LER~(’c

flflrr~

BEFORE THE

ILLINOIS POLLUTION CONTROL BOAJA

~ 2 ~

2093

STATE OF

Con

trt~J

~

AS

03’

)

(Adjusted Standard-Air)

IN THE MATTER OF:

PETITION OF CROMWELL-PHOENIX,

INC.

FOR AN ADJUSTED

STANDARD FROM 35

III. Adm.

Code Subpart F, Section 218.204

(c)

(the “Paper Coating Rule”)

To:

See Attached

Service List

)

)

)

NOTICE OF FILING

PLEASE TAKE NOTICE that

I have today filed with the Office ofthe

Clerk of the

Illinois

Pollution Control Board the PETITION

FOR ADJUSTED STANDARD OF

CROMWELL-PHOENIX, INC., and APPEARANCE OF QUARLES &

BRADY, copies of

which are herewith served upon you.

PROOF OF SERVICE

1, the undersigned,

on oath state that I have served the attached

PETITION FOR

ADJUSTED STANDARD OF CROMWELL-PHOENIX,

INC.

and APPEARANCE by

U.S. Mail

upon the persons listed on the attached service list this

29th

day ofMay, 2003.

$1~r~~/flv

~

~frine

M. Landow-Esser

Janine M. Landow-Esser

Monica M.

Tynan

QUARLES & BRADY LLC

500 W. Madison Street, Suite 3700

Chicago, Illinois 60661

312.715.5055

This filing

is submitted on recycled paper.

~ser,Attorney

May 29, 2003

QBCH!\307772.

I

---

RECEIVED

CLERR’~

OFFICF.

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

MAY

292003

STATE OF

ILLINOIS

Pollution

Contra! Board

IN

THE MATTER OF:

)

)

AS

______

PETITION OF CROMWELL-PHOENIX,

INC.

)

(Adjusted Standard-Air)

FOR AN ADJUSTED STANDARD FROM

35

)

Ill.

Adin, Code Subpart F, Section 218.204 (c)

)

(the “Paper Coating Rule”)

)

APPEARANCE

Quarles & Brady

LLC

by its

attorneys, Janine M. Landow-Esser and Monica Tynan,

hereby files its

APPEARANCE in this proceeding, on behalfofCromwell-Phoenix, Inc.

Mrnne M. Lando’I-Esser

May 29, 2003

Janine M. Landow-Esser

Monica Tynan

QUARLES

& BRADY LLC

500 W. Madison

Street

Suite 3700

Chicago, Illinois 60661

312.715.5055

This filing

is submitted on recycled paper.

Qnc,-1h307740. i

---

SERVICE LIST

Illinois Pollution Control Board

James R. Thompson Center

Suite 11-500

100 West Randolph Street

Chicago, Illinois 60601

David BloonTherg

Air Quality Planning Section

—

MC39

Illinois

Environmental Protection Agency

1021 North Grand Avenue East

Springfield, IL 62794

Bureau of Air

Illinois Environmental Protection Agency

1021

North Grand Avenue East

Springfield, Illinois 62794

Division of Legal Counsel

Illinois Environmental Protection Agency

1021

North Grand Avenue East

Springfield,

Illinois 62794-9276

Qi3CHI\338463.1

This filing is submitted

on recycled

paper

---

RECEIVED

TRADE

SECRET

CLERKS OFFICE

(st~

)~c~o~

~

~

MAY

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7

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2003

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CONFIDENTIAL

___

_____________

BEFORE THE ILLINOIS

POLLUTION CONTROL BOARD

IN THE MATTER OF:

)

AS

____

Petition of Cromwell-Phoenix, Inc.

)

(Adjusted Standard)

for an Adjusted Standard from 35

)

Ill. Adm. Code Subpart F, Section

2 18.204 (c)

)

(the “Paper Coating

Rule”)

)

PETITION

FOR

ADJUSTED STANDARD

CROMWELL-PHOENIX,

Inc.

(“CROMWELL”),

through

its

attorneys,

Quarks

&

Brady

LLC,

pursuant

to

35

III. Adm.

Code

Subpart

ft

Section

104.400

et

seq., and

Section

28.1

of the Illinois

Environmental Protection

Act,

415

ILCS

5/28.1

(the “Act”), respectfully

submits

this

Petition

for

Adjusted

Standard

(“Petition”)

to

the

Illinois

Pollution

Control

Board

(the

“Board”)

seeking

an

adjusted

standard from the VOM

content

Limitations of

35111. Adm.

Code

Subpart

F

Section

218.204(c)

as

those

rules

apply

to

the

emissions of

volatile

organic

material

(“VOM”)

from

CROMWELL’s

corrosion

inhibiting

(“Cl”)

packaging

materials

production

facility in Alsip, Cook County, Illinois.

