variations or alternatives adopted by the 

Board pursuant to Section 28, 28.1 or 35 of the Act to the 

control requirements, emission limitations, or test methods 

set forth in this Part shall be effective only when approved 

by the USEPA as a SIP revision. 

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

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

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

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

from 35 Ill. Adm. Code Part 218, AS 92-13, Slip. Op. at 4 (September 1, 1994); see also, In the 

Matter of Reasonably Available Control Technology for Major Sources Emitting Volatile 

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

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

B. Nature of the Regulation of General Applicability- Section 104.406Cb) 

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

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

with severe non-attainment areas to adopt RACf regulations applicable to sources of YOM 

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

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

Subpart TI. Id. 

7 
Electronic Filing -Received, Clerk's Office, 08/1 0/2011 

C. Level of Justification- Section 104.406(c) 

The regulations of general applicability fi-om which Greif seeks an adjusted standard do 

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

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

(Authorizing the Board to grant an adjusted standard upon adequate proof of the following: (1) 

the factors relating to the petitioner are substantially and significantly different from the factors 

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

existence of those factors justifies an adjusted standard; (3) the requested standard will not result 

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

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

standard is consistent with applicable federal law.). 

D. Facility and Process Description- Section 104.406(d) 

Greif operates a fiber drum container manufa"'turing facility in Naperville, DuPage 

County, Illinois. DuPage County is part of the Metropolitan Chicago Interstate Air Quality 

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

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

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

manufacturing began at the Naperville plant in April1988. Greif's Naperville facility 

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

general, fiber dnuns are produced by cutting fiber material to the appropriate length, forming it 

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

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

and transport of food-grade products. 

8 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

Greif conducts QC testing of the drwn liners as follows: (1) as a drum moves along the 

conveyor belt toward the QC spray station it triggers a sensor on the guide rail causing the 

conveyor belt to stop; (2) a mechanical wand drops into the drum and releases the QC test fluid; 

(3) the mechanical wand retracts, the conveyor belt is restarted and the drum is conveyed 45 feet 

to the QC inspection station where the interior is visually inspected for pinholes (if pinholes arc 

present, the ethanol causes a brown spot to appear, enabling the line inspector to detect the 

pinhole); (4) the drum is conveyed 120 feet to a drying oven where most of the remaining test 

fluid is evaporated; (5) after leaving the drying oven any remaining fluid is vacuumed from the 

drum and the drum is wiped dry. The QC test fluid evaporates slowly, resulting in VOM 

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

Jn addition to the QC Test Process described above, permitted VOM emission sources at 

the Naperville facility include a caulk applicator, the paint spray booth and ink printing. Each of 

these sources has a source-specific annual VOM limit in the FESOP, and the aggregate of those 

VOM limits is 1.4 tpy. Because the plant's emissions have historically been less than 25 tpy, the 

facility has not previously been subject to Subpart TT and does not employ any equipment to 

capture or destroy VOM emissions. 

E. Jnvestigation of Compliance Alternatives: Methods for Reducing VOM 

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

104.406(e) 

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

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

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

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

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

9 
Electronic Filing -Received, Clerk's Office, 08/10/2011 

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

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

offset the benefits of any associated YOM reductions. 

1. Capture Systems 

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

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

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

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

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

contains YOM, may still be emitting YOM. An effective capture system would require a tunnel 

enclosure covering the 165 foot conveyer system from the QC spray station to the inspection 

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

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

ensure adequate capture of emissions. Id. Dueling to the associated control dcvice(s) also would 

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

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

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

for each control system. 

2. Control Technologies. 

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

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

material substitution. Id. at Section 3.2. As detailed below, each of these 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 of YOM reduction and/or have potentially harmful safety impacts. 

a. Recuperative Thermal Incinerators 

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

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

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

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

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

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

recovery as great as 60 percent and therefore requires Jess natural gas than traditional 

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

complete destruction of YOM). Id. 

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

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

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

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

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

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

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

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

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

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

11 
Electronic Filing -Received, Clerk's Office, 08/ 10/2011 

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

See RACT Study at Table 4-1. 

b. Carbon Adsorbers 

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

concentrations. See RACT Study at 3.2.2. A carbon adsorber typically consists of two or more 

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

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

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

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

cases, distillation is required to separate the YOM materials from the regeneration steam. Jd. 

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

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

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

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

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

the use of carbon beds. Jd. Fwther, ketones found in the denatured alcohol present an inherent 

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

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

health and safety risks remain. Jd. 

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

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

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

at Table 4-1. 

12 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

c. Biofilter and Material Substitution 

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

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

on the Greif drum plant in Oroille, Ontario, which could potentially reduce VOM emissions 

from that plant by 70 percent. !d. At Naperville, the 8 I percent capture and control objective 

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

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

control technology reduction. !d. A biofilter system has lower operating costs, although the 

- capital costs are comparable to incinerators. !d. Biofilters must be heated to maintain 

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

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

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

VOM emissions. !d. 

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

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

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

at Table 4-I. 

3. Material Substitution Options 

a. QC Test Fluid- Dilution with Acetone 

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

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

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

13 
Electronic Filing -Received, Clerk's Office, 08/ 10/2011 

Due to 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 

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

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

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

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

imperfections in the drum linings. 

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

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

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

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

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

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

Griefs inability to meet its customers' quality assurance standards. Id. 

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

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

5 seconds. Id. Based on this result, Greif next experimented with a mixture of70 percent 

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

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

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

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

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

14 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

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

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

spraying- although with significantly lighter staining. !d. Based on these test runs, Greif 

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

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

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

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

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

detection of drum defects without harming the product. 

After determining that the 45/55 QC test fluid mixture could satisfy appropriate QC 

standards, Greif conducted additional tests to determine whether the amount ofQC test fluid 

applied to each drum could be reduced. Based on this testing, Greif determined that it could 

reduce the QC test fluid sprayed into each drum to an amount not to exceed 48 grams. 

Diluting the QC test fluid with water and reducing the amount of fluid used also has the 

potential to reduce annual emissions ofVOM from the QC Test Process below the 25 tpy 

applicability threshold of Section 218.980 and below the 22.8 tpy emissions limit in condition 3 

of the FESOP. This has been demonstrated by a significant reduction in overall facility 

emissions between 2007 and 2008 and the approximate 70% reduction in per drum emissions. In 

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

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

reduced by $541 per ton ofVOC controlled. See RACT Study at Table 4-1. 

15 
Electronic Filing -Received, Clerk's Office, 08/ 1 0/2011 

4. Compliance Alternatives Conclusion 

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

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

material substitution. While each of these options could achieve the 8 I percent capture and 

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

$I 7 ,672. These costs exceed what the Board has considered reasonable in adopting RACT 

regulations. See infra at Section II(H)(I ). Material substitution using acetone is technically 

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

percent denatured alcohol combined with reducing the amount of QC test fluid applied to each 

lined drum that is tested results in an overall reduction in costs while achieving an approximately 

70% reduction in VOM emissions compared to pre-substitution levels. 

