BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
INTHEMATTEROF:
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RECEJIVETh
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PETITION OF
CROMWELL-PHOENIX,
INC.)
PCB
No.
AS 03-05
FOR
AN ADJUSTED STANDARD
FROM
35
)
(Adjusted
Standard)
A1i(i
222003
Ill.
Adm. Code
Subpart F,
Section 2 18.204(c)
)
STAlE OF iLLll~O15
(the
Paper Coating Rule
)
)
Pollution
Control
Board
NOTICE OF
FILING
TO:
Charles
B.
Matoesian
Bradley P. Halloran
Division ofLegal Counsel
Hearing Officer
Illinois Environmental Protection Agency
Illinois Pollution Control Board
1021 North Grand Avenue East
James R. Thompson Center
Springfield,
IL
62794-9276
100 West Randolph, Suite 11-500
Chicago, IL
60601
PLEASE TAKE NOTICE that on August 22, 2003, we filed with the Clerk ofthe Illinois
Pollution ControlBoard,
100 West Randolph Street, James R.
Thompson Center Suite
11-500,
Chicago, Illinois, 60601-3218, an original and nine (9) copies ofCromwell-Phoenix, Inc.’s
POST-HEARING BRIEF,
a copy ofwhich is
attachedhereto and hereby served upon you.
CROMWELL-PHOENIX,
C.
By______
One ofIts Attorneys
EricB. Boyd
Lorena S. Neal
SEYFARTH
SHAW
55
B. Monroe St.,
Suite 4200
Chicago, Illinois 60603
(312) 346-8000
CT-TI
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TI-ITS FILiNG
IS MADR
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RPCYCI
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PAPFP
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
iN
THE MATTER OF:
)
PETITION OF CROMWELL-PHOENDç INC.)
PCB No.
AS
03-05
ci
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~
FOR AN ADJUSTED
STANDARD FROM 35
)
(Adjusted
Standard)
2
Ill. Adm.
Code Subpart F,
Section 2 18.204(c)
)
~
2
JJ03
(the ‘Paper Coating Rule”)
)
SlAtE
OF ILLINOIS
Pollution Control Board
CROMWELL-PHOENIX INC.’S POST-HEARING BRIEF
CROMWELL-PHOENIX, Inc.
(“Cromwell”), by and through its attorneys, and pursuant
to 35
Ill. Adm.
Code
§
101.612 and the Hearing Officer’s Order dated August 11, 2003,
respectflully submits the following as its post-hearing brief.
During the course ofthe August 7, 2003
hearing on Cromwell’s Petition for Adjusted
Standard, the Hearing Officer, Mr. Bradley P. Halloran, determined that certain questions posed
by Alisa Liu ofthe Illinois Pollution Control Board should be addressed by the parties in their
post-hearing briefs.
~
Transcript p.
5, Lines
7-9.
Although Mr.
Boyd,
the attorney for
Cromwell, responded to some ofMs. Liu’s questions,
Mr. Boyd was not sworn as a witness.
Cromwell now addresses the questions posed by Ms.
Liu.
The following responses are
supported by the affidavits ofthe persons with personal knowledge to respond to the specific
questions.
Ms.
Liu:
The Petitioner, on page 17, refers to some
experiments that were conducted,
reformulate CI coatings and installation ofadd-on controls.
Ther&s some
detailed information
concerning the evaluation ofthe add-on controls, but there is no data documenting the
experiments that were conducted on the reformulated coatings.
I was wondering if you could
please provide some information on those experiments and the results oftheir testing?
Transcript, p.
15.
Response:
The reformulation tests were conducted under the direction ofChet A.
Bidessi, Cromwell’s Laboratory Director, from December 2001
through June 2002.
A
CH1
10566745.1
discussion ofthe test results is
included at paragraphs
5
-
in the Affidavit ofChet A.
Bidessi,
attached hereto as Exhibit
1.
Ms. Liu:
In the petition on page four, Cromwell mentions that it may be the
only
manufacturer ofCI packaging material in Illinois.
Could you please comment on whether or not
Cromwell
is aware ofother CI packaging manufacturers in other states that are subject to similar
VOM emission control requirements?
...
And if so,
could you follow up with whether or not
Cromwell
is aware ofhow those other facilities comply with those applicable VOM limitations
that they have in their states?
Transcript, p.
16.
Response:
Based on their knowledge ofthe industry, Cromwell representatives believe
that other companies opcrate facilities that manufacture CI packaging materials in Indiana,
Wisconsin and Canada.
Cromwell representatives have not, however, researched what VOM
emission control requirements, if any, apply to those CI packaging material production facilities,
and are not aware if or how those other facilities comply with any applicable
VOM limitations.
~
Paragraph 10 ofthe Affidavit ofChet A. Bidessi.
Ms. Liu:
The petition does not include a street number for Cromwell’s Alsip facility.
It
refers to Ridgeway Avenue.
Could you please provide a more precise address, please?
Transcript, p.
16.
Response:
The Cromwell-Phoenix facility is located at 12701
South
Ridgeway in Alsip,
Illinois.
~
Paragraph 3
ofthe Affidavit ofChet A.
Bidessi.
-
Ms. Liu:
Also, on page four ofthe petition, it states that Cromwell started CI packaging
operations in 2001.
The building has been around since 1965, and we were wondering if that
same Alsip facility was being used for manufacturing CI products prior to Cromwell taking over
operations?
And if so,
is Cromwell or the Agency aware ofany information ofthe compliance
status of the facility if it was doing that kind of operation before 2001?
Transcript, p.
17.
Response:
The exact use ofthe building before 2001
is unknown.
To the best
knowledge ofCromwell representatives, however, the building was not used to manufacture CI
packaging products before 2001.
~
Paragraph 3
ofthe Affidavit ofChet A.
Bidessi.
Ms. Liu:
Inthe petition on page six,
it states that Cromwell had performed gravimetric
tests to determine the weight loss in emissions
from CI packaging production-processes.
It was
stated that the gravimetric demonstrated the overall VOM emissions
are less thanfive percent of
2
CIII
10566745.1
the weight ofthe CI solution applied,
could you possibly provide the gravimetric test data,
including the results, that demonstrates that five percent?
Transcript,
p.
17.
Response:
As stated by Mr. Boyd at the hearing, the gravimetric test data demonstrating
overall VOM emissions was provided to the IEPA in a Clean Air Act Permit Program
(“CAAPP”) permit application.
The information is contained in Exhibit 220-5A and Exhibit 220-
6 ofthe CAAPP Application.
The information shows that the overall VOM emissions are less
than five percent ofthe weight of the CI solution applied, ranging from a low of0.43
to a high
of 2.93.
~
Paragraph
12 ofthe Affidavit ofMark A. Home, attached hereto as Exhibit 2.
Ms.
Liu:
Could you also,
along those lines, provide some information on the amount of
different types of CI
coatings used on an annual basis along with their VOM content?
Ifthere
are
some trade secrets involved,
perhaps just the gallons per year along with associated
VOM
content.
Transcript, p.
18.
Response:
The CAAPP application also contained information on the CI coatings used
and the VOM content ofthe coatings.
The information on coating use is
contained in Exhibit
220-5A ofthe CAAPP Application.
The information providedwas based on actual coating use
information for 2001.
$~
Paragraph
10 ofthe Affidavit of Mark A. Home.
The information on
the VOM content ofthe coatings is contained in Exhibit 220-2 ofthe CAAPP Application.
~
Paragraph 7 ofthe Affidavit ofMark A. Home,
Ms. Liu:
In Cromwell’s motion for an expedited review, the Petitioner indicates that
there’s going to be a proposed merger with this other company and that that will result in an
increase in production ofCI packaging,
and the motion states the facility will still be a minor
source.
Given Cromwell’s earlier pre-merger estimates offive to six tons ofVOM per year from
the CI process, could you please provide an estimate ofthe anticipated increase?
Transcript, pp.
18-19.
Response:
An exact estimate ofthe amount ofVOM emissions post-merger is not
possible at the presenttime due to uncertainties with respect to the merger.
The Alsip Facility,
however,
plans to continue to be a minor (less than 25
tpy) source ofVOM emissions.
~
Paragraph
11 ofthe Affidavit ofChet A. Bidessi.
3
CH1
10566745.1
Ms. Liu:
On page two,
Cromwell
notes that, “Because it prints on the majority ofits
products before applying the corrosion inhibiting solutions,
it’s printing/coating operations are
regulated by 35 Illinois Administrative Code, Subpart H, 218.401.”
Inthe section from which
Cromwell seeks the adjusted standard, which is 218.204(c), there is a note that says that the
paper coating VOM limit does not apply to sources regulated under 218.401, so I was wondering
ifyou could clarify whether the requested relief from the adjusted standard pertains only to the
CI packaging materials that you don’t print on, or if you meant it to apply to all ofyour CI
packaging materials whether you printed on them or not?
Transcript, pp.
19-20.
Response:
The requested relief pertains to the CI coating material application, notthe
printing done prior to the
CI coating.
The printing operation is governed by 35
III. Admin. Code.
§
218.401.