I.

PROCEDURAL HISTORY

CROMWELL

began

production

at

its

Alsip

facility

in

early

2001.

Following

an

inspection

by

the

Illinois

Environmental

Protection

Agency

(“IEPA”)

and

an

exchange

of

correspondence,

IEPA

issued

Violation

Notice

A-2001-00265

dated

November

20,

2001.

Among

other

things,

the

Violation

Notice

alleged

that

CROMWELL

had

failed

to

demonstrate

compliance with

the

reasonably available

control

technology (“RACT”) emission limitations

set

forth

in 35111. Adm.

Code 218, Subpart F,

applicable to paper coating operations.

338419.1

This

filing is submitted

on

rccyclcd

paper

---

CROMWELL

held

telephonic

meetings

with

representatives

of

the

Illinois

Environmental

Protection

Agency

(“IEPA”)

to

discuss

the Violation

Notice,

and

submitted

its

Compliance

Commitment

Agreement

to

IEPA

on

February

19,

2002.

The

Compliance

Commitment Agreement explained that the VOM

in

CROMWELL’S

products acts as more than

a mere carrier for active

ingredients.

The VOM acts as a paper softener, improves paper folding

qualities,

dissolves

and

retains

corrosion

inhibitor

compounds

and

facilitates

their

gradual

migration

to

the customer’s

wrapped

metal

parts

over

a prolonged period of time.

Thus

while

CROMWELL

advised

IEPA

that

it

was

attempting

to

find

coating

formulations

that

would

comply

with

the

applicable

RACT

standards,

it

also

advised

that

reformulation

was

likely

to

impair product quality

and

could, because ofthe need to utilize

dryers to

drive off added water,

ironically have

the undesirable

effect

of increasing

emissions of VOM.

CROMWELL

noted,

additionally,

that

because it prints

on

the

majority of its products before

applying

the corrosion

inhibiting

solutions,

its

printing/coating operations

are regulated by

35

Ill.

Adm.

Code

Subpart

H,

Section 218.401

governing printing.

IEPA responded

by

issuing

its

Notice of Intent to

Pursue

Legal

Action

on

March

19,

2002.

CROMWELL

held

another

telephonic

meeting

with

IEPA

and

strongly

urged

that

a

representative of IEPA visit its

facility so

that the agency could

view

first hand the operations

in

question.

Mr.

David

B.

Bloomberg,

a

coatings

specialist

with

IEPA’s

Air

Quality

Plaiming

Section,

visited

the

facility

on

May

9,

2002.

Following

the

facility

visit

and

subsequent

discussions with IEPA, both parties agreedthat CROMWELL would file this Petition.

CROMWELL

submitted

a

Clean

Air

Act

Permit

Program

(“CAAPP”)

application

to

IEPA

on

March

29,

2002.

That application

demonstrates

that

CROMWELL

is

a

true

minor

-9-

---

source.

CROMWELL has requested that IEPA issue a lifetime air operating permit. The CAAPP

application currently is under review at IEPA.

II.

A.

Standard

From Which Relief Is Sought (Section 104.406(a))

CROMWELL requests

that

the

Board

grant CROMWELL

an

adjusted

standard

from

35

Ill.

Adm.

Code

Subpart

F,

Section

218.204(c)

(the “Paper Coating

Rule”) as this

rule

applies

to

the

emissions

of

VOM

from

CROMWELL’S

operations

in

Alsip,

Cook

County,

Illinois.

These rules became effective on August

16,

1991.

The Paper

Coating

Rule

from

which

CROMWELL

seeks and

adjusted standard

requires paper coaters

to

utilize coating

materials containing no more than

2.3

pounds of VOM

per

gallon of coating

applied

(excluding

water).

In

the

alternative,

the

source

may

utilize

a

capture

system

and

control device which

achieves

an

81

reduction

in the

overall

emissions of

VOM

from

the coating line,

and

a

90

reduction

of the captured

VOM emissions,

or achieve

VOM reductions that are equivalent to the limitations

of 35

IAC 2 18.204.

See 35

Ill.

Adm.

Code

Subpart F,

Section

2 18.207.

As will be demonstrated herein, CROMWELL cannot use compliant coatings, and

the approved control technologies will work only at unreasonable costs

and

with nominal

VOM

reduction

benefit;

as such, they are not RACT for CROMWELL.