F. Greif's Proposed Adjusted Standard- Section 1 04.406([) 

Greif proposes the following adjusted standard for adoption by 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 

220 Frontenac Road in Naperville, DuPage County, Illinois (the Facility). 

2. The Facility will reduce VOM emissions from its QC Test Process by 

using a test fluid composed of no more than 45 percent denatured alcohol 

by weight and no less than 55 percent water by weight. 

3. The Facility will calibrate the QC Test Process equipment to spray no 

more than an average of no more than 48 grams of QC 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 of the bag. 

b. Place the plastic bag over the spray head of the wand of the 

QC Test Process and secure it in place with a rubber band or binder clip. 

c. Cycle the QC Test Process by passing a drum through the 

process in the normal manner of operation with the plastic bag capturing 

the QC test fluid. Remove the plastic bag from the spray head of the wand 

of the QC Test Process and weigh it on the same gram scale used in step a. 

16 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

d. Calculate the weight of QC test fluid sprayed as the 

difference between the weight determined in step c and the weight 

determined in step a. 

e. Repeat steps a. through d. for five cycles of the QC Test 

Process. Calculate the average weight of QC test fluid sprayed per cycle 

and compare that average to the standard of an average of no more than 48 

grams of QC 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 of entry and shall be made available for inspection and copying by 

the Agency or USEPA upon request. Any records retained in an 

electronic format (e.g., computer) shall be capable of being retrieved and 

printed on paper during normal source office hours so as to be able to 

respond to an Agency or USEP A request for records during the course of a 

source inspection. 

5. The Facility will maintain records of its denatured alcohol usage that will 

allow the monthly calculation ofthe amount of denatured alcohol used 

during the month and the calculation ofVOM emissions on a 12-month 

rolling total basis for comparison to annual VOM limits in the FESOP. To 

allow these calculations, the Facility will: 

a Record the volume of denatured alcohol held as inventory 

on the first and last day of each month. 

b. Maintain records of the volume of denatured alcohol 

received at the Facility during each month. 

c. The volume of denatured alcohol used for a month shall 

equal the inventory volume on the first day of the 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 VOM content of the denatured alcohol (in pounds per 

unit of volume) to compute the weight (in pounds) ofVOM emitted during 

the month. 

e. Using the emissions ofVOM in pounds calculated for each 

month in step d, the Facility will compute the 12-month rolling VOM 

emissions for the QC Test Process and report those results to Facility 

management. 

6. Greif will continue to investigate the availability of alternative QC test 

fluids with loVfer VOM content. Greif will incorporate such lower VOM 

QC test fluids into its QC Test Process provided that the lower VOM QC 

test fluids allow visual detection of pinholes or other tears or 

imperfections in the drum linings within an acceptable period of time and 

does not result in any negative product quality impacts. 

17 
Electronic Filing - Received, Clerk's Office, 08/ 1 0/2011 

7. The proposed adjusted standard will not affect the calculation of Greif's 

potential Emissions Reduction Market System ("ERMS") baseline or its 

ERMS allotment if Greif's Naperville plant should participate in the 

ERMS program. 

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

session for Naperville facility personnel on the requirements of the FESOP 

and the internal procedures for tracking compliance with FESOP 

conditions. 

9. Emissions and operation of the QC Test Process shall not exceed the 

following limits: 

VOMUsage 

VOM Emissions 

CTons/Mo) 

2.3 

2.3 

CTons/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 of data. 

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

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

1. Air Quality Impact Analysis of Greif's Operations 

Application of the proposed adjusted standard will allow Greif to reduce VOM emissions 

from the QC Test Process by about 70% on a per drum basis compared to pre-change levels. 

While this reduction is less than the 81 percent capture and control requirement of Section 

218.986(a), the proposed adjusted standard will allow Grief to reduce VOM emissions below 

levels required by its FESOP and the threshold for Subpart TT applicability. 

The emissions ofVOM from the QC Test Process at the Naperville plant will have a 

minimal impact on air quality. 1n 2009, state-wide VOM point source emissions were 54,668 

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

at www.epa.state.il.us/air/air-qualitv-report/2009/air-quality-reoort-2009.pdf) (201 0 data was not 

available at the time Greif filed its Amended Petition). Thus, even at the maximum permitted 

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

18 
Electronic Filing - Received, Clerk's Office, 08/1 0/2011 

emissions from the QC Test Process would amount to about 0.04% of state-wide point source 

emissions. Similarly, 2009 YOM point source emissions for the Metropolitan Chicago area were 

11,884. See September 8, 2010 E-mail from EP A.FOIA.BOA@ Illinois.gov to Susan Charles 

responding to Freedom oflntormation Act request, attached a~ Exhibit B. Assuming maximum 

emissions permitted under the FESOP for the Naperville plant, YOM emissions from the QC 

Test Process would amount lo only 0.19% of Metropolitan Chicago point source emissions. 

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

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

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

from 35Ill. Adm. Code Section 2I8.986, AS 00-6, Slip. Op. at 5 (April6, 2000) (uncontrolled 

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

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

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

significantly impact air quality). The Board also has shown a pa1iicular concern for capture and 

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

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

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

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

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

Environmental Protection Agency) for an Adjusted Standard from Parts of 35I/l. Adm. Code 

218.966 and 2I8.986, AS 92-14, Slip. Op. at 9 (Board granted adjusted standard where use of 

control technology would emit NOx which, like YOM, contributes to ozone formation, that 

would partially offset the benefits of YOM reduction). 

19 
Electronic Filing -Received, Clerk's Office, 08/10/2011 

2. Cross-Media Environmental Impacts Resulting from an Adjusted 

Standard. 

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

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

anticipated. 

H. Justification- Section I 04.406(h) 

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

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

TI!inois Environmental Protection Act, 415 ILCS 5/28.l(c), authorizes the Board to grant an 

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

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

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

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

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

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

federal law. 

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

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

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

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

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

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

limiting the amount of QC test fluid sprayed into each drum is substantially and significantly 

different from factors the Board may have relied on in deciding to require capture and control 

20 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

methods for managing YOM emissions. Third, even if Greif could not manage YOM emissions 

by dilution of the QC test fluid, the physical design of Greifs operations and the slowevaporation of its QC test fluid are unique factors impacting and significantly limiting Greifs 

ability to capture and control YOM emissions through add-on controls. Fourth, the costs to 

achieve the 81 percent capture and control requirement of Section 218.986(a) would exceed the 

threshold cost level the Board previously has found to be economically reasonable. 

a. The Board Did Not Consider Jlactors Involving the Drum 

Manufacturing Business in Adopting Subpart TT. 

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

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

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

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

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

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

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

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

Op. at 5. 