The CI coating operation, however,
is not subject to 35
III. Admin.
Code
§
218.401,
but the coating requirements of35 Ill.
Admin. Code
§
2 18.204.
The Petition for Adjusted
Standard only
seeks relief from the requirements of35 Ill.
Admin. Code
§
218.204, not the
requirements of35 Ill. Admin.
Code
§
218.401.
Ms. Liu:
I was wondering if you could also explain the rationale for limiting the VOM
content ofthe CI coatings to 8.3
pounds per gallon in your adjusted standard wording?
Transcript, p. 22.
Response:
The CI compound with thehighest VOM content that Cromwell-Phoenix
currently uses contains 8.28 lbs ofVOMJgaI (less water).
The 8.3
lbs/gal limit was chosen in
order to allow the Facility to continue to use this coating.
Different types ofmetals require CI
packaging products with different coating formulations.
The limit of 8.3 lbs/gal rather than 8.28
lbs/gal was chosen because the standard at 35
Ill.
Admin.
Code
§
2 18.204 is based on one
decimal place, not two:
$,~
Paragraph 8 ofthe Affidavit ofMark A. Home.
Ms. Liu:
In the proposed language forthe adjusted standard, it would
require that
Cromwell report all annual emissions to the Illinois Environmental Protection Agency, could you
please clarify whether this requirement pertains to all
emissions of VOM at the facility or all air
emissions in general?
It might be something that you might want to insert in the wording so that
you’re only gearing this adjusted standard to the VOM emissions rather than other emissions that
your client might have that might be regulated.
Transcript,
p. 22.
Response:
The regulations at 35
Ill. Admin.
Code Part 254 require permitted facilities
that emit air contaminants to submit annual emissions reports to the EPA.
Because Cromwell’s
4
Clii
10566745.1
Alsip facility is a minor source ofemissions,
the annual reporting requirements of
35 Ill. Admin.
Code Part 254, Subpart. C apply.
The proposed language forthe Adjusted Standard was intended
only to require the annual emissions reporting that is already required ofthe Alsip facility
pursuant to
35 Ill. Admin.
Code Part 254, Subpart
C.
Ms.
Liu:
On page
14 ofthe petition, Cromwell states that if the requested relief is not
granted, it will have to
control 15.21
tons ofVOM per year.
I was wondering if you could
explain how the potential VOM reduction of 15.21 tons per year was calculated?
Transcript,
pp.
24-25.
Response:
The potential to emit VOM from the
CI manufacturing process at the Alsip
facility is
16.4 tpy, the potential to emit VOM from the flexographic printing inks
is 0.2 tpy, and
the potential to emit VOM from the Mixing Tanks is 0.3 tpy, for a total of 16.9 tpy.
Page 8 of
the RACT Analysis that was attached to the Petition and
accepted at the hearing as Petitioner’s
Exhibit
1
explains that the economic cost analyses were based on 90
control ofthe potential
VOM emissions for the
CI Coating operations, the flexographic printing inks and the mixing
tanks that were reflected on Exhibit 200-1 ofthe CAAPP
application.
The 15.21
tons reflects
potential controlled VOM emissions, and was determined by taking 90
of 16.9 tons.
~
Paragraph 6 ofthe Affidavit ofMark A. Home.
Ms. Liu:
Also on that page
14, Cromwell states that its operation is a “relatively small
contribution to the local air shed when compared to the hundreds ofthousands oftons ofVOM
emitted each year in the Chicagoland non-attainment area.”
Could you please calculate the
impact ofthose VOM emissions from the Alsip facility in terms ofthe overall emissions from
the Chicago non-attainment area if the Board were to
grantthe relief?
Transcript, pp.
25-26.
Response:
Following the hearing in this matter, in order to respond to this question,
Mark A. Home reviewed the
1999
Illinois Periodic Emissions Inventory for the Chicago ozone
non-attainment area (Chicago NAA) that was published in December 2001.
Based on this
inventory, point source VOM emissions in the Chicago NAA were
112.09 tons/day (TPD), area
source VOM emissions were
185.60 TPD, on-road mobile VOM emissions were 241.77 TPD,
-
5
Ciii
10566745.1
off-road mobile VOM emissions were
133.44 TPD,
and VOM emissions from biogenic sources
were 292.43
TPD.
This equates to total annual VOM emissions in the Chicago area of
352,345.45 tons, ofwhich 245,608.5 tons were emitted by anthropogenic sources.
When this
number is compared to the
5
to 6 tpy ofactual VOM emissions or the
16.4 tpy potential VOM
emissions from the
CI Coating Operations at the Alsip Facility, it is
clear that the VOM
emissions from Cromwell’s CI Coating Operations are appropriately described as relatively
small.
In addition, it should be notedthat the Board’s rules for Other Emission Units
in the
Chicago NAA that are not regulated by other VOM control requirements (35
III. Admin.
Code
Part 218, subpart TT) do not apply to sources with the potential to emit less than 25 tpy ofVOM.
~
Paragraph
13 oftheAffidavit ofMark A. Home.
Respectfully submitted,
CROMWELL PHOENIX,
INC.
By:______
One ofIts Attomney~
Eric B.
Boyd
Seyfarth Shaw
55 East Monroe Street
Suite 4200
Chicago, Illinois 60603
(312) 346-8000
DATE:
August 22, 2003
6
Ciii
10566745.i
Post-Hearing BriefExhibit
1
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
iN THE MATTER OF:
)
PETITION OF CROMWELL-PHOENIX,
~c.
PCB No.
AS 03-05
FOR AN ADJUSTED STANDARD FROM 35
)
(Adjusted Standard)
Ill.
Adm. Code Subpart F, Section
2 18.204(c)
)
(the “Paper Coating Rule”)
)
AFFIDAVIT OF CHET A. BIDESSI
I, Chet A. Bidessi, being first duly sworn under oath, depose and state as follows:
1.
I am currently employed as the Laboratory Director for Cromwell-Phoenix, Inc.
(“Cromwell”).
I have worked in that capacity for approximately 4
years.
2.
My training is as a Chemical Engineer.
I received an MSc in Chemical Engineering from
Lvov Polytechnic in the Ukraine in
1984, and an MASc in Chemical Engineering from the
University ofToronto in 1991.
-
3.
Cromwell
is located at 1270! South Ridgeway in Alsip, Illinois.
Cromwell began
production ofcorrosion inhibiting (“CI”) packaging materials at this facility in early 2001.
Neither I nor to my knowledge any other Cromwell representatives knowthe exact use of the
building before 2001.
To the best ofmy knowledge, however, the building was not usedto
manufacture CI packaging products before 2001.
4.
CI products contain a high amount ofhigh molecular weight volatile organic materials
(VOMs), such as propylene glycol, that act as both a corrosion inhibiting agent and a carrier for
-
other CI compounds.
These VOMs remain in the coated paper productand give certain
properties to the finishedproduct, such as a natural kraft paper look and feel.
5.
As part of my duties as Laboratory Director, I was responsible for conducting tests to
determine whether Cromwell could reduce the amount of VOM in Cromwell’s CI coating
formulations.
The tests were conducted
from December, 2001
through June, 2002.
6.
To reduce the amount ofVOM in
Cromwell’s formulations, three approaches were
considered.
First, we reduced the amount of VOM, which in turn meant increasing the amount
ofwater to compensate for the solids dissolution.
Second, we increased the amount ofsolids
in
the formulations by increasing the amount ofcurrent solids and/or adding new solid chemicals.
Finally, we replaced the current VOM carrier with higher molecular weightmaterials.
As
described below, each approach was unsuccessful in that the reformulated coatings either made
product quality unacceptable or would result in increased VOM emissions.
CH1
10569864.1
7.
We found several problems with the first approach.
First, increasing the water caused the
coated paperto become wrinkled.
Second, the reformulated solutiontook a longer period of
time to dry, meaning that these formulations would require drying by heat.
Such drying would
result in increased VOM emissions.
Finally, the reformulated solutions
were oily, and the coated
products had a very different appearance and feel than our current products.
8.
We found several problems with increasing the amount of solids in the CI coatings as
well.
One problem was that the chemicals did not stay in the paper substrate after the paper was
coated.
Instead, a white powder bloomed to the surface of the coated paper.
In addition, some
chemicals were precipitated out ofsolution by the addition ofthe other chemicals during the
mixing stage.
Some solutions turned into a suspension and could not be used for coating the
paper.
9.
Finally, we also were not successful in replacing the existing VOM carrier with other
materials.
The paper coated with those formulations had an oily look and a stiffer feel.
The
solutions were difficultto mix, and more heat was needed for mixing.
In addition, some
chemicals did not dissolve completely.
Finally, the coating weights were high and the coated
products were difficult to dry.
10.
Based on my knowledge ofthe CI packaging material industry, I believe that other
companies operate facilities that manufacture CI packaging materials in Indiana, Wisconsin and
Canada.
Neither I nor to my knowledge any other Cromwell representatives, however, have
researched
what VOM emission control requirements, if any, apply to those CI packaging
material production facilities, and are not aware if or howthose other facilities comply with any
applicable VOM limitations.