B.

Nature of Regulation

of General Applicability (Section 104.406(b))

The

regulations

from

which

CROMWELL

seeks

an

adjusted

standard

were

among those promulgated

to

implement Section

182(d) of the Clean Air Act,

42

U.S.C.

7401

et

seq.

which,

among

other things,

requires

individual

states

with

severe

ozone

non-attainment

areas

to

adopt RACT

regulations

applicable

to

sources of VOM within the non-attainment area.

-3-

---

As mandated by the Clean Air Act, the Board

established the requirements described in the Paper

Coating Rule.

The

Chicago-area severe

ozone non-attainment

area includes

sources located

in

Cook,

DuPage,

Kane,

Lake,

and Will

counties, Oswego

Township

in

Kendall County,

and

Aux

Sable and

Goose

Lake Townships in

Grundy County.

CROMWELL is

located

in

Cook

County

which is part of the Chicago-area designated severe ozone

non-attainment area.

CROMWELL is a minor source and is seeking a lifetime air operating permit.

C.

Level ofJustification (Section 104.406(c))

The

regulations

of

general

applicability

from

which

CROMWELL

seeks

an

adjusted standard

do not specify a level ofjustification for

an adjusted standard.

D.

Facility and Process Description (Section 104.406(d))

1.

General Information

CROMWELL

is

an

Illinois

corporation

located

in

Alsip,

Cook

County,

Illinois.

CROMWELL employs

31

people and operates in

a

98,000 square

foot building.

The building was constructed

in

1965;

CROMWELL began operations

in

the building in

early

2001,

CROMWELL’S equipment

is

approximately

40

years

old.

CROMWELL

believes

that

it

is

the

only

manufacturer of corrosion

inhibiting

packaging

materials

in

Illinois.

2.

Process Description

CROMWELL

produces

corrosion

inhibiting

packaging

materials

by

-4-

---

In most

cases

various

images

are printed on

the kraft paper

prior to

the

application

of

the

CI

solutions.

These

images

include

the

CROMWELL

logo,

lot

number, product usage

instructions,

and graduated

lines for measurement purposes.

The

images

are

applied

using

an

in-line

flexographic

printing

cylinder

and

water

based

tiexographic inks.

3.

~issions

The

only

emissions

of

regulated

pollutants

from

the

production

of

the

corrosion inhibiting packaging materials are the relatively low emissions of VOM.

None

of the

VOM

compounds

used

are

defined

as

Hazardous

Air

Pollutants

under

Section

112(b) of the Clean Air Act.

CROMWELL selects the impregnation coating and

carrier

constituents

based upon

their ability

to be

retained

in the product for a prolonged period

-5-

---

of time.

Therefore, the emissions of VOM are

very

low

by design.

Low vapor

pressure

VOM carrier compounds

are utilized,

and the finished packaging material

is rewound on

a

cylindrical

core

immediately

after

the

solutions

are

applied,

thereby

physically

encapsulating

the product

and

further

impeding

the

volatilization of the

liquid

fraction

components.

In

addition,

the

vast

majority

of

the

packaging

products

are

produced

without

using

dryers.

Less

than

10

of CROMWELL’S

products

require

the use

of

infra-red

(“IR”)

dryers.

IR

drying

is

required

when

the

CI

solution

contains

a

greater

percentage of water.

The

excess

water must

be

driven off using

the IR

dryers.

It

is

important

to

note

that

since

both

water and

VOM will

be

driven off concurrently,

VOM

emissions

will increase

as the amount

of drying that

is

required increases.

Gravimetric

tests

have

been

performed

to

determine

the

weight

loss

and

emissions

from

the

CI

packaging production processes,

including storage.

In the most

recent tests,

the weight of

the

virgin

paper

used.

CI

solution

applied,

and

the

final

products

produced

were

determined over

periods

that represent their

typical holding

times

in

the CROMWELL

facility.

The gravimetric data demonstrate that the overall

VOM emissions

are less

than

5

of the weight

of CI

solution

applied.

This

emission

factor

assumes that

the

VOM losses are proportional to their composition in the liquid fraction of the CI solution.

In fact, the water will likely preferentially volatilize relative to

the VOM components due

to its

higher vapor pressure.

Therefore, the VOM emission factors usedby CROMWELL

can be

considered worst case.

It is clear that the VOM emissions

from the CI solution are

very low due to

their low volatility

and their effective retention in the paper substrate.