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

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

Chicago assembly plant /d. Slip Op. at 1. The Board stated that Subpart TT applies to YOM 

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

adopting Subpart TT, 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 
Electronic Filing- 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 

of its OC Test Fluid and Limitations on the Amount of QC 

Test Fluid Used Constitute Substantially and Significantly 

Different Factors. 

Even if the Board had considered factors impacting the capture and control ofVOM 

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

Greif's unique QC Test Process, the particular complexity of constructing capture equipment 

over an extended conveyor line or the ability to manage VOM emissions by diluting the QC test 

fluid with water and limiting the amount of QC test fluid applied to each drum. Construction of 

effective capture equipment is further complicated by the need to maintain physical access to the 

drums for visual inspection. This means the conveyor line cannot be totally enclosed to 

maximize capture. These factors are substantially and significantly different from emission units 

where material substitution is not possible and the construction and operation of emission 

capture equipment is less extensive. 

c. Greif's QC Test Process is Substantially and Significantly 

Different from Other Manufacturing Activities Considered by 

the Board. 

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

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

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

fluid and the need for Greif to inspect 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 area to 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 by plant staff, 

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

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

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

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

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

the Board in adopting Subpart TT and will significantly impact Greifs costs to control YOM 

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

d. Costs of Achieving RACT Control Standard Exceed those 

Considered by Board in Setting RACT Standard. 

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

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

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

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

of' Petition ofFormel Industries, Inc./or an Adjusted Standard from 35 Ill. 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 of YOM reduced were 

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

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

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

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

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

an Adjusted Standard from 35 lAC 218.980, AS 91-8 (Sept. 21, 1995) (Board found $40,000 per 

ton of YOM reduced to be economically unreasonable). 

23 
Electronic Filing -Received, Clerk's Office, 08/10/2011 

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

The intent of the regulations promulgated under 3 5 TIL Adm. Code Part 218 is to 

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

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

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

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

emissions from the QC Test Process below the applicability threshold for Subpart 'I"fl and below 

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

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

3. The Requested Standard Will Not Result in Adverse Health Effects. 

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

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

Illinois Annual Air Report at Table C-5 (2010 emission data was not available at the time Greif 

filed its Amended Petition). Thus, even at the maximum permitted emission levels for the 

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

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

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

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

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

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

3 Greifunderntands th~t Subpart IT is a "once in-always in" rule. 35 lll. Adm. Code Section 218.980( c). However, 

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

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

subject to Subpart IT. 

24 
Electronic Filing- Received, Clerk's Office, 08/10/2011 

The Board has granted numerous exemptions to the 81 percent capture and control 

requirement in Subpart TT in cases where the annual VOM emissions that were exempted from 

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

Motor Co. (2000), AS 00-6, Slip. Op. at 3 (even with uncontrolled emissions of 390 tpy of 

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

Chemical Corporation, AS 92-14, Slip. Op. at I 0 (Board agreed that operation of emission 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 of 76 tpy from 

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

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

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

(2002), AS 02-3, Slip. Op. at 4. In Ford, 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 air quality." I d. Here, dilution of the QC test fluid and limitation on the amount of 

QC test fluid used per drum is producing roughly a 70% reduction ofVOM emissions- an even 

greater reduction on a percentage basis than what was at issue in the Ford petition. 

4. The Requested Standard is Consistent with Federal Law. 

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

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

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

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

Clean Air Act. A state may revise its SIP, again subject to USEPA approval. 42 U.S.C. § 7410. 

25 
Electronic Filing - Received, Clerk's Office, 08/1 0/2011 

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

adjusted standard granted by the Board. 

J. Hearing- Section 1 04.406(j) 

Greif requests a hearing in this matter. 

K. Supporting Documentation- Section 1 04.406(k) 

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

2. FOIA Response from Illinois Environmental Protection Agency, Bureau 

of Air, attached to this Petition as Exhibit B. 

III. CONCLUSION 

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

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

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

economic hardship to Greif with no corresponding environmental benefit. Certait1 compliance 

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

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

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

health and safety risks. 

26 
Electronic Filing -Received, Clerk's Office, 08/ 10/2011 

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

standard from 35 lll. Adm. Code, Subpart IT, Section 218.986(a), as that rule applies to the 

emissions of VOM from Greif Packaging LLC's operations in Naperville, Illinois. 

Respectfully submitted, 

GREIF, INC. AND 

GREIF PACKAGING LLC 

By: /s/ Susan Charles 

Thomas W. Dimond 

Sus an Chari es 

ICE MILLER LLP 

200 West Madison Street 

Chicago, illinois 60606 

312-726-1567 

August 1 0, 2011 

27 
Electronic Filing - Received, Clerk's Office, 08/30/2011 

I EPA 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 ILL ADM. 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 of Legal Counsel 

Illinois Environmental Protection Agency 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

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

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

FILING, PROOF OF PETITION NOTICE REQUIREMENTS and CERTIFICATE OF 

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

Date: August 30, 2011 

Thomas W. Dimond 

Susan Charles 

ICE MILLER LLP 

200 West Madison Street 

Suite 3500 

Chicago, lllinois 60606 

Respectfully submitted, 

GREIF, INC. and GREIF PACKAGING, LLC 

By: /s/ Susan Charles 

One of its Attorneys 

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

BEFORE 111E ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER 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 lll. Adm. Code Sections 104.408 and 104.410, on August 12,2011, 

petitioners Greif, Inc_ and Greif Packaging, LLC ("Greif'') published notice of the filing of their 

Second Amended Petition for an Adjusted Standard ("Petition") by advertisement in a newspaper 

of general circulation in the area of Greif's Naperville plant. In support of this filing Greif states 

the following: 

1. Greif filed the Petition with the Clerk of the lllinois Pollution Control Board on 

August 10, 2011. 

2. Pursuant to the Petition, Greif seeks an adjusted standard from 35 lll. Adm. Code 

§ 218.986(a) as it applies to control requirements for emissions of volatile organic material at 

Greif's fiber drum manufacturing facility located in Naperville, Illinois. 

3. On August 12,2011, Greif published notice of the filing of the Petition by 

advertisement in the Naperville Sun, a newspaper of general circulation in Naperville, lllinois. 

4. As required by 35 Ill. Adm. Code Section 104.408(a), Greif published notice of 

the filing of the Petition within 14 days after it filed the Petition. 

5. The notice includes the specific language required by 35 Ill. Adm_ Code Section 

I 04.408(b )-

1 
Electronic Filing -Received, Clerk's Office, 08/30/2011 

6. As required by 35 Ill. Adm. Code Section I 04.410, a certificate of publication 

issued by the publisher of the Naperville Sun certifying publication ofthe notice on August 12, 

2011 is attached as Exhibit 1. The certificate of publication attaches Greif's notice as it appeared 

in the Naperville Sun and states that the Naperville Sun satisfies the requirements of the Illinois 

Notice by Publication Act, 715 ILCS 5/0.01, et seq. The language included in Grief's notice is 

consistent with 35 Ill. Adm. Code Section 104.408(b). 