11.
Cromwell has entered into merger negotiations with another company.
Ifthe merger
occurs, an increase in production ofCI packaging materials and increased actual VOM emissions
may occur.
An exact estimate ofthe amount ofVOM emissions post-merger is not possible at
the present time due to uncertainties with respect to the merger.
The Alsip Facility, however, is
not currently a major source ofVOM emissions
(i.e.,
potential emissions greater than 25 tpy)
and
has no plans to become a major source of VOM emissions
after the merger.
Subscribed and Sworn to before me
this 21st Day of August, 2003.
Notary Public
~Ar~EAT1I
LORETTA F. SCHULTZ
2
CH1
~
PUBLIC, STATE
OF ILLINOIS
MY COMMISSION
EXPIRES
9/4 2005
Post-Hearing BriefExhibit 2
BEFORE THE
ILLINOIS POLLUTION
CONTROL
BOARD
iN THE MATTER OF:
)
PETITION OF CRO~LL-PHOEMX, INC.
PCB No.
AS 03-05
FOR AN ADJUSTED STANDARD FROM
35
)
(Adjusted
Standard)
Ill. Adm.
Code Subpart F,
Section
2 18.204(c)
)
(the
‘Paper Coating Rule”)
)
AFFIDAVIT
OF
MARK A. HORNE
I, Mark A. Home, being first duly sworn under oath, depose and state as follows:
1.
I
am a Registered Professional Engineer (State of Indiana) working with ERM, Inc. ‘s
office in Holland, Michigan.
I have been employed by ERM since 1998.
2.
I have more than 20 years ofexperience in environmental compliance, including
preparing permit applications for major new source review projects; performing Top-Down
BACT analyses for printing, specialty chemical
products packaging, and recreational vehicle
industries in various states;
completing Title V permit applications for many major sources
throughout the Midwest; preparing model Title V and PSD permits for guidance to state
permitting
agencies; participating in regulation development;
presenting oral and written
testimony at regulatory hearings; performing multi-media environmental compliance audits for
numerous
manufacturing facilities throughout the Midwest, including inspections ofTSDFs used
by the facilities; and preparing and implementing compliance test plans to determine
conformance with permit limitations and synthetic minor status.
A true
and correct copy of my
resume is attached as Attachment A.
3.
I have worked with Cromwell-Phoenix,
Inc. since 2001.
Based on information provided
by the client, I prepared the March 29, 2002 Clean Air Act Permit Program (“CAAPP”) permit
application and the May 2003 Reasonably Available Control Technology
(RACT) Analysis that
was included as Exhibit A to the Petition for Adjusted Standard filed with the Board on May 29,
2003.
4.
The March 29, 2002
CAAPP application included a summary ofsource wide potential
and actual VOM emissions.
The information was contained
in Exhibit 200-1
ofthe CAAPP
Application.
A true and correct copy ofExhibit 200-1
is attached to this Affidavit as Attachment
B.
5.
Exhibit 200-1 shows that the potential VOM emissions from the Alsip Facility’s
CI
Coating Operations are
16.4 tpy.
Exhibit 200-1
also shows that the potential VOM emissions
from the Alsip Facility’s Flexographic Printing Inks are 0.2 tpy
and that the potential VOM
emissions from the Alsip Facility’s two Mixing Tanks are 0.3 tpy.
6.
The RACT
Analysis (that was attached to the Petition and
accepted at the hearing as
Petitioner’s Exhibit
1) explains that the economic cost analyses were based on 90
control of
CH1
10569484.1
the potential VOM emissions for the CI Coating Operations, the Flexographic Printing Inks and
the Mixing Tanks that were reflected on Exhibit 200-1 of the CAAPP application.
The sum of
these threepotential VOM emission sources (16.4
+
0.2
+
0.3) equals
16.9 tpy of potential VOM
emissions.
The
15.21
tons referenced in the RACT
Analysis was determined by taking 90
of
16.9 tons.
7.
The March 29, 2002 CAAPP
application also included information on the as-applied
VOM content ofthe CI coatings used at the Alsip Facility.
The information was contained in
Exhibit 220-2 ofthe CAAPP Application.
Exhibit 220-2 also included information on the
ingredients of each CI coating formulation and the specific quantities ofeach, ingredient in the
formulation.
A true and correct copy ofExhibit 220-2 (with the information on the ingredients
ofeach CI coating formulation and the specific
quantities ofeach ingredient in the formulation
deleted) is attached to this
Affidavit as Attachment C.
8.
Exhibit 220-2 shows that the CI coating with the highest as applied
VOM content (less
water) is the Formulae W&F at 8.28
lbs/gal.
The 8.3
lbs/gal limit requested in
the Adjusted
Standard Petition was based on the Facility’s need to continue to use the Formulae W&F coating
for some CI packaging products.
The limit of8.3
lbs/gal rather than 8.28 lbs/gal was chosen
because the standard at 35 Ill.
Admin. Code
§
2 18.204
is based on one
decimal place,
not two.
Exhibit 220-2 shows that the as-applied CI coatings at the Alsip
Facility range from a high of
8.28 lbs/gal VOM to a low of 3.59 lbs/gal VOM.
9.
The March 29, 2002 CAAPP application also shows the amount ofdifferent types ofCI
coatings used on an annual basis along with their VOM content.
The information was contained
in Exhibit 220-5A ofthe CAAPP
Application.
A true and correct copy ofExhibit 220-5A is
attached to this Affidavit as Attachment D.
10.
Exhibit 220-5A was used to
determine the potential VOM emissions from the CI Coating
Operations at the Alsip Facility.
The emissions information was based on the
total weight of
coatings applied during 2001
multiplied by
an emission factor determined for the coatings.
The
potential VOM emissions were determined based
on the worst case emission factor and based on
operations for 8760 hours per year.
Exhibit 220-5A shows that the potential VOM emissions
from the
CI Coating Operations at the Alsip Facility are
16.4 tpy.
11.
I also assisted in the planning and
coordination ofgravimetric tests performed by
Cromwell personnel to determine the weight loss in
emissions from CI packaging production
processes.
The gravimetric weight loss test protocol and gravimetric weight loss data was
provided to the IEPA as part ofthe March 29, 2002
CAAPP permit application,
and was
identified as Exhibit 220-6 of the CAAPP Application.
A true and correct copy ofExhibit 220-6
is attached to this Affidavit as Attachment E.
12.
Support forthe statement in Cromwell’s Petition for Adjusted Standard that the overall
VOM emissions
from Cromwell’s CI packaging production process at the Alsip facility are less
than five percent ofthe weight ofthe CI solution applied is found in Exhibit 220-5A and Exhibit
220-6.
Exhibit 220-5A shows that the VOM emissions factor for the coating formulations
ranged from
a low of 0.43
lbs VOM emitted/100 lbs coating applied to a high of2.93
lbs VOM
emitted/100 lbs coating
applied.
These
numbers equate to percentages of0.43
to 2.93, which are
2
Ciii
10569484.1
emitted/l00 lbs coating applied.
These numbers equate to percentages of0.43 to 2.93, which are
lower than the
5
indicated in thePetition.
Themanner in which the emissions factors were
determined is described in Exhibit 220-6.
13.
Following the hearing in this matter, in order to respond to a question raised by Ms. Alisa
Liu at the hearing, I reviewed the 1999 Illinois Periodic Emissions Inventory for the Chicago
ozone non-attainment area (Chicago NAA) that was published in December 2001.
Based on this
inventory, point source VOM emissions in the Chicago NAAwere
112.09 tons/day (TPD), area
source VOM emissions were
185.60 TPD, on-road mobile VOM emissions were 241.77
TPD,
off-road mobile VOM emissions were 133.44 TPD, and VOM emissions from biogenic sources
were 292.43 TPD.
This equates to total annual VOM emissions in the Chicago area of
352,345.45 tons, ofwhich
245,608.5
tons were emitted by anthropogenic sources.
When this
number is compared to the
5
to 6 tpy ofactual VOM emissions or the
16.4 tpy potential VOM
emissions from the CI Coating Operations at the Alsip Facility, it is clear that the VOM
emissions from Cromwell’s CI Coating Operations are appropriatelydescribed as relatively
small.
In addition, it should be noted that the Board’s rules for Other Emission Units in the
Chicago NAA that are not regulated by other VOM control requirements
(35
III. Admin. Code
Part 218, subpart TT) do not apply to sources with the potential to emit less than 25 tpy ofVOM.
Mark A. Home
Subscribed and Sworn to before me
this 21st Day of August, 2003.
~taiy
Public
JANICE
L. WHEELER
Notary
Public, Ottawa
County.
MI.
My
Ccmmi~sion
Exr~~res
Nov. 03, 2003
3
Printed
on Recycled Paper
ATTACHMENT
A
Mark A. Home, P.E.
More than 20 years of experience in
environmental
Registration
compliance, including preparation of permit
•
Registered Professional Engineer, State of Indiana
applications for major new source review projects.