-6-

---

Based

on

these

emission

factors,

total

VOM

emissions

from

the

CROMWELL facility were no more than approximately

5

to 6

tons per year for calendar

years 2001

and 2002.

Typical hours of operation are approximately 2900 hours per year.

Projecting operations

to

8760 hours per

year,

and

continuous

full

web width

maximum

operation of all

production units,

potential

emissions

from

the

facility are

less

than

25

tons

per

year,

including

ancillary

mixing

and

handling

operations.

Therefore,

the

CROMWELL facility is

a simple minor source.

CROMWELL

has

been

working

on

Cl

solution

reformulations

in

an

attempt

to

reduce

the

as-applied

VOM

content

(less

water)

to

as

great

a

degree

as

practicable,

while

still

providing

sufficient

solids

dissolution,

retention,

and

migration.

However, as the amount of water in

the solutions is

increased,

so does the need to

utilize

the IR

dryers

to

drive offthe excess water.

Along with the increased

evolution of water

will

be

an

associated

proportionate

increase

in

VOM

emissions

for

the

equivalent CI

product produced. This

is counterproductive to the goal ofVOM emissions reduction.

4.

Pollution Control Equipment

CROMWELL does not employ the use of any pollution control equipment

in its operations.

5.

Permit Status

At the request of

IEPA, CROMWELL submitted a Clean Air Act

Permit

Program

(“CAAPP”)

application

on

March 29,

2002.

Although

a

CAAPP application

was submitted,

CROMWELL

is a minor source.

Accordingly,

in its CAAPP application

CROMWELL

requested

that

a

lifetime

air

operating

permit

be

issued

for

the

CROMWELL facility.

The

CAAPP

application

is

under

review

within IEPA.

During

-7-

---

the

course

of

discussions

between

IEPA

and

CROMWELL

concerning

the

CAAPP

application

and Notice of Violation A-2001 -00265, IEPA and

CROMWELL

agreed that

CROMWELL should

submit

this

Petition

for Adjusted

Standard.

It

is

CROMWELL’s

understanding that

its air operating permit will be

issued upon the Board’s issuance of its

Opinion and Order on this

Petition.

6.

General Description of the Local

Non-Attainment Area

CROMWELL

is

located

in

an

industrial

area

in

Alsip,

Illinois

on

Ridgeway

Avenue.

The nearest school

or residential area is

approximately

I

mile

from

the CROMWELL facility.

The city ofAlsip

is

located in

Cook County, Illinois,

which is

part of the Greater Chicagoland

Severe-17 Ozone

non-attainment area designated under

40 CFR

81.314, as defined by USEPA pursuant to

Section

107 ofthe Clean Air Act.

E.

Cost of Compliance and Compliance Alternatives (35 IAC 104.406(e))

Achieving compliance with the applicable limitations of 35

IAC Part 218

Subpart

F requires that either the VOM content ofthe CI Solutions

be reduced, or that add-on

controls be

applied.

The

technical

and

economic

feasibility

of these

two

options

for

the

CI

packaging

production operations

at CROMWELL are discussed below.

I.

CROMWELL’s Operations Were Not Contemplated by Applicable Rules

Achieving the VOM content

levels

in

the CI coatings that are called for in

the

applicable

section

of

35

IAC

Part

218

Subpart

F

(35

IAC

2 18.204(c))

is

not

practicable for functional, environmental, and economic reasons.

Unlike

conventional coating operations, where

VOM solvents

are used as

carriers

of

pigments

and

other

solids,

and

the

VOM

solvents

are

intended

to

be

evaporated, the VOM components in CROMWELL’S

CI solutions

are intended to remain

-8-

---

in

the

CI

packaging

products

in

order

to

perform

their

essential

corrosion

inhibiting

functions.

As

such,

CROMWELL

has

inherent

economic

and

product

performance

incentives

to

ensure

that

the

VOM

components

are

retained

in

the

product

and

not

emitted.

Therefore,

the high

molecular weight,

low

volatility VOM components in the CI

Solutions

are

selected

by

CROMWELL

to

enhance retention

in

the product,

and

not

be

emitted, by design.

It

is

important

to

note that

the

35

IAC

Part

218

Subpart

F paper coating

standards

are

based

on

the

Control

Techniques

Guideline

(CTG)

titled

“Control

of

Volatile

Organic

Emissions

from

Existing

Stationary

Sources

—

Volume

II:

Surface

Coating

of Cans,

Coils,

Paper,

Fabric,

Automobiles

&

Light

Duty

Trucks” dated

May

1977

(EPA-450/2-77-008).