WHEREFORE, for the reasons stated above, Greif has satisfied the requirements for 

providing notice of the filing of its Second Amended Petition for an Adjusted Standard and for 

filing proof of such notice with the Illinois Pollution Control Board. 

Date: August 30, 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: !sf Susan Charles 

One of its Attorneys 

2 
Public Notices Public Notices 

Not!Cl);or Second Amonded Petltlo~~d Gn:ll · · .·~;ta~kaglng U.C tor an Adjusted '!/:1'0/HC 1 - . . the Illinois Polwtkm c • On Augus110, 2011, Groll, Inc. and Grolf Packaging LlC (Grell) 

I filed 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 

1 emlss!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 a danatured 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· 

I 

ess, 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 per culendar quortcr by the following procedure. · a. Weigh a. plasfc bag 011 a gram scalo to da$ermlne the wei!tlt 

of the bag.· b • .Piaoe the l)lastic bEiil over the spray head of ihe wand of the 

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 stops n. throu{tl d. for !Iva ~es of tho 0C Test 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 of ac test fluid per drum. 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 by the 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 Facility will: . 

a. Ftooord tho volume Of d91)alumd a/00001 hGfd as lrwentory oo 

ttm first and ~a~Js ot eactl montl't 

b. Melntaln s of tho volume Of dr:naturl!'d a1cohol recei\led at the FaciAty during cnch montll. c. The YOilino- 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 

iwontoty on tho last day 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 Into Its QC Test Procoss provided that the lower VOM QC test fk.lids l'llloW visual delecdon ot pill· 

hole!l or other tea!"B or lrnporfocHons In tho wum linings wilhfn an accoptable period ot time and doGs not result In any n~nfiVC 

prodwt QUO:Hty li'nJKlo1$, . 7. The propoSed a~usk!:i standard will nolalfact tho catcul£tion of Grelfs potential EmiSsions Redlctlon Merkel Systam-

("ERMS") btJSallne or Its 'ERMS _e!lolmcnt If Greif's NapeM!Ie plenlshould part!clpato Jn the EAMS prorgram. · 

. 8. Environmental sli!fl of Grell's paron! 'l'o'in cortduct a fonniJitraln1 

lng 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~­

. oood the 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«i on the maximum millorlal usage and tha 1 tMxlmum 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 of data. 

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 00 test flu- Id and rod.Jclna the quarrtlty used per drvm, and the eng\leerlng 

Complexities tF ocnstrucllnQ capture eqlit>menl aver an 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) the cost; of IXli'TIPivi~ with Sectloo 218.986(&) ro:t:eed 1hose ccn- 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 of Publication 

State oflllinois- County of Ocook 0 Kane 0Lake 0 McHenry 

~DuPage D Will D DeKalb D Kendall 0 Grundy 

Sun-Times Media, does hereby certify it has published the attached advertisements in the 

following secular newspapers. All newspapers meet lllinois Compiled Statue requirements for 

publication of Notices per Chapter 715 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 The Beacon News 0 The Courier News 

0 The Herald News 0 The Lake County News-Sun 

~The Naperville Sun 0 The SouthTownStar 

0 The Chicago Sun-Times 0 Pioneer Press/The Doings 

0 Job Posting on Monster.com 

m WITNESS WHEREOF, the undersigned, being duly authorized, has caused this Certificate 

to be signed and its official seal affixed at Aurora, lllinois 

David Fontechin 

OFRC\Al SEAL 

CATHERINE A CYNCAR 

NOTAIW PUBUC, STATE OF IWNOtS 

KANE COUNTY 

MY COMMISSION EXPIRES 11/1:9/2014 

Public Legal Notices Account Executive 

Subscnbed and sworn to before me this ..),. '? Day of -h- A. D. eJ {) /J 

By· 

~d:bl~ EXHIBIT 1 
Electronic Filing -Received, Clerk's Office, 08/30/2011 

CERTfFICATE OF SERVICE 

I, the undersigned, certify that on this 30th day of August, 2011, I have served 

electronically the attached NOTICE 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 of Legal Counsel 

lllinois Environmental Protection Agency 

I 021 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 

I 00 W. Randolph St., Suite 1 I -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 TAKE NOTICE that I have today filed with the Office of the Pollution Control Board 

the RECOMMENDATION of the Illinois Environmental Protection Agency a copy of which is 

herewith served upon you. 

DATED: October II, 2011 

I 021 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 of Legal Counsel 

THIS FILING IS SUBMITTED 

ON RECYCLED PAPER 

·-
Electronic Filing- 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 of the Illinois 

Pollution Control Board ("Board") at 35 Ill. Adm. Code 104.416. The Illinois EPA recommends 

that the Board GRANT the Second Amended Petition of Greif, Inc., and Greif Packaging, 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. Greif operates 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. I d. Some drums 

require the addition of a polyethylene liner due to customer specifications, such as when the 

drum is needed for storage of food-grade products. !d. The quality control ("QC") system in 

Greifs plant involves testing the liners of drums by spraying a test fluid into the interior of the 
Electronic Filing- 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, Greif uses an automated 

system to spray the interior of the drum liners with QC test fluid. I d. 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. If no pinholes are present, the drum moves along to the drying oven where remaining 

fluid is evaporated. !d. YOM is emitted throughout the quality control check and in the drying 

oven. ld. 

3. Greif states that 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. Greif asserts that it 

calculates the volume of denatured alcohol held as inventory on both the first and last days of the 

month. I d. Greif notes that it also tracks the volume of denatured alcohol purchased within each 

month. !d. The difference in volume "is then multiplied by the YOM content (in pounds per gal) 

of the denatured alcohol to compute the mass (in pounds) of YOM emitted during the month." 

I d. 

4. The Naperv.ille plant is subject to a Federally Enforceable State Operating Permit 

("FESOP") (No. 9707044). Condition three of the FESOP limits YOM emissions ofGreifs QC 

test process to 22.8 tons per year. !d. This condition also limits the YOM emissions from the 

remainder of the plant to 1.4 tons per year. !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") of any single HAP or 

25 tpy for any combination of HAPs. Jd. at 3. Greif reported 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 of the FESOP, relating to YOM emissions. Greif 

asserts that the QC test process had emissions in 2006, 2007, 2008, 2009 and 2010 of 35.2, 46.7, 

19.1, 7.7 and 8.95 tons, respectively. I d. These years of high emissions are the subject ofthe 

Illinois EPA's Violation Notice, A 2007-00132. ld. After reviewing the matter, the Illinois EPA 

agreed that Greif would make changes to the process, as noted elsewhere in this document, and 

file a Petition for an Adjusted Standard to resolve the alleged violations. 