Performed Top-Down BACT analyses for printing,
Fields of Competence
specialty chemical products packaging,
and
•
Multi-Media Compliance Auditing
recreational vehicle industries in various states.
•
Permit applications for major new source review
Completed Title V permit applications for many
major sources throughout the Midwest. Prepared
‘~0j
model Title V and
PSD
permits for guidance to state
•
Top-down BACTanalyses
permitting agencies. Participatedin regulation
•
Preparation and implementation of compliance test
development. Presented oral and
written testimony at
plans
regulatory hearings. Performed multi media
•
Regulatory Compliance
environmental compliance audits for numerous
•
Emissions Trading Programs
(ERMS, NO~)
manufacturingfacilities throughout the Midwest,
including inspections of TSDFs used by the facilities.
•
Control Technology Assessment
Prepared and implemented compliance test plans to
•
Emission Inventories
determine conformance with permitlimitations
and
•
Hazardous WasteManagement
synthetic minor status.
•
Community Right-to-Know Compliance
Education
•
M.S., Environmental Engineering, Purdue
University,
1984
•
B.S., Environmental Engineering, Purdue University,
1980
Professional
Affiliations
•
Air
& Waste Management Association, International
and
Lake Michigan States Section
Key
Projects
Secured
several construction and operating permits in
expedited times frame for a new thermoplastic
polyurethane and new wood
furniture
manufacturing
facilities
located in a severe ozone nonattainment area.
Performed multi-media environmental audits of many
printing, recreational vehicle
and
modular home
manufacturingfacilities to ensure compliance with
CAA, CWA, RCRA, and
EPCRA requirements, as well
as corporate environmental standards. Conducted
audits of TSDFs used by many of these manufacturing
plants
to ensure they met RCRA and corporate
environmental requirements.
Performed emissions inventories,provided guidance on
required compliance measuresand completed Title V
Operating Permit applications for many heatset and
coldset web offset lithographic printing plants.
Developed
and
submitted model permits to the state
regulatory agency concurrent with many of these
applications.
Completed
PSD
and
Title V permit applications for a
major chemical products packagingfacility, including a
complete Top-Down BACT analysis.
Established the
groundwork for the corporate implementation
of the Title V operating permit application program for a major
international printing
company.
Presented
oral
and
written testimony at regulatory
hearings in response to proposed rulemakings for the
Chicago FederalImplementation Plan and enhanced
RACT requirements for heatset, coldset, web and
sheetfed offset lithography.
Provided technical support for successful legal
proceedings vs. USEPA to resolve a
PSD
permitting
issue for a major expansion,
and to establish reasonable
compliance
time
periods for monthly rotogravure
carbon adsorption solvent recovery systemcontrol
efficiency demonstrations.
Coordinated and conducted compliance test programs
for various industrial clients including petroleum
refineries, steel mills,
pathological and hazardous waste
incinerators,
and power plants. Specified air pollution
control hardware and designed capture systems.
Completed the emissions inventory, Title V
Operating
Permit application and compliance plan for a synthetic
natural
gas
manufacturing facility of a
major
utility.
New Source Review
and PSD
issues were addressed.
Conducted compliance test programs on
utility
and
industrial process boilers firing coal, fuel oil
and
natural
gas. The coal fired units included both chain grate and
tangentially fired pulverized coal fuel feed systems.
Completed a synthetic minor permitapplication and
emissions inventory for a Portland cement distribution
terminal.
Developed a complete trial burn plan for a major cement
manufacturer for the use of hazardous waste
supplemental fuel in the production of their cement.
Prepared operating permit applications, annual emission
reports
and
resolved RCRA waste disposal issues for a
wood
furniture
manufacturingplant. Prepared materials
usage analysis and assisted in establishing the facility as
a synthetic minor HAP source.
2/02
MA!-!
ATTACHMENT
B
EXHIBIT 200-1
SUMMARY OF SOURCE WIDE POTENTIAL
AND
ACTUAL VOMEMISSIONS
Potential VOM Emissions
Actual CY2001 VOM
(tons/year
@ 8760 hrs)
Emissions
(tons)
Process or Operation
-
CI Coating Operations
16.4
4.24
Versil Pak
Wax Coating Operation
5.9
0.9
Flexographic Printing Inks
0.2
0.06
Mixing Tanks (2)
0.3
0.1
Process Boiler
0.1
0.1
Total
22.9
tpy VOM
5.4
tpy VOM
CAAJ’P
Application
Page 1 of 1
Cromwell1’hoeniac Inc.
Alsip, Illinois
ATTACHMENT
C
Formula A
Formulae
W&F
Weight (Ibs)
VOC (Ibs)
Gallons
Weight
(Ibs)
VOC
(lbs)
Gallons
0.0
0.0
0.0
0.0
166
166.0
19.9
282
282.0
33.8
2860
2860.0
330.4
2734
2734.0
315.8
220
0.0
26.4
222
0.0
26.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
337
0.0
24.5
0.0
0.0
323
323.0
43.5
0.0
0.0
220
0.0
26.4
0.0
0.0
274
274.0
36.5
800
800.0
106.6
0.0
0.0
402
402.0
53.0
Totals
4400
3623.0
507.5
Totals
4440
4218.0
535.7
As-Applied VOC
(
by Weight)
82.34
As-Applied VOC
(
by
Weight)
95.00
As Applied VOC
(lb/gal)
7.14
As Applied
VOC
(lb/gal)
7.87
As Applied VOC (lb/gal less H20)
7.53
As Applied VOC (lb/gal
less 1-120)
8.28
VOM by vol ofcoating (less H20)
89.43
VOM by vol of coating (less
H20)
100.00
VOM
by volume of volatile fraction
94.22
VOM
by volume of volatile fraction
95.03
Formula LVFG
Formula MPI
Weight (Ibs)
VOC (lbs)
Gallons
Weight (Ibs) VOC (Ibs)
Gallons
732
0.0
32.36
64
0.0
2.8
0.0
0.00
0.0
0.0
1120
1120.0
129.38
3647
3647.0
421.3
2426
0.0
290.89
720
0.0
86.3
0.0
0.00
126
0.0
17.0
732
0.0
89.45
0.0
0.0
17
0.0
1.96
,
0.0
0.0
0.0
0.00
0.0
0.0
0.0
0.00
0.0
0.0
490
0.0
58.75
250
0.0
30.0
0.0
0.00
0.0
0.0
0.0
0.00
0.0
0.0
Totals
5517
1120.0
602.78
Totals
4807
3647.0
557.4
As-Applied
VOC (
b~
Weight)
20.30
As-Applied VOC
(
by Weight)
75.87
As Applied VOC (lb/gal)
1.86
As Applied VOC
(lb/gal)
6.54
As Applied VOC
(lb/gal less H20)
3.59
As Applied VOC (lb/gal less
H20)
7.74
VOM by vol of coating
(less H20)
41.48
VOM
by vol
of coating (less
H20)
89.42
VOM by volume
of volatile fraction
30.78
VOM
by volume
of volatile fraction
82.99
n
Ezhi
bit
220-5A
VOC
Emissions
Determination
Roll Weight
________
Start
Finish
1611
1926
2580
3029
1375
1632
1709
1970
5
W
1672
1916
Weight of Coating
Applied
Remaining
Evolved
324
315
9
466
449
17
266
257
9
268
261
7
246
244
2
Coating Evolved
(
by weight)
2.78
3.65
3.38
2.61
0.81
Average Coating Weight
Loss
and Cl Coating VOM Content Summary
Avg Weight Loss
Formulation VOC
Truesdail
M24
VOC
Galbraith
M24 VOC
Average VOC
Formula
(
by wt)
Content
(
by wt)
Content
(
by wt)
Content (
by wt)
Content (
by wt)
A
3.27
82.34
86.96
87.67
85.66
W/F
2.43
95.00
92.33
90.19
92.51
LVFG*
14.33
20.30
23.93
6.34
16.86
MPI
0.55
75.87
55.57
52.74
61.39
VOM Emissions
Summary
Total Wt (Ibs) of
ProportIonal lbs
ink
Coating Applied
Solids Applied*
During CY 2001
During
CY2001
154,000
232
128,760
194
.27,605
42
48,070
72
VOM Emission Factor
(lbs VOM
Emitted/100
lbs Coating Applied)
2.93
2.39
2.44
0.43
Formula
A
W/F
LVFG
MPI
Totals
358,435
541
8470
4.24
Total Flexographic ink Applied
(lbs)
1386
Flexographic Ink Solids
(wt)
=
39
*Notes: LVFG
is
normally applied
at 5 lbs/ream (85
of thetime) and
infrequently applied
at 15 lbs/ream
rsteel
wrap’
15).
Trials
8 and 9 represent the 5
lbs/ream
apprication rate, whereas Trial 6
represents
the 15 lbs/ream
rate.
The
average weightloss
for
LVFG
represents
the
weighted
averageof
these
test
values.
Also,
as shown above, the weight of ink
solids
applied is included as an
additional
factor
in the determination ofVOM emissions.