In Section

5.0 of this

document (Paper Coating),

it describes

the paper coating process as follows (Page

5-1):

“In organic solvent paper coating, resins

are dissolved

in

an

organic

solvent or

solvent mixture

and

this

solution

is

applied

to

a

web

(continuous roll)

of paper.

As the coated web is

dried,

the solvent evaporates and

(lie coating cures.”

(Emphasis

added).

Clearly,

for conventional coaters, the purpose of

the

solvent is to

act

as

a carrier

for the pigments

and resins.

In such a case the intent is

for

the

solvent

to

be

evaporated,

leaving

the

solids

to

dry

and/or

cure

as

the

surface

coating

on

the

paper

substrate.

In

the

case

of

CROMWELL,

the

liquid

organic

components

are

intended

to

be

impregnated

into

and

remain

with

the

paper product.

They are intended to

become an integral

component ofthe product.

This

type ofproduct

clearly was

not contemplated at the time the CTG for paper coating was developed.

Further, on page

5-13 of the paper coating CTG,

it describes how the vast

majority of solvents

used in conventional paper coating operations are evolved during the

-9-

---

application,

drying,

and

curing

steps.

“Many

plants

report

that

96

percent of solvent

introduced

to

the coating

line

is recovered.

Part of the solvent remains with the finished

product

after it

has

cured

in

the

oven.

Some

coaters

estimate that

2

or

3

percent

of

solvent

remains

in

the

product.”

This

again

differentiates

the

conventional

coating

operations

contemplated

by

the

paper

coating

CTG

from

the

type

of

CI

packaging

production operation at CROMWELL.

CROMWELL applies the CI solution to

the kraft

paper substrate

with

the

intent

that

the

vast

majority of the CI

solution constituents

will

remain in

and

become

an

integral part of the

final product.

While

conventional coating

operations drive off96 percent or more ofthe solvent applied, the CI packaging materials

produced by

CROMWELL

retain

over

95

of

the organic

liquids applied,

since these

organic

liquid

components

are

an

integral

part

of

the

product.

It

is

clear

that

CROMWELL’S type of operation

and

their products were

not

contemplated

in the

CTG

for the paper coating industry.

It is

important to understand that the presence ofthe VOM components in

the

CI

solutions

and

CI

products

provides

an

essential

corrosion

inhibiting

function.

These VOM components are themselves corrosion

inhibiting,

and they serve to

facilitate

the

gradual

migration

of other corrosion

inhibiting

solids

present

in

the

CI

packaging

products onto the customer’s wrapped metal parts over

a prolonged period oftime.

In

addition,

it

is

undesirable

for

the

CI

products

manufactured

by

CROMWELL

to

contain

excess

water,

as

the

presence

of residual

water

in

the

CI

products

promotes

corrosion.

Excess

water

also

causes

unacceptable

expansion

of the

paper

fibers

resulting

in

the product

becoming

wrinkled

and

welted,

as well as

the cut

sheets

becoming

curled.

This

makes

the

products

very

difficult

to

handle

by

-

10-

---

CROMWELL

personnel

and

their customers,

and

results

in

the

inability

to

achieve

a

good

wrap on

the

metal

items

that

are being protected

by

the

CI

papers.

Therefore,

if

additional

water was utilized

in lieu of some of the VOM components

in the

CI

solution,

additional

supplemental heated

drying operations would be required

in

order to

drive off

the

excess

water.

Not

only

would

additional

energy

be

consumed

in

doing

this,

but

additional VOM would be

evolved in the process.

The VOM would evaporate

along with

the

excess

water,

thus

increasing

the

net

overall

emissions

from

the

facility.

CROMWELL asserts that this would result in

a detriment to

the environment,

and would

negatively impact the economic viability ofthe CI production operations.

A projection of VOM emissions

changes

was made

in

order

to

approximate

the

emissions impact

resulting

from

a reformulation of the

CI

solutions

to

the 2.3

lbs

VOM

per gallon

level

required under

35

IAC

218.204(c).

The emissions

projection was

based

on

an

extrapolation of the VOM emissions

factor established

at the current CI

solution

VOM

contents,

vapor

pressures

and

ambient

operating

conditions,

and

applying

the

increased

constituent

vapor

pressures

at

the

elevated

temperatures,

and

the

decreased

VOM contents ofthe CI

solutions.

Based on heating the substrate

to a minimum of 54°C

(129°F),the VOM emissions of the reformulated

CI solutions are projected

to increase by

a

factor of approximately

7.8

times

above

that of the current

formulations.