5. Greif filed its Petition for Adjusted Standard on January 27,2011, pursuant to Section 

28.1 of the 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. Greif properly filed a Proof of Publication ofNotice with the Board for each of these 

Petitions, stating that the various notices appeared in the Naperville Sun on January 27, June I 0, 

and August 12,2011. 

7. Pursuant to 35 III. Adm. Code Section I 04.416, the Illinois EPA is required to file a 

response to a Petition for Adjusted Standard within 45 days of filing. 

8. However, as a result of ongoing discussions, Greif filed 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 

I 0. The Second Amended Petition requests that the Board grant Greif an adjusted standard 

from 35 Ill. Adm. Code 218.986(a). This subsection states: 

Section 218.986 Control Requirements 

Every owner or operator of an emission unit subject to this Subpart shall comply 

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

a) Emission capture and control equipment which achieves an overall 

reduction in uncontrolled YOM emissions of at least 81 percent 

from each emission unit, or (Board Note: For the purpose of this 

provision, an emission unit is any part or activity at a source of a 

type that by itself is subject to control requirements in other 

Subparts of this Part or 40 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, or is otherwise any part 

or activity at a source.) 

*** 

II. During the years 2006 and 2007, the Illinois EPA alleges Greif became subject to the 81 

percent capture and control requirements of Subpart TT. ld. Section 218.986 (a) to (c) are part 

of Subpart TT which is a "once in-always in" regulation, which is why Greif is still subject to the 

provision despite reducing its plant-wide emissions to a level below the applicability threshold. 
Electronic Filing -Received, Clerk's Office, 10/11/2011 

STANDARD OF REVIEW 

12. Section 28.1 of the Act states that the Board may grant individual adjusted standards from 

rules of general applicability whenever the Board detennines that an applicant can justify an 

adjustment. In adopting a rule of general applicability, the Board may specify the level of 

justification required of a petitioner for an adjusted standard. If a rule of general applicability 

. does not contain a level of justification that the petitioner must meet to obtain an adjusted 

standard, the requirements of Section 28.1 (c) of the 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 of those factors justifies an adjusted standard; 

(3) The requested standard will not result in environmental or health effects 

substantially and sufficiently more adverse than the effects considered by the 

Board in adopting the rule of general applicability; and 

(4) The adjusted standard is consistent with any applicable federal law. 

13. The regulation of general applicability from which Greif seeks an adjusted standard, 35 

Ill. Adm. Code 218.986(a), does not specify a level of justification that Greif must satisfy to 

obtain an adjusted standard. Therefore, Greif must satisfy the level of justification set forth in 

Section 28.1 (c) of the Act. As summarized below, the requested adjusted standard for Greifs 

drum manufacturing operations presents facts sufficiently different from Subpart TT which the 

Agency agrees justifies the Adjusted Standard . 

COMPLIANCE ALTERNATIVES 

14. Greif asserts in its Second Amended Petition that its operations were not contemplated 
Electronic Filing -Received, Clerk's Office, 10/11/2011 

by the Board when it passed Subpart TT, Section 21 8.986(a). Greif completed a Reasonably 

Available Control Technology ("RACT") study in August 20 I 0, revised March 20 II, to evaluate 

compliance alternatives to meet the Section 218.986(a) requirement to reduce VOM emissions by 

81%. I d. at 4. Greif states that one complicating factor for any capture system is that a tunnel 

enclosure would be needed for the entire length of the QC process. !d. at I 0. The QC process is 

long, and completed at several points in the factory. !d. As Greif must have access to the drums 

for inspection, the tunnel system would be more complex than a normal system. I d. Greif 

asserts the RACT study compared three capture and control systems: capture plus recuperative 

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

substitutions. I d. That is, a capture system is assumed for all add-on control technologies. !d. 

15. Concerning the three add-on control options, recuperative thermal oxidizers, carbon 

adsorbers, and biofilters and material substitutions, Greif asserts that all will be prohibitively 

expensive. !d. at I 0- I I. In addition, some will "have potentially harmful safety impacts." !d. 

A recuperative thermal incinerator requires large amounts of natural gas for fuel and according to 

Greif, "[f]requent operation cycles in thermal oxiders cause condensation corrosion and thermal 

deterioration of the insulation which requires ongoing maintenance costs." !d. at I I. Carbon 

adsorbers use two or more beds of activated charcoal with one treating emissions while the other 

is regenerating. Jd. at I 2. Greif states 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 of the 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. Biofi lters and material substitution presents its own set of problems. First, Greif asserts 

that a biofilter proposed to be installed at another Greif facility would only reduce YOM 

emissions by 70%. Thus either another technology must also be used or "the reductions in YOM 

emissions from the use of the 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 of electricity, natural gas or steam. I d. 

17. Greif also 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. I d. at 14. 

Water was then tested to see if diluting the QC fluid with water would work. Jd. Varying 

combinations of QC fluid and water were tested. I d. Greif asserts that the maximum amount of 

water that allowed Greifs employees to properly check the quality of the drums was a dilution of 

55% water, 45% QC fluid. I d. at 15. Greif then tested to see if the amount of diluted QC fluid 

could be reduced. Based on testing, Greif determined that at least 48 grams of test fluid can be 

used during the QC process. Jd. 

ENVIRONMENTAL IMPACT 

18. Greif asserts that the granting of the petition will have minimal impact on air quality. !d. at 

18. Greif states that even at the highest emissions level allowed Greif by its FESOP, emissions from 

the QC process would only equal 0.04% of the state-wide point source emissions. ld. at 19. It 

should be noted that the Agency does not accept this argument on its face, as almost any individual 

source could make the same claim, and it is the aggregate of sources in the area that causes ozone 
Electronic Filing- Received, Clerk's Office, 10/11/2011 

nonattainment. However, the technical factors in this instance and the emission reductions Greif has 

already made offset the Agency's concern in this regard. 

19. Greif then 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 of the 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 of air 

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 of the Clean Air Act. If the 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 Greif have discussed thisproposed adjusted standard with USEPA, and USEPA has 

provided comments. 

PROPOSED ADJUSTED STANDARD 

22. Greif has requested an Adjusted Standard from the Board's air pollution control 
Electronic Filing- 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 Greif to operate its facility subject to the following conditions: 

I. The proposed adjusted standard applies to the emission of YOM 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 of the fiber drums are lined with polyethylene to meet customer 

specifications, particularly for storage and transport of food-grade products. Lined drums must 

be tested to ensure the integrity of the polyethylene lining. That testing is performed at the QC 

Test Process, which consists of the 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 spray releases 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 of the 

drum is visually inspected for pinholes. 

c. The drum next is conveyed to a drying oven where most of the 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 of no 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 equipment to spray an average of no 

more than 48 grams of QC 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 of the bag. 

b. Place the plastic bag over the spray head of the wand of the QC Test Process and 

secure it in place with a rubber band or binder clip. 

c. Cycle the QC Test Process by passing a drum through the process in the normal 

manner of operation with the plastic bag capturing the QC test fluid. Remove the 

plastic bag from the spray head of the wand of the QC Test Process and weigh it on the 

same gram scale used in step a. 

d. Calculate the weight of QC 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 of the QC Test Process. Calculate the average 

weight of QC test fluid sprayed per cycle and compare that average to the standard of 

an average of no more thim 48 grams of QC 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 of entry 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 of being 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 of a source inspection. 