WorstCase
Emission
Factor:
Total Cl
Coating Applied in CY 2001:
Numberof Operating Hours in CY 2001:
Potential
Operating
Hours
per
Year
Potential VOM Emissions
(tonslyr)
=
Cromwell-Phoenix,
Inc.
Alsip,
Illinois
2.93
lbs VOM
Emitted per 100
lbs
Cl
Coating
Applied
358,435
lbs
2800
Hours
8760
hours
16.4 tons
Risky’s
Machine (Swiss)
Trial
Formula
-
Roll
Start
Weight
Finish
Weight of Coating
Applied
Remaining
Evolved
Coating Evolved
(
by weight)
I
W
2435
2807
375
372
3
0.80
2
W
2394
2794
409
400
9
2.20
3
W
2086
2377
303
291
12
3.96
4
W
1708
2066
368
358
10
2.72
5
W
2656
3463
840
807
33
3.93
6
LVFG
1905
2065
294
160
134
45.58
7
MPI
2687.5
3412.5
729
725
4
0.55
8
LVFG
1794.0
2060.0
299
266
33
11.04
9
LVFG
2015.0
2312.0
318
297
21
6.60
Walter’s Machine (Blue Line)
Trial
1
2
3
4
Formula
A
A
A
W
Actual VOM
EmIssions (Ibs)
4512
3078
674
206
Actual
VOM
Emissions (tons)
2.26
1.54
0.34
0.10
ATTACHMENT
E
Exhibit
22
0-6
Gravimetric Weight Loss Test
Protocol and Gravimetric Weight
Loss Data
TEST PROTOCOL FOR DETERMINING EMISSIONS
1.
Gravimetric Weight Loss Determinations for Coating Lines
-Weigh the master roll of kraft paper which will
be impregnated with the
corrosion inhibiting (Cl) solution. Record this weight as Roll Weight before Cl
treating.
-Weigh the paper core(s) on the wind-up shaft.
Record this weight; to be
subtracted from the finished
roll(s).
-
Set up the web using the master kraft paper roll.
Any
scrap from this step is
kept and weighed as Scrap before CI treating.
Record this weight; to be
subtracted from the Weight of master roll.
-Weigh the container of corrosion inhibiting
solution. Fill the clean and dry
coating pan to the required mark, for the gravure and applicator rollers. Record
this weight as Solution before treating.
-Start process and impregnate the kraft paper with the corrosion inhibiting (Cl)
solution. Most times a master kraft paper roll will give two rolls of Cl treated
paper. All cores
used are weighed. Any scrap generated during this process
is
weighed; this scrap weight is added to the weight of the Cl finished
roll(s). All Cl
solution
used is weighed and these weights comprise the Weight of Cl solution
before treating.
-At end of the run, weigh the finished impregnated
CI treated roll(s). Record this
weight as Roll Weight after Cl treating, this is the “as produced roll weight”. Any
scrap after the impregnating process is added to this weight
-At the end of the run, weigh the remaining uncoated master kraft paper roll; if all
the paper was used
up, weigh the core.
Record this weight, to be subtracted
from the Weight of the master kraft
roll before Cl treating.
-At the end of the run, empty all remaining Cl solution from the pan into the
original Cl solution container and weigh.
Record this weight as Cl Solution after
treating.
Page
1 of
S
TEST PROTOCOL FOR DETERMINING EMISSIONS
Gravimetric Weight Loss Calculations for the Coating Lines:
Any loss in weight is regarded as an air emission.
Weight of kraft paper used in treating process:
(Weight of master kraft roll)
-
((Weight of core
(i-
any paper remaining at the end
of the Cl treating process)
+
Weight of Scrap before Cl treating))
Weightof Cl treated Paper:
((Weight offinished treated roll(s))
+
(Weight of Cl treated scrap))
-
((Weight of
core(s))
Weight of CI solution remaining in the treated Paper
Weight of CI treated paper
-
Weight of kraft paper used
in
treating process
Weight of Cl solution used in the impregnating process:
(Weight of Cl Solution before treating
+
Weight of Cl Solution added)
-
Weight of
CI Solution after treating
Percent Loss of Solution
(
emissions
by weight):,
100
x (Weight
of Cl solution used in impregnating process)
-
(Weight of Cl solution
remaining
in the treated Paper)
I
(Weight of Cl solution
used in impregnating process)
The above emissions calculation is then further refined by accounting for residual
weight loss that occurs during the storage and the finishing operations, as described
below in Steps 2,
3, 4 and 5.
VOM Emissions
The final gravimetric loss is multiplied by the
weightVOM that is in the liquid fraction
ofthe as-applied Cl solution. This is a worst case determination that assumes that the
evaporation of VOM is proportional to its composition in the solution. In fact, the water
fraction will preferentially volatilize due to its higher vapor pressure.
Page 2 of
5
TEST PROTOCOL FOR DETERMINING EMISSIONS
2. Weight Loss of Cl Treated master rolls with Time
-After the Cl treated master rolls are produced at the coating lines, the weight of
these rolls are recorded and dated. This weight is the as-produced roll weight.
Every week these rolls are weighed and the new weights and corresponding
dates are recorded. If rolls will be used in a short time period (i.e. less than a
one week increment), then the roll weight is
taken before the roll is used.
The Weight Loss observed during the storage period is deducted from the “Weight of
Cl Solution remaining in the treated paper” in Step 1.
3. Weight Loss at Rewinding Stations:
At this station, the as produced master rolls are rewound into smaller length rolls and in
some cases,
smaller widths as well.
-After the Cl treated master rolls are produced at the coating lines,
the weight of
these rolls are recorded and dated. This weight is the as produced roll weight.
-All cores to be used on the rewind shaft are weighed and recorded as core
weight after rewind.
-Set up Web of the treated paper. Any scrap during this step is recorded and is
subtracted from the weight of the as produced roll.
-Start rewind process. Any scrap/trimmings from this step are recorded and
added to the weight of the finished smaller rolls.
-At the end of the rewinding process, weigh all
smaller rolls made.
Weight Loss Calculations for the Rewinding Station:
Weight Loss during Rewinding
=
((As
produced master roll)
-
(Scrap weight
+
Core
weight
))
-
((Smaller roll weight)
-
(Scrap/trimmings weight
+
core(s) weight after
rewind))
The Weight Loss observed during the rewind process is deducted from the “Weight of
Cl Solution remaining in the treated paper” in Step 1.
Page 3 of
5
TEST PROTOCOL FOR DETERMINING EMISSIONS
4. Weight Loss for the Sheeting
Process
This is the process whereby the
CI treated Master rolls from the coating lines are cut
into large size sheets.
-After the
CI treated master rolls are produced at the coating lines, the weight of
these rolls are recorded
and
dated. This weight is the as produced roll weight
-Set up Web of the treated paper. Any scrap during this step is recorded and
subtracted from the weight of the as produced roll.
-Weigh the pallet onto which the cut sheets will be stacked.
-Begin sheeting process. Stack sheets onto weighed pallet. Any scrap during
this process is weighed and recorded as Scrap during sheeting. This Scrap
weight is added to the weight of cut sheets.
-Atthe end ofthe sheeting process, weigh stack of cut sheets on pallet. Subtract
pallet weight to get weight of cut sheets.
Weight Loss Calculations for the Sheeting Process:
Weight Loss during Sheeting
=
(As
produced roll weight
-
Scrap from set-up)
-
(Weight
of cut sheets
+
Weight of Scrap during sheeting process)
The Weight Loss observed during the sheeting process is deducled from the “Weight
of Cl
Solution remaining in the treated paper” in Step 1.
Page 4 of
5
TEST PROTOCOL FOR DETERMINING EMISSIONS
I
5. Weight Loss for the Guillotine Cutting Process
This is the process in which the large cut sheets from the Sheeting process are
trimmed into precise smaller sheets.
-Weight of large cut sheets from the Sheeting process is recorded.
-Sheets are trimmed to precise size. All trimmings are kept and weighed as
scrap trimming.
-Weigh the precise cut sheets.
Calculations for the Guillotine Cutting Process:
Weight Loss during the Guillotine Cutting Process
=
(Weight of large cut sheets)
-
(Weight of precise cut sheets
+
Weight of scrap trimmings)
)
The Weight Loss observed during the Guillotine cutting process
is deducted from the
“Weight of Cl Solution remaining in the treated paper” in Step 1.
NOTE:
1. All weights forthe paper rolls, cut sheets and containers of Corrosion
Inhibiting solutions were done on a Rice Lake Weighing Systems scale, model
number: 4x4HP-5K~
with an electronic read out, CAS model Cl-2001A This
scale has a capacity of 1000 and accuracy of
±
1
lb.
All weights for the cores and scrap papers were done on an Ohaus scale, model
number l5S. This scale has a capacity of 100 and accuracy of
±
0.01
lb.
Both scales are calibrated quarterly each year by the Abacus Scale Company of
Chicago,
IL. The most recent calibration was performed on Jan.10, 2002.
2.
These initial determinations were processed in a step wise fashion. The
results obtained are valid for the specific operational step. Currently, we are
measuring emissions in a progressive manner to follow through from the initial
step of printing coating to the final step of either precise cutting or rewinding.