In such

a

case, annual VOM emissions would

increase from the current

5

or

6 tons per year,

up to

approximately

39

tons per year, or higher.

Actual substrate temperatures will likely need

to

be

considerably

higher than

54°C,probably

in

excess of 65°C (150°F),in

order

to

sufficiently drive off the excess water.

Therefore, VOM emissions would

accordingly be

even

higher.

Again,

it

is

important

to

emphasize

that

the

intent

of the

CI

solution

-11-

---

impregnation

process

is

to

retain

the

VOM

constituents

in

the

substrate.

The

use

of

elevated process temperatures

is counterproductive

to this goal.

2.

Add-On Controls Are Not Economically Reasonable

CROMWELL’S

consultant,

ERM,

Inc.,

analyzed

the

technical

and

economic feasibility

of the application of add-on

control

devices to

CROMWELL’S

CI

coating

operations.

See

Reasonably Available Control

Technology

(“RACT”) Analysis

by ERM,

Inc.

at Exhibit A attached hereto.

The technically feasible control options were

determined

to be oxidation and a combination carbon adsorption/oxidation system.

As

can be

seen

in

the RACT

analysis

in

Exhibit

A, the

costs of installing

add-on oxidation or carbon adsorption/oxidation controls at CROMWELL are excessive.

Table

2 of Exhibit A summarizes the annualized costs

associated with the application of

these control technologies.

The annual cost per ton of VOM controlled for each of these

options ranges from

approximately

$25,000

to

$70,000.

This

is well above the level that

would

be considered reasonable under

a

conventional RACT demonstration.

Also, these

costs

do not

consider the costs

associated with

compliance demonstration

testing,

which

likely

would

be

on

the

order

of $40,000

to

$50,000.

In addition,

while the annualized

costs

are themselves

excessive, the initial capital outlay would also be prohibitive and the

ongoing

annual

cost

of the controls

would

be

on

the

order

of $375,000

to

$560,000.

These

costs

are clearly excessive,

given

that

the

actual

level

of VOM emissions

to

be

controlled is on the order of 5

or 6 tons per year.

F.

Proposed Adjusted Standard (35 JAC

104.406(1))

CROMWELL

proposes

the

following

adjusted

standard

for

adoption

by

the

Board:

-

12-

---

CROMWELL

may

continue

to

operate

its

corrosion

inhibiting

packaging

materials production operations as long as:

1.

The total

actual

VOM emissions

from

the CROMWELL

facility do

not

exceed 25 tpy.

2.

The

Versil

Pak

wax

laminating

coatings continue

to

meet

the applicable

VOM content limitations under

35

IAC Part 218

Subpart F.

3.

The

web

fed

and

sheet

fed

Cl

coating

and

printing

lines

use

only

Corrosion

Inhibiting

solutions

whose

as-applied

VOM

contents do

not

exceed

8.3

lbs

VOM per gallon,

less water.

4.

CROMWELL shall

operate

in

full

compliance

with

all

other

applicable

provisions of 35

IAC Part 218

Subpart F.

5.

CROMWELL shall

continue

to

investigate viable

reduced

VOM content

CI

coatings

and,

where

practicable,

shall

substitute

such

coatings

as

long

as

such

substitution

does

not

result

in

a

net

increase

in

VOM

emissions.

An

annual

report

summarizing the activities

and

results

of these investigatory

efforts

will be

prepared by

CROMWELL and submitted to the IEPA.

6.

CROMWELL shall operate in full compliance with the Clean Air Act.

7.

CROMWELL shall continue to report all annual emissions

to

the IEPA.

-

13

-

---

G.

The

Quantitative

and

Qualitative

Impact

of

CROMWELL’S

Activity

IAC 104.406(g))

Due

to

the

nature

of

the

VOM

components

used

in

the

CI

solutions

at

CROMWELL,

less

than

5

tons

of actual

VOM per

year

are

emitted

from

that

portion of their

production operations.

Approximately

5

to

6 tons

per year ofactual VOM are typically

emitted

from

the entire

plant,

including

the Versil

Pak

wax laminating

operations.

This

is

a relatively

small contribution

to

the

local

air shed

when compared to

the hundreds of thousands

of tons of

VOM emitted each year in the Chicagoland Nonattainment Area.

In addition, if CROMWELL were to

attempt to

utilize reduced VOM content CI

coatings,

VOM

emissions

would

actually

increase.

As

previously

described,

if water

were

utilized

in

the

CI

solutions

in

lieu

of some of the VOM components,

additional

supplemental

heated drying would be

required

in order

to

drive off the

excess

water.