5. The Facility will maintain records of its QC test fluid usage that will allow the monthly 

calculation of the amount of QC test fluid used during the month and the calculation of YOM 

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 of QC test fluid held as inventory on the first and last day of each 

month. 

b. Maintain records of the volume ofQC test fluid received at the Facility during each 

month. 

c. The volume of QC test fluid used for a month shall equal the inventory volume on the 

first day of the month plus the volume received at the Facility during the month, less 

the volume in inventory on the last day of the month. 

d. The volume used during a month calculated in step c shall be multiplied by the YOM 

content of the QC test fluid (in pounds per unit of volume) to compute the weight (in 

pounds) of YOM emitted during the month. 

e. Using the emissions of YOM in pounds calculated for each month in step d, the 

Facility will compute the 12-month roUing YOM emissions for the QC Test Process 

and report those results to Facility management. 

6. Greif will continue to investigate the availability of alternative QC test fluids with lower YOM 

content. Greif will incorporate such lower YOM QC test fluids into its automated QC Test 

Process provided that the lower YOM QC test fluids allow visual detection of pinholes 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 of Greifs potential Emissions 

Reduction Market System (''ERMS") baseline or its ERMS allotment if Greifs Naperville plant 

should participate in the ERMS program. 

8. Environmental staff of Greifs parent company will conduct a formal training session for 

Naperville facility personnel on the requirements of the FESOP and the internal procedures for 

tracking compliance with FESOP conditions. 
Electronic Filing- Received, Clerk's Office, 10/11/2011 

9. Emissions and operation of the 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 of data. 

23. Although the Illinois EPA believes that the alternative compliance methods and add-on 

options investigated by Greif have costs which are not RACT, the Illinois EPA strongly disputes 

Greifs definition ofRACT. The Petitioner relics upon the case of In re: Petition of Louis 

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

53, 72 I N.E.2d 723, 726-27 & 731 (2"d Dist. 1999) for the proposition that costs exceeding 

$1,734 (in 1996 dollars) per ton of reductions were economically unreasonable. In addition, in 

its RACT study, Greif goes so far as to say that the "Board's RACT cost threshold was a 

maximum of $1,734 per ton of VOM controlled" (I 996 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. I d. It is also worth pointing 

out that 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 of various miscellaneous metal parts and products coating 

facilities cases. !d. at 10-11. It is not clear if the figure should be used to calculate RACTfor 

every category of sources. 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 per ton in 1980 dollars and was for 

facilities located in attainment areas. Berkman, 10. Greif is 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 RACT II Rules, Chapter 2, Air Pollution, R80-5, Proposed Opinion for 

Second Notice of October 5, 1982, at 19; adopted as the Final Opinion in the order of December 

30, 1982. This figure has not been updated to 1996, let alone 2011, dollars, and the cost of 

RACT has continued to 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 of the 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 at each plant guide the Board in determining RACT. In addition, Subpart TI is 

different from the regulations at issue in the other cases cited. The particulars of each regulation 

help to determine RACT. The Illinois EPA believes that Greif qualifies for an adjusted standard 

based upon its calculation of RACT, but it is the RACT for 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 of each RACT decision. 
Electronic Filing- Received, Clerk's Office, 10/11/2011 

HEARING 

27. Greif has 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 I I, 201 I 

I 020 North Grand Avenue East 

P.O. Box 19276 

Springfield, Illinois 627949276 

(2I 7)782-5544 

(217)782-9807 Facsimile 

Respectfully submitted, 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY 

By:ls/ Charles E Matoesian 

Charles E. Matoesian 

Assistant Counsel 

Division of Legal Counsel 
Electronic Filing- Received, Clerk's Office, 10/11/2011 

STATE OF ILLINOIS 

COUNTY OF SAN GAM ON 

) 

) 

) 

ss 

CERTIFICATE OF SERVICE 

I, the undersigned, an attorney, state that I have served electronically the attached, 

RECOMMENDA TJON upon the following persons: 

John Therriault, Acting Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

I 00 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 

I 021 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 of Legal Counsel 
Electronic Filing- Received, Clerk's Office, 11/01/2011 I~ IEPA ATTACHMENT NO._ 

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER 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 of Legal Counsel 

Illinois Environmental Protection Agency 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

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

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

FILING, SUBMISSION OF AIR QUALITY IMPACT ANALYSIS and CERTIFICATE 

OF SERVICE, copies of which are attached herewith and served upon 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 of its Attorneys 

I 
Electronic Filing- 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 

FOR AN ADJUSTED STANDARD FROM 

35 ILL ADM. CODE PART 218 

SUBPART IT 

) 

) 

) 

) 

) 

) 

) 

AS2011-00I 

(Adjusted Standard- Air) 

SUBMISSION OF AIR QUALITY IMPACT ANALYSIS 

Pursuant to the March 21,2011 Hearing Officer Order ("Order"), petitioners Greif, Inc. 

and Greif Packaging, LLC ("Greif'') hereby submit the attached "Final Air Quality Impact 

Analysis of the VOC Emissions from the Greif Packaging Facility in Naperville, Illinois, Using 

the Scheffe Tables." In support of this filing Greif states the following: 

I. The Order directed Greif to provide an Ambient Air Quality Impact Analysis 

("Air Quality Analysis") for ozone as part of its Petition for Adjusted Standard. The Order 

provides that Air Quality Analysis would be used by the Illinois Pollution Control Board in 

evaluating whether the proposed adjusted standard will "cause or contribute to violations of the 

[National Ambient Air Quality Standards ("NAAQS"] for ozone or delay efforts to attain the 

NAAQS in a timely manner." The Order further directed Grief to "consult with the [Illinois 

Pollution Control Agency ("Agency")] as to the necessary elements Greif should 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. Greifhas presented 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 Grief that 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, Greif has satisfied the requirement of the 

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 of its Attorneys 

2 
Electronic Filing- Received, Clerk's Office, 11/01/2011 

CERTIFICATE OF SERVICE 

I, the undersigned, certify that on this I st 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 of Legal Counsel 

Illinois Environmental Protection Agency 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

Is/ Susan Charles 

Susan Charles 

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

August II, 2011 

Mr. Scott S. Mounts P .E. 

.EHS Manager- Notih America 

Greif Inc. 