Results of this effort will be reported at a later date.
Page5of5
Emission’s Test at
Picky’s
Machine
(Swiss
Press 84”)
Trial ff
1
1/5/02
84”
Wide White
Woven W. The
CI
formulation
used here,
has
5
water.
Kraft Master RollWeight at start:
2446#
-
1 1#
(core weight)
=
2435#
As Produced RollWeight: 2819ff
-
(1 1ff
(coreweight)
+
1#
(scrap))
=
2807ff
CI Solution in Paper: 2807#
-
2435ff
=
372#
CI
Solution
used: 500# -125#
=
375#
CI Solution lost in process: 375
-
372
=
3ff
Loss ofCI Solution:
(3/375) x 100
=
0.80
Trial #2
1/5/02
84” Wide White WovenW. The CI formulation used here,
has
5
water.
“~
Kraft
Master Roll Weight at Start:
2405#
-
1 1# (core
weight)
=
2394ff
As Produced Roll Weight: 2808#
-
(11ff (core weight)
+
3ff (scrap))
=
2794ff
CI Solution
in Paper: 2794#
-
2394ff
=
400ff
CI Solution used
: 492#
-
83#
=
409#
CI Solution
lost
in process: 409
-
400
=
9ff
Loss ofCI Solution: (9/409) x 100
2.20
TrIal
#3
1/5/02
72”
Wide White Woven W. The
CI formulation used here,
has
5
water.
Kraft Master Roll
Weight at Start:
2096#
-
10# (coreweight)
2086#
As Produced Roll Weight:
2389ff
-
(10# (core weight)
+
2# (scrap))
=
2377#
CI Solution in Paper: 2377#
-
2086ff
=
291ff
CI Solutionused:
500# -197ff
=
303#
CI Solutionlost in process: 303
-
291
12ff
Loss ofCI Solution: (12/303) x 100
=
3.96
Pagelof
5
Emission’s Test at
Picky’s Machine
(Swiss
Press 84”) contd
Trial
#4
1/5/02
72”
‘Wide Scrim Wrap W.
The CI
formulationused
here,
has
5
water.
Kraft Master Roll Weight at
Start:
1730#
-
(10ff (coreweight)
+
12# (scrap))
=
1708ff
As Produced Roll Weight: 2078ff
-
(10ff (coreweight)
+
2ff
(scrap))
=
2066ff
CI Solution in Paper: 2066ff-
1708#
=
358ff
CI Solution
used
: 498ff -130#
=
368ff
CI Solution
lost
in process: 368
-
358
=
10#
Loss ofCI Solution: (10/368) x
100
=
2.71
Trial#5
-
1/8/02
72½”
WideFerro-Pak 40W. The CI formulationused here, has
5
water.
Kraft Master Roll Weight at Start:
2675ff
-
(10ff (core weight)
+
9ff (scrap))
=
2656ff
As Produced Roll Weight:
((1707ff(roll 1)
+
1783ff (roll 2))
-
((10ff (core weight roll 1)
+
10#
(core weight roll2)
+
3ff (scrap roll 1)
+
4ff (scrap roll 2))
=
3463#
CI Solutionin Paper:
3463#
-
2656ff
=
807ff
CI
Solutionused
:(
493ff
-
72# (drum 1))
+
(507ff
-
88ff (drum 2))
=
840#
CI Solution lost in process: 840
-
807
=
33#
Loss ofCI Solution: (33/840) x 100
=
3.92
Page 2 of
5
Emission’s Test at
Picky’s Machine
(Swiss
Press 84”) contd.
Trialff
6
1/16/02
73” Wide Ferro-Pak4OFG. The CI formulation used here,
has
44
water.
Kraft Master Roll Weight at Start:
1937#
-
(8ff (core weight)
+
24ff (scrap))
=
1905ff
As
Produced
Roll Weight:
((1253#(roll 1)
+
828ff (roll 2))
-
((8# (core weight roll
1)
+
8ff
(coreweight roll2))
=
2065ff
CI Solution in Paper: 2065#
-
1905ff
=
160ff
CI Solution used
:(
581#
-
287ff)
=
294ff
CI
Solution lost in process: 294
-
160
=
134ff
Loss ofCI Solution:
(134/294) x 100
=
45.57
Trial#7
1/18/02
73” WideFerro-Pak 4OMPL The CI formulation used here, has
15
water.
• Kraft Master
Roll Weight at
Start:
2699ff
-
(10ff (core weight)
+
1.5ff (scrap))
=
2687.5ff
As Produced Roll Weight:
((1745#(roll
1)
+
1688# (roll 2))
-
((10ff (core weight roIl 1)
+
lO#
(coreweight
roll2)
+
2.5ff
(scrap roll
1))
=
3412.5#
CI Solution in Paper: 3412.5#
-
2687#
=
725.5ff
CI Solution used
:(
5
12#
-
0# (drum 1))
+
(497#
-
280ff
(drum 2))
=
729ff
CI Solution lost
in process: 729
-
725.5
=
3.5ff
Loss of CI Solution: (3.5/729) x
100
=
0.48
Page 3 of
5
Emission’s
Tests
at Walter’s Machine (Blue Line 72”)
)
Trial#1
12i12/O1
43” Wide
Ferro-Pak 35A.
The CI formulation used here, has
5
water.
Kraft Master Roll Weight at Start:
1617#
-
(6ff (core weight))
=
161 1#
As Produced Roll Weight:
((1071#(roll 1)
+
865ff (roll2)+2ff (coated scrap roll 2))
-
((6#
(core weight roll 1)
+
6ff (core weightroll2)))
=
1926ff
CI
Solution inPaper:
1926ff- 1611ff =315#
CI Solution used
:(
408ff
-
84ff)
=
324ff
CI Solution lost
in process: 324-315= 9ff
Loss of CI Solution: (9/324) x
100
=
2.78
Trial #2
12i12/01
72½”
Wide
Ferro-Pak
35A.
The CI
formulation
used here, has 5
water.
Kraft Master Roll Weight at Start:
2707# -(11ff (core weight)
+
116ff (paper scrap)
=
2580#
As
Produced Roll Weight:
((1628#(roll 1)
+
1416ff (roll 2)
+
6ff
(scrap roll))
-
((1 1ff
(core
weight
roll 1)
+
10ff
(coreweight roll2)))
=
3029#
CI Solution in Paper: 3029ff
-
2580ff
=
449ff
CI Solution used
:(
513# -47ff)
=
466ff
CI Solution lostin process: 466
-
449
=
17ff
Loss ofCI Solution: (17/466) x
100=3.65
TriaI#3
12/13/01
36½”
Wide
Ferro-Pak 35A.
The
CI formulation used here, has 5
water.
KraflMaster Roll Weight at Start:
1386#
-
(6# (core weight)
+
5#
(paper scrap)
=
1375#
As Produced Roll Weight:
((856#(roll
1)
+
781# (roll 2)
+
5#
(paper scrap
))
-
((5#
(core
weight roll 1)
+
5ff
(core weight roll2)))
=
1632ff
CI Solution in Paper:
1632#
-
1375ff
=
257ff
CI Solution used
:(
474ff
-
208ff)
=
266ff
CI Solution lost in process:
266
-
257
=
9ff
Loss ofCI Solution: (9/266) x 100
=
3.38
Page 4
of
5
Emission’s
Tests
at Walter’s Machine (Blue Line 72”) contd
Trialff 4
12/17/01
46”Wide
Ferro-Pak 3SWB
The CI
formulation
used
here,
has
5
water.
Kraft Master RollWeight
at
Start:
1718ff
-
(9ff (coreweight)
=
1709ff
As ProducedRollWeight:
((993#(roll 1)
+
987ff(roll 2)
+
2ff (coated scrap
roll 1))
-
((6ff
(core
weight roll 1)
+
6ff
(coreweight
roll2))
=
1970ff
CI
Solution in Paper: 1970#
-
1709ff
=
261#
CI Solutionused
:(
499ff
-231ff)
=
268#
CI Solution lost
in process: 268
-
261
=
7ff
Loss ofCI Solution: (7/268) x 100
=
2.6
Trialff
5
12/17/01
46” Wide
Ferro-Pak
35WB.
The CI formulation used here, has
5
water.
Kra.ft
Master
Roll Weight at
Start:
l678#
-
(6ff (core weight))
=
1672ff
AsProducedRollWeight:
((991#(roll 1)
+
934ff (roll 2)+ 3ff (coated scrap
roll 2))
-
((6# (core
weight roll 1)
+
6ff (core weight
roll2)))
1916#
CI Solution in Paper: 1916ff
-
1672#
=
244#
CI Solutionused:( 194ff
-
52ff)
=
246ff
CI Solution lost in process:246-244= 2#
Loss ofCI Solution: (2/246)x 100
=
0.8
1
Page5 of
5
Emission’s Test at’ Picky’s Machine
(Swiss
Press 84”)
Trial ff 8: Wei~.htLossDuringIinpregnating’Process
3/13/02
85” Wide
4OFG;
one side treated.