This

would result

in

an

increase

in

VOM

emissions

for

the

same

product

produced,

since

there

would

be

additional

VOM

driven

off

along

with

the

excess

water.

Also,

there

would

be

additional

energy

consumption required to perform the increased supplemental drying.

As described in Exhibit

A at page 9, if the most economical add-on controls were

applied

to

the

CI

coating

operations

at CROMWELL, the associated

energy

and

environmental

impacts would

be

substantial

in

comparison

to

the

small

net reduction

in

VOM

emissions.

In

order

to

control

the

15.21

tons

per

year

of potential

VOM

emissions

from

the

CI

coating

operations,

approximately

13.5

million

cubic

feet

of natural

gas

will

be

burned,

resulting

in

emissions of over 800

tons of CO2

(a greenhouse gas), 0.67 tons of NO~(an acid rain precursor,

criteria

pollutant,

and

an

ozone

precursor),

and

0.57

tons

of CO

(an

acute

toxic

and

criteria

pollutant).

In

addition,

over

120,000

kWhr

of

electricity

would

be

consumed

annually.

-

14-

---

Therefore,

the

deleterious

energy

and

environmental

impacts

would

be

substantial,

while

the

benefits ofVOM reduction would be minimal.

H.

Justification (Section

104.406(h))

As

previously described, the Paper Coating

Rule

did

not

contemplate the

issues

pertaining

to

manufacturers

of

CI

materials

when

the

rule

was

promulgated.

Moreover,

compliance

with

the

Paper

Coating

Rule

would

undermine

the

quality

and

efficacy

of

CROMWELL’s

products.

Compliance

would

necessitate

the

addition

of

water

to

CROMWELL’s

formulae.

As

residual

water

is,

obviously,

undesirable

for

CROMWELL’s

products,

CROMWELL would

be

forced

to

use supplemental

IR

dryers to

drive offthe

excess

water.

This

extra step

in

the manufacturing process would

have the unintended

and

unwanted

effect of driving off additional VOM and

increasing the net overall emissions

from

the facility.

Thus,

CROMWELL’s

compliance

with

the RACT

standards

is

not

feasible

without incurring

extraordinary cost

and

expense, compromising product quality

and

functionality,

and

increasing

the

overall

VOM

emissions

from

the

facility.

The

RACT

adjusted

standard

proposed

by

CROMWELL

is justified

because

it

is

technically feasible,

economically

reasonable,

and

will

have

no

significant

adverse

impact

on

the

ambient

air

quality

in

the

Greater

Chicagoland

Nonattainment Area.

I.

Consistency

with

Federal Procedural Requirements (Section

104.406(i))

I.

Consistency with Federal Law

By granting the proposed adjusted standard, the Board will not violate any

provisions of the Clean Air Act.

CROMWELL’s operations

and

the appropriate RACT

requirements

applicable

to CROMWELL are subject to

this

proceeding.

Pursuant to

the

Act

and the Clean Air Act, the Board

is empowered to

determine what constitutes RACT

-

15-

---

for

CROMWELL.

Accordingly,

under

its

authority

to

adopt

RACT

regulations,

the

Board may grant the requested relief consistent with

federal law.

2.

Federal Procedural Requirements

Under federal law, the Board’s grant ofthe adjusted standard requested by

CROMWELL

will be submitted

to

the USEPA

for inclusion as

a RACT rule specific

to

CROMWELL

in

the

State

Implementation

Plan

for

Illinois.

As

such,

the

adjusted

standard will comport with federal

procedural requirements.

J.

Hearing (Section 104.406(j))

CROMWELL requests a hearing in this matter before the Board.

K.

Supporting Documents (Section

104.406(k))

Supporting documents cited in

this Petition

are

attached hereto as Exhibits A

and

B.

Ill.

SECTION 28.1(C)

FACTORS

Under

Section

28.1(c)

of

the

Act,

415

ILCS

5/28.1,

the

Board

may

grant

individual

adjusted

standards

upon

adequate

proof

that:

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 any

applicable

federal law.

-

16-

---

A.

The

Factors

Relating

To

CROMWELL

Are

Substantially

and

Different

CROMWELL’S

operations

are

unique

in

Illinois.

Examination

of the

CTG

published for the paper coating industry demonstrates

clearly that CROMWELL’S operations are

distinct

from

those

that

the

IEPA sought

to

regulate

when it promulgated

35

Ill.

Adm.

Code,

Subpart

F, Section

2 18.204 (c).