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 Impact Analysis of the VOC 

Emissions from the Greifpackaging Facility in Naperville, IJlinois Using tlte Scheffe Tables" is 

attached. 

If you have any questions concerning this report, please call me at (630) 699-7665. 

Sincerely, 

Thomas C. Ponder, Jr. PE 

EXHIBIT 1 

Telephone 630-699-7665 email: alponder@comcast.net 
Electronic Filing- Received, Clerk's Office, 11/01/2011 

Air Quality hnpact Analysis of the VOC 

Emissions from the Greif Packaging Facility in Naperville, Illinois 

Using the Scheffe Tables 

Prepared by 

Thomas C. Ponder, Jr. PE 

The most recent three years of highest values for 1-hour ambient ozone data and 8-hour average 

ambient ozone data (in palis per billion or ppb) for the monitoring station located in Lisle in Du 

Page County is shown below. The Lisle station data was chosen for this analysis because it is 

the monitoring station closest to the Greif Packaging Naperville facility. These data were 

obtained from Table B-2 in the lllinois Annual Air Quality Reports for each of2007, 2008 and 

2009. These are the three most recent years for which Illinois has published the information in 

an Annual Air Quality Report. 

Highest 1-hour Ambient Ozone Measurements 

Year ~ 2nd 3rd 4th 

2009 70 67 66 66 

2008 77 70 66 66 

2007 99 86 81 80 

Highest 8-hour Average 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-hour ozone 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 of the 

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 

over the past three 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 of the 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 for the Naperville facility. Scheffe 1988 

is a screening tool that is intended to allow a simplified calculation of estimated 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 of volatile 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) if the facility had 50 TPY of NMOC 

emissions. This is based on the Table 2 value of 50 TPY NMOC under the 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-hour ambient ozone measurement to 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 for the 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 of the baseline 

measurement does not matter. Whether one uses the highest of the fourth highest 

measurements at the Lisle station over the last 3 years (80 ppb) or simply the highest 

ozone concentration measured over those same 3 years (99 ppb ), adding the 

conservative increment estimate for the Naperville facility would not result in any 

exceedances of the 120 ppb 1-hour standard at that monitoring station. 

Accordingly, the proposed adjusted standard should not interfere with Illinois' ability to 

attain the 1-hour ozone NAAQS. 

8-hour Average 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 of the 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 of Air Quality Goals for Ozone, PM2.5 and 

Regional Haze (EPA April 2007). 

The baseline 8-hour average ozone concentration is the average of the 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 ( 1.4 7 

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' ability to 

attain the 8-hour average ozone NAAQS. 

3 
ILLINOIS POLLUTION CONTROL BOARD 

November 8, 2011 

IN THE MATTER OF: ) 

RECEIVED If CLE~OFFICE M ATTACHMENT NO 

NOV- 8 2011 ·-

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 OF HEARING 

A hearing in the above-captioned matter is scheduled at the following date, time, and 

IT IS SO ORDERED. 

December 20, 2011 

J:OOp.m. 

James R. Thompson Center 

Room 11-512 

100 West Randolph Street 

Chicago, lllinois 60601 

Bradley P. Halloran 

Hearing Officer 

lllinois Pollution Control Board 

James R. Thompson Center, Suite 11-500 

100 W. Randolph Street 

Chicago, lllinois 6060 I 

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. of the- 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 3 I ~/S14-61).n. fh ~·Jay<., pril\J' to thchearing. 
2 

CERTIFICATE OF SERVICE 

It is hereby certified that true copies of the foregoing order were mailed, first class, on 

November 8, 2011, to each of the persons on the service list below. 

It is hereby certified that a true copy of the foregoing order was hand delivered to the 

following on November 8, 20 II: 

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 Control Board 

James R. Thompson Center 

100 W. Randolph Street, Suite 11-500 

Chicago, illinois 6060 I 

312.814-8917 

SERVICE LIST 

AS 2011-001 

Division of Legal Counsel 

!EPA 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, n.. 62794-9276 

AS 2011-001 

Thomas W. Dimond 

Ice Miller LLP 

200 W. Madison 

Suite 3500 

Chicago, n.. 60606 

AS 2011-001 

Susan Charles 

Ice Miller LLP 

200 W. Madison 

Suite 3500 

Chicago, n.. 60606 
~ 

R~NO._ 

ILLINOIS POllUTION CONTROL BOARD 

November 8,. 2011 

NOV -8 2011 

STATE OF IWNOIS 

FGIIUIIon eootrol Boiilftl 

IN THE MA ITER OF: 

PETITION OF GREIF PACKAGING, 

llC FOR AN ADJUSTED STANDARD 

FROM 35 ILL. ADM. CODE 218 

SUBPART IT 

) 

) 

) 

) 

) 

) 

• 

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. The time and location of the hearing will be noted in the notice of hearing. 

The hearing officer directs the petitioner to address the pre-hearing question attached to 

this order. A written response must be filed 10 days before the hearing. 

The parties or their legal representatives are directed to appear at a telephonic status 

conference with the hearing officer on December I, 2011, at 11:00 a.m. The telephonic status 

conference must be initiated by the petitioner, but each party is nonetheless responsible for its 

own appearance. At the conference, the parties must be prepared to discuss the status of the 

above-captioned matter and their readiness for hearing. 

IT IS SO ORDERED. 

Bradley P. Halloran 

Hearing Officer 

lllinois Pollution Control Board 

James R. Thompson Center, Suite 11-500 

100 West Randolph 

Chicago, lllinois 60601 

312.814.8917 
AS 11-1 GREIF PACKAGING, LLC 

HEARING QUESTIONS FOR PETITIONER AND IEPA 

35 lAC 1 04.406(g) 

On November 1, 2011, Greif Packaging submitted its "Final Air Quality Impact Analysis of the 

YOC Emissions from the Greif Packaging Facility 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 of YOC Emissions for the Air Quality Impact 

Page 2 of Greif's Analysis explains that the 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 ... " (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 emissions from the QC test process at the 

Greif Naperville facility 

reduction rate actually achieved during 2009 and 2010 for the 

adjusted standard ' 

reduction rate required by Subpart IT 

Based on a review of the information provided, it appears that the differential could be 

calculated as follows, producing a result that is closer to 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)] = YOM emissions based on the Subpart TT reductions 

• Would you please clarify the differential YOM emissions to be used to compute the air 

quality impact? 

B. Application of the Scheffe Tables 

1 
The Air Quality Impact Analysis relies on the "VOC/NOx Point Source Screening Tables" 

by Richard D. Scheffe, September 1988 (Scheffe Method). 1 Page 7 of the Scheffe Method 

·lists three steps for determining an ozone increment for the screening estimate: 

1- Determine which column of the screening tables is applicable. Greif's Analysis relied 

on the ''Table 2. Urban based ozone increment (pphm) as a function of NMOC 

[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.) 