The
CI formulationused here,
has
44
water.
Kraft MasterRoll
+
CoreWeight at start:
3050ff
Kraft
Master
Roll remaining
+
CoreWeight at start:
1212ff
Scrap Paper duringwebbing process: 44ff
Weight ofKraft Paperused forproductionrun: 3050
-
(1212
+
44)
=
1794ff
Weight
ofCI coatedMaster Roll: 2069ff
As ProducedCI coated
Paper Weight: (2069#
+
2ff (coated scrap)
-
11ff (coreweight)
=
2060#
CI Solution in Paper: 2060ff
-
1794ff
=
266ff
CI Solution in
drum
at
start
of
run:
580#
CI Solution indrum at end of
run:
281#
CI Solutionusedfor run:
299#
CI Solution
lost
in process: 299
-
266
=
33#
LossofCI Solution during
impregnation process:
(33/299) x
100
=
11.04
Stage 2:
Weight Loss ofCI Master
Roll
standing
onFloor
Weight as produced (3/13/02:
2069ff
Weight ofRoll (3/15/02):
2069ff
Weight ofRoll (3/18/02):
2069ff
Weight ofRoll (3/21/02):
2069ff
Weight ofRoll (3/22/02):
2069#
Loss during standing
for 9
days:
Page
1 of
4
Stage 3: Weight Loss during
Trimming and Rewinding
3/22/02
(Six inches
was
trimmed offthe edges ofthe CI Master Roll.)
Weight ofCI
Master Roll at start:
2069ff
Weight ofCore at start:
11ff
Weight ofCI Paper at
start:
2058ff
Weight
ofTrimmed
Roll
+
Core
at end:
1904ff
Weight
ofCore at end:
11ff
Weight of
Trimmed
CI Paperat end:
1893#
Weight ofscrap
trimmings at
end:
165ff
Weight ofCI Paper at end:
1893
+
165
=
2058#
Loss during Trimming and Rewinding:
fl
Loss during the manufacture ofthe 4OFG product
Loss
during
impregnation
+
Loss
during standing
+
Loss
during trimming/rewinding:
33 +0+0=33ff
Loss during
the entire
manufacturing process:
(33/299)x 100=11.04
Page 2
of 4
Trial ff 9
3/18/02
74” Wide 4OFG; one side treated. The CI formulation
used
here, has 44
water.
Stage 1: Weight Loss During Impregnating Process
3/18/02
Kraft Master Roll
+
Core Weight at start:
2036ff
Core Weight at start:
‘
.
10ff
Scrap Paper during webbing process at start:
11ff
Weight ofKraft Paper
used
for production run: 2036
-
(10
+
11)
=
2015#
Weight of CI coated Master Roll#1:
1756ff
Weight ofCI coated Master Rollff2:
568#
As Produced CI
coated
Paper Weight: (1756ff
+
568#
+
8# (coated
scrap)
-
((10ff (core weight
roll #1)
+
10ff (coreweight roll ff2))
=
2312ff
CI Solution in CI coated Paper: 2312ff -2015ff
=
297ff
CI Solution in drum at start ofrun:
592ff
CI Solution in drum at end ofrun:.
274ff
CI Solution used for run:
318ff
CI Solution lost in process:
318 -297
=
21ff
Loss of CI Solution: (2 1/318) x
100
=
6.60
Stage 2: Weight Loss ofCI Master Roll standing on Floor
Roll ff1:
Weight as produced (3/18/02):
1756#
Weight ofRoll (3/20/02):
1756#
Loss during standing for 2
days:
0
Roll ff2:
Weight as produced (3/18/02):
568#
Weight ofRoll (3/20/02):
568ff
Loss during standing for 2 days:
0
Page 3 of 4
Stage3: Weight Loss during Trimming and Rewinding
3/20/02
Roll#1
(1 inch was trimmed offthe edges ofthis CI Master Roll.)
Weight ofCI Master Roll at start:
1756ff
Weight ofCI Master Roll remaining
+
Core at start:
12#
Weight ofCI Paper used:
1744ff
Weight ofTrimmed Roll
+
Core at end:
1730ff
Weight ofCore at end:
10ff
Weight ofTrimmed CI Paper at end:
1720ff
Weight ofscrap trimmings at end:
24ff
Weight ofCI Paper at end:
1720
+
24= 1744ff
Loss during Trimming and Rewinding:
0
Roll#2
(1 inch
was trimmed
offthe edges ofthis CI Master Roll.)
Weight ofCI Master Roll at start:
,
568#
Weight of CI Master Roll remaining
+
Core at start:
1 2#
Weight ofCI Paper used:
556ff
Weight ofTrimmed Roll
+
Core at end:
556ff
Weight ofCore at end:
10ff
Weight äfTiimmed CI Paper at end:
546#
Weight of scrap trimmings at end:
10ff
Weight ofCI Paper at end:
546
+
10=
546#
Loss during Trimming
and
Rewinding:
0
Loss during the
manufacture
ofthe 4OFG product
Loss during impregnation
+
Loss during standing
+
Loss
during trimming/rewinding:
21 +0+0=21ff
Loss during the entire manufacturing process:
(21/318)x 100=6.60
Page 4 of
4
Emission
Tests
at Manual Coater
Printing
and
impregnatingLiner boards with Corrosion Inhibiting Formulations
1. Ferro-PakA Formulation; 4 Skids ofLiner Boards were treated
with
the Ferro-Pak A
formulation.
Weight ofFerro-PakAformulation (CI Solution) at start ofrun:
153#
Skid #1:
Weight ofLiner board
+
Skid:
568ff
Weight ofSkid:
59ff
Weight ofSkid
+
coated LinerBoard:
579#
Weight ofCI Solution Used:
11#
Skid #2:
Weight ofLinerboard
+
Skid:
533ff
Weight ofSkid:
38ff
Weight ofSkid
+
coated
Liner Board:
547ff
Weight ofCI SolutionUsed:
14ff
Skid #3:
Weight ofLinerboard
+
Skid:
544ff
Weight ofSkid:
30ff
Weight ofSkid
+
coated LinerBoard:
556ff
Weight ofCI Solution Used:
‘
12ff
Skid #4:
Weight ofLiner board
+
Skid:
555ff
Weight of Skid:
48ff
Weight of Skid
+
coated Liner Board:
570ff
Weight ofCI Solution Used:
15ff
Total Weight ofCI SolutionUsed:
(11+ 14+ 12+ 15)
=
52#
Weight ofCI Solution
remaining at end ofrun:
1 00#
Loss ofCI solution:
153ff
-
(100#
+
52#)
=
1ff
or0.65
Page 1 of 2
Emission
Tests
at Manual Coater (conttL)
2. Ferro-Pak W formulationwas used to treat
1 skid ofLiner Board
Weight ofFerro-Pak W formulation (CI solution) at start ofrun:
136#
Skid #1:
Weight ofLinerboard
+
Skid:
8 14ff
Weight ofSkid:
31ff
Weight ofSkid
+
treatedLiner Board:
872ff
Weight ofCI SolutionUsed:
58ff
Weight ofCI Solution remaining at end ofrun:
77#
Loss ofCI solution:
136ff
-
(77#
+
58ff)
=
1# or 0.74
Page 2 of
2
Emission
Tests
at Rewinder #1
Printed,
impregnated as produced CI Master rolls
are
re-rolled into smaller roll sizes (most times
trimmed to specific widths).
Trial
1.
Weight ofCI Master roll:
835#
Weight ofrewound Rolls:
798ff
Weight ofTrimmings
+
Core:
38ff
Total Weight after rewinding: (798
+
38ff)
836ff
Process Loss(
Emission):
(Weight
of
CI Master roll)
-
(Weight ofrewound Rolls
+
Weight ofTrimmings+ Core) /
(Weight ofCI Master roll)
)
(835ff)
-
(798#
+
38ff)! 835#
=
-0.001 1ff or -0.12
Trial 2.
Weight ofCI Master roll:
851#
Weight ofrewound Rolls:
812ff
Weight ofTrimmings
+
Core:
40ff
Total Weight afterrewinding: (812
+
40#)
=
852ff
Process Loss (
Emission):
(Weight ofCI Master roll)
-
(Weight ofrewound Rolls
+
Weight ofTrimmings+ Core) /
(Weight ofCI Master roll)
(851ff)-(812#+40#)/ 851ff
=
-0.00l1# or-0.12
Page 1 of 2
Emission Tests at Rewinder #1 (contd.)
Trial
3.
Weight of
CI
Master roll:
850ff
Weight ofrewound Rolls:
809ff
Weight ofTrimmings
+
Core:
,
45ff
Total Weight after rewinding:
(809
+
45#)
=
854ff
ProcessLoss (
Emission):
(Weight of CI
Master
roll)
-
(Weight ofrewound Rolls
+
Weight of
Trimmings+ Core) /
(Weight
of CI
Master roll)
(850#)
-
(809ff
+
45#) /
850#
=
-0.0047ff
or -0.47
Trial 4.