If the 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 tpy from 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- Interpolate linearly to produce an interpolated ozone increment. Page 2 of Greif's 

Analysis used linear interpolation to calculate an ozone increment of 1.47 ppb associated 

with the increase of 6.7 NMOC tpy by using the"> 20.7" column of the Scheffe Table 2 

and the following equation: 

(1.1 pphrn * O.Dl pphm/ppb )*(6.7 tpy I 50 tpy) = 1.47 ppb 

Consistent with the Scheffe method, it appears the linear interpolation could be calculated 

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 Table 2, demonstrating that each column has a different 

slope. 

1 http://ndep.nv.gov/bapc/oermitting/downloadlmodel!scheffe.doc 

2 
Table 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 

I 110 -~--' 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.Ox 
The ex:ample on page 9 of the Scheffe Method linearly interpolates the ozone increment 

from the two closet points as graphed from Table 2. However, Grief's emissions 

differential is lower than the lowest point in the table or on the graph. The Scheffe Table 

2 and the resulting graph do not go to zero for either the NMOC emissions or the ozone 

increment, but a 0 pphm ozone increment would correspond to a 0 tpy NMOC emission. 

Therefore, for the purposes of a linear interpolation, the two closet points to the 1.8 tpy 

revised value above would be 0 and 50 NMOC Emissions, with an ozone increment 

between 0 and 1.1 pphm under the "5.2 - 20.7" column. 

Based on this, the following equation could be 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 associated with NMOC emissions) 

y 3 = 1.1 

XJ = 0 

X 2 = 1.8 

x,= 50 

{[(1.8-0)(1.1-0)]/ (50-0)} + 0 = 0.0396 pphm 

0.0396 pphrn * 0.01 = 0.000396 ppm 

0.000396 ppm * 1000 ppb I ppm= 0.396 ppb 

It appears that the ozone increment associated with an increase of 1.8 tpy differential 

·could be closer to 0.396 ppb rather than the 1.47 ppb that Greif associated with an 

increase of 6.47 tpy in its Analysis. 

• Would you please clarify your analysis of the ozone increment? 

C. Impact on Illinois Ability to Attain the 1-hour and 8-hour Ozone NAAQS 

Pages 2 and 3 of the analysis conclude that adding 1.47 ppb to the highest of the fourth 

highest ozone measurements would not result in any ex:ceedances of the 120 ppb !-hour 

standard or 75 ppb 8-hour average ozone national Ambient Air Quality Standards (NAAQS). 

4 
• Based on your comments regarding the revised calculations postulated above, would 

you please restate whether the impact of Greif's proposed adjusted standard would 

cause or contribute to violations of the NAAQS for ozone or delay efforts to attain the 

NAAQS in a timely manner? 

5 
6 

CERTIFICATE OF SERVICE 

It is hereby certified that true copies of the foregoing order were mailed, first class, on 

November 8, 2011, to each of the persons on the service list below. 

It is hereby certified that a true copy of the 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,_- \ 

Bradley P. Halloran 

Hearing Officer 

Illinois Pollution Control Board 

James R. Thompson Center 

100 W. Randolph Street, Suite 11-500 

Chicago, lllinois 60601 

312.814-8917 

SERVICE LIST 

AS 2011-001 

Division of Legal Counsel 

!EPA 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, n.. 62794-9276 

AS 2011-001 

Thomas W. Dimond 

Ice Miller LLP 

200 W. Madison 

Suite 3500 

Chicago, n.. 60606 

AS 2011-001 

Susan Charles 

Ice Miller LLP 

200 W. Madison 

Suite 3500 

Chicago, n.. 60606 
POLLUTION CONTROL BOARD, ILLINOIS 

Pub Hrg 1212012011 

AOOROERNUMBER: 0000176522-01 

PO NUMBER: Pub Hrg 1212012011 

AMOUNT: $26.4° 

NO OF AFFIDAVITS: 

POLLUTION CONTROL BOARD, ILLINOIS 

100 W RANDOLPH ST 11-500 

DON BROWN 

CHICAGO, IL 60601-3218 

13 Sun Times Media 

Sun-Times Media West 

Certificate of Publication 

I EPA ATTACHMENT NO.-

State of Illinois- 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 

~:;:;;z;:z ... _., .. ~ 

No " . 

OFFICIAL SEAL 

TAMMY ALBANOS 

NOTARY PUBLIC, STA1t OF IWNOIS 

MY COMMISSION EXPIRES 2-22-2015 
iEPA ATTACHMENT ~i__ 

Page 1 

ILLINOIS POL.LUTION CONTROL BOARD 

IN THE MATTER OF: 

) 

PETITION OF GREIF No. AS 11-1 l 

PACKAGING, LLC, FOR AN ) (Adjusted Standard - ~ 

ADJUSTED STANDARD FROM A' ) '"--_!"'";: "'Ji ~ ..,, ~-;-;-~ ·~ u 'V r:! D 

1. r C'ti~i4f<'~ OFFICE 

35 ILL. ADM. CODE 218 JAN 0 5 2012 

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 .............,. ....... ,.,.-"-_ ,_......,..."""-"' ,..,., . ....,..,.-==~~..,._,.-- ..... ~ .............. """"""' ........ .....-......-......,.,. ..... .:.=;,., .............,.,., •• .,.--...... ... ~ ......... -·~ 
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 a 
Page 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? 
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(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 Amended 
Page 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 , 

; 

; ' ' ~ ...... --...... ,""_.... .. -~"~ ... -~..,.,., ....... ..__,"',....,.,..,, . .........,..,... .., ........... ........,..,_,._, .. "'""'"'"'.,"·'·~----.............. ..,""""'-" ... =-:.>.~.,.,, _,..,.__,,...,_.....,,_,_,._.,,..1 
( 

. ( 

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 basis 
Page 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, and 
Page 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 

---~---~·~ --~~~~-·--·~~-~-·------~~·_j 
Page 12 

1 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 of 
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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 

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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 ~ 

' ~ 

'--.==""-""· =·"'· ""··"'--"'-""·-=-""··-=""-""-""-=""·="'·==-=="'· =· "'··-==--=-""· ,.,. --""~""-=--=-=· .,.,. "''"'"'""'· ==· 
Page 15 

1 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 the 
Page 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 to 
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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: 

EXAMINATION 
Page 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 Naperville 
1 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) j 

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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. , 

i 

! L...,;·-==-=-""··===--=-=-""-=-=·"'-"'-"'·""-"'"""-="--"'· ==···"'"""'"''=·"'·=-"'~"'-"'·=-"'--=-==-=-~==-"'·-="'·-==-"'-""'""-d. } 
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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 1 

I 

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Page 23 

1 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 restrict 
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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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Page 25 

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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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 
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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. 

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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. 
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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. 

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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 

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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 
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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 

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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 to 
Page 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.) 
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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 
Page 38 

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