Weight ofCI Master roll:
869#
Weight ofrewound Rolls:
837#
Weight ofTrimmings
+
Core:
32ff
Total Weight after rewinding:
(837
+
32#)
=
869ff
ProcessLoss(
Emission):
(Weight ofCI
Master
roll)
-
(Weight
of
rewound Rolls
+
Weight
of
Trimmings+
Core) /
(Weight ofCI Master
roll)
(869ff)
-
(837ff
+
32ff) / 869ff
=
Off or 0
Page 2 of
2
)
Emission Test at Sheeter #3
3SF CI Treated as produced master roll being sheeted to 34” x 37”; Width ofroll: 37” wide
Weight ofCI master Roll
1: 767ff
Weight of CI master Roll 2: 726#
Total Weight ofCI master rolls:
1493ff
Weight ofCI Paper remaining on master Roll
1:
480ff
Weight ofCI Paper remaining on master Roll 2:
523ff
Total Weight of CI Paper remaining on
master
rolls:
1003#
Weight
of
Scraps:
3ff
Total Weight ofCI paper used from master rolls: (1493-3)
-
(1003
)=~
487#
Weight of Truck:
196#
Weight
ofTruck
+
Sheeted
CI Paper:
686ff
Weight ofSheeted CI Paper:
686
-
196
=
490#
Loss in Weight
(
emission):
(487-490) /487
=
-
0.006
or
-
0.62
Emission Tests at Guillotine Cutter
Paper Sheets from Sheetermachines being cut to precise sizes and placed. in boxes.
Trial
1.
Weight of
CI Paper sheets received from Sheeter machine:
Weight ofCI Paper
+
Skid
=
1888#
Weight ofSkid
=
23ff
Weight ofCI Paper received
=
1865ff
Weight ofCI Paper cut to precise sheets:
Skid 1:
Weight ofCI Paper cut
+
boxes:
=
1097ff
Weight ofboxes:
=
66ff
Weight
ofCI Paper cut:
=
103 1#
Skid 2:
Weight ofCI Paper cut
+
boxes:
=
658#
Weight ofboxes:
=
48ff
Weight ofCI Paper cut:
=
610ff
Total Weight ofCI Paper cut:
(Weight ofCI Paper cut,
Skid!
+
Weight ofCI Paper
cut,
Skid2)=
1031 +610=
1641#
Weight of
Trimmings
(duringthe
cutting
process):
Weight ofDumpster
+
Paper
Trim
=
943ff
Weight ofDumpster empty:
=
719ff
Weight ofPaper Trim:
=
224#
Process Loss (
Emission):
((Weight of CI Paper received))
-
((Weight ofCI Paper cut,
Skid!
+
Weight ofCI Paper cut,
Skid 2)
+
(Weight ofPaper Trim))
I
((Weight ofCI Paper received))
(1865ff)
-
((1641#)
+
(224ff))
/1865ff
=
Off or0
Page
1 of
2
Emission
Tests
at Guillotine Cutter (contd.)
Trial 2
on Second
Cutter:
Weight ofCI Paper from Sheeter machine:
=
1804ff
Skid
1:
Weight ofCI Paper
cut
+
boxes:
=
461ff
Weight ofboxes:
=
59ff
Weight ofCI Paper cut:
=
402ff
Skid 2:
Weight of
CI Paper cut
+
boxes:
=
461#
Weight ofboxes:
=
43ff
Weight of
CI Paper cut:
=
418ff
Skid 3:
Weight ofCI Paper
cut
+
boxes:
=
447ff
Weight ofboxes:
=
44ff
Weight ofCI Paper cut:
=
403ff
Skid4:
Weight ofCI Paper cut
+
boxes:
=
450ff
Weight ofboxes:
=
44ff
Weight ofCI Paper cut:
=
406ff
Total Weight ofcut CI Paper: (402+418+403+406)
=
1629ff
Weight ofTrimming (during the cutting process):
=
175ff.
Process Loss (
Emission):
((Weight
ofCI Paper from Sheeter machine))
-
((Total Weight ofcut CI Paper)
+
(Weight of
Trimming)) / (Weight ofCI Paper from Sheeter machine)
(1804#)
-
((1629
+
175ff))
I
(1804ff)
=
Off
or 0
Page 2
of 2
Weight Loss in Time of CI As Produced Master Rolls
Roll
1,
35MP1,
39” wide.
As Produced Master Roll Weight:
85
1#
Weight after 6 days:
85 1#
•
Loss ofWeight
(
emission):
0
Roll 2,
35MP1,
39” wide.
As Produced Master Roll Weight: 836ff
Weight after 6 days:
835ff
Loss ofWeight
(
emission):
1# or 0.12
~
As Produced Master Roll Weight:
11
15#
Weight after
5
days:
1113ff
Loss ofWeight
(
emission):
2ff or 0.18
Roll 4, 50A, 50.5” wide.
As Produced Master Roll Weight:
1 138#
Weight after
5
days:
.
1 136#
Loss ofWeight
(
emission):
2ff or 0.18
Roll
5,
50 A,
50.5”
wide.
As Produced Master Roll Weight:
1 137#
Weight
after
5
days:
1 136#
Loss ofWeight
(
emission):
1# or 0.0 1
Roll 6, 50 A,
50.5”
wide.
As Produced
Master
Roll Weight:
1144ff
Weight after
5
days:
1 144ff
Loss ofWeight
(
emission):
0#
Page
1 of
4
Weight Loss in Time of CI As Produced Master Rolls
Roll 7,
35MP1,
39” wide.
As Produced Master Roll Weight: 85O#
Weight after 7 days:
850#
Loss ofWeight
(
emission):
Off
Roll 8,
35MP1,
39” wide.
As Produced Master Roll Weight: 869#
Weight after 3 days:
869ff
Loss ofWeight
(
emission):
Roll 9,
35MP1,
39” wide.
As Produced Master Roll Weight: 852ff
• (
~
Weightafter 3 days:
85 1#
•~‘
Loss ofWeight
(
emission):
1# or 0.12
Roll
10, 35A,
36.5”
wide.
As Produced Master Roll Weight: 728ff
Weight after 1 days:
727#
Loss ofWeight
(
emission):
1# or 0.14
Roll
11,
35A, 36.5”
wide.
As Produced Master Roll Weight
767#
Weightafter
1 days:
767#
Loss ofWeight
(
emission):
0#
*Nijpabe~gerror: there was no Roll
12
Roll
13, 35A, 41” wide.
As Produced Master Roll Weight: 1002#
Weightafter 7 days:
.
1002#
Loss ofWeight
(
emission):
Page 2 of
4
Weight Loss in Time of CI As Produced Master Rolls
Roll
14, 30A, 37” wide.
As Produced
Master
Roll Weight:
1062ff
Weight
after
14 days:
1062#
Loss
ofWeight
(
emission):
Off
Roll 15,
30A, 37” wide.
As ProducedMasterRoll Weight:
775#
Weight
after
14
days:
775ff
Loss ofWeight
(
emission):
Off
Roll
16,
35F, 37” wide.
As Produced Master Roll Weight: 741.#
Weight after 21
days:
741#
Loss ofWeight
(
emission):
Off
Roll
17, 3SF, 37” wide.
As
Produced Master Roll Weight:
833ff
Weight after
21
days:
832#
Loss ofWeight
(
emission):
1ff or 0.12
Roll
18,
35A, 49” wide.
As Produced Master Roll Weight:
1002#
Weight
after
14 days:
•
1002#
Loss ofWeight
(
emission):
Off
Roll
19, 4OPCA, 39” wide.
As Produced Master Roll Weight: 987#
Weight after
14 days:
987#
Loss
ofWeight
(
emission):
0#
Page 3 of
4
Weight Loss in Time of CI As Produced Master Rolls
Roll 20, 4OPCA, 39” wide.
As Produced Master Roll Weight: 874#
Weight after 21
days:
875#
Loss
ofWeight(
emission):
-1ff or
-0.11
Roll 21,
35MPJ.,
39” wide.
As Produced Master Roll Weight:
525#
Weight
after
21
days:
525ff
Loss ofWeight
(
emission):
O#
Page 4 of 4
PROOF OF
SERVICE
I, the undersigned, on oath or
affirmation
state that I have served on the date ofAugust 22,
2003, the attached Post-Hearing
Brief, by fax and U.S. Mail to Charles E. Matoesian and by
U.S. Mail upon the following persons:
Charles E. Matoesian
Division
ofLegal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, IL
62794-9276
Bradley P. Halloran
Hearing Officer
Iffinois
Pollution Control Board
James R.
Thompson Center
Suite 11-500
100 West Randolph
Chicago, IL
60601
SUBSCRIBED
TO
AND SWORN BEFORE ME
TH1S~(PDAYOF AUGUST, 2003
NO
Y PUBLIC
OFFICIAL
SEAL
JANET
M.
POLACEK
NOTARY
PIJBUC,
STATE OFIWNOIS
MYCOMMISSION
EXPIRES 3.27.2004
TIllS FILING
IS
MADE
ON RECYCLED PAPER
CH1
10538050.4