Thus the factors relating to CROMWELL are substantially and

significantly different than those pertaining to typical paper coaters.

B.

The Existence ofThose Factors JustifIes an Adjusted Standard

As

discussed

fully

in

this

Petition,

CROMWELL

has

investigated

a

number

of

compliance

options.

The

compliance

alternatives

investigated

include

experiments

with

reformulated

CI

coatings

and

the installation of add-on

controls.

These alternatives

have

not

proven

to

be

technically

feasible

or economically

reasonable.

Under

the

circumstances,

the

requested adjusted standard

is technically and economically justified as the only means available.

C.

The

Adjusted

Standard

Will

Not

Result

in

an

Adverse

Environmental

Impact or Health Effect

As

discussed

previously

in

this

Petition, the requested

adjusted standard will not

have

an

adverse environmental

impact or health

effect.

CROMWELL

is

a

minor

source,

and,

based

upon

information

and

belief,

is

the

only

CI

material

manufacturing

facility

located

in

Illinois.

By definition, CROMWELL’s

emissions

will have only a minor impact on

air quality

within the Greater Chicagoland Nonattainment Area.

-

17-

---

U.

The

Proposed Standard is Consistent

with Applicable Federal Law

The proposed adjusted standard

is consistent with

federal

law as discussed

in this

Petition.

The granting of the adjusted standard will

not

violate

any

provision of the

Clean Air

Act

because

no

federal

RACT

standards

have

been

established

that

are

applicable

to

CROMWELL’s

specific operations as a manufacturer ofCI materials.

IV.

CONCLUSION

CROMWELL

requests

that

the

Board

grant

the

proposed

adjusted

standard

as

an

alternative to

the RACT regulations adopted

by the Board in the Paper Coating Rule.

To require

CROMWELL

to

comply

with

the

requirements

of

35

III..

Adm.

Code

Subpart

F,

Section

218.204(c)

et

seq.

would

result

in

substantial

economic

hardship

to

CROMWELL

with

no

corresponding

environmental

benefit.

It

is

not

technically feasible

to

comply

with

the

Paper

Coating Rule as compliant coatings do not meet CROMWELL’s

product efficacy standards, and

because

compliance

could

have

the

reverse

effect

of

creating

increased

emissions

and

environmental

detriment.

Finally,

add-on

controls

are

unreasonably

expensive,

provide

little

environmental benefit, and

have associated significant adverse ancillary environmental impacts.

Pursuant

to

35

Ill.

Adm.

Code

104.406,

CROMWELL

submits

the

technical

report

prepared

by

Environmental

Resources

Management,

Inc.

(Exhibit

A),

and

the

Affidavit

of

CROMWELL (Exhibit B) to verify the facts asserted in this Petition.

-

18-

---

WHEREFORE,

Cromwell-Phoenix,

Inc.

respectfully

requests

that

the

Board

grant

CROMWELL

the

proposed

adjusted

standard

from

35

Ill.

Adm.

Code,

Subpart

F,

Section

18.204(c)

as

those

rules

apply

to

the

emissions

of

VOM

from

Cromwell-Phoenix,

Inc.’s

operations

in Alsip, Cook County, Illinois.

CROMWELL-PHOENIX,

INC.

Janine

M. Landow-Esser

QUARLES

& BRADY LLC

500

W. Madison Street

Suite 3700

Chicago, Illinois 60661

May 29, 2003

-

19-

---

EXHIBIT A

---

Cromwell-Phoenix,

Inc.

Reasonably Available

Control

Technology

(RACT) Analysis

IlPinois

EPA

JO No. 031

003 AOP

May2003

Alsip, Illinois

TRADE

SECRET

Delivering sustainable solutions

~na more competitive

world

/~9,ili2

~)

S

ERM

---

Cromwell-Phoenix, Inc.

May 2003

RACT Analysis

Page

1

REASONABLY

AVAILABLE

CONTROL

TECHNOLOGY

(RACT) ANALYSIS

A

source specific

RACT

analysis

is

presented herein in support

of a demonstration

of

technological

and

economic

feasibility

of

add-on

pollution

controls

at

the

Cromwell-

Phoenix,

Inc.

(Cromwell-Phoenix)

manufacturing

facility

in

Alsip,

Illinois.

RACT

is

defined as “the lowest

emission limitation that

a particular source is capable of meeting

by

the

application

of

control

technology

that

is

reasonably

available

considering

technological and economic feasibility” (44 FR 53761, September 17,

1979).

Cromwell-Phoenix

is

a manufacturer of corrosion inhibiting packaging materials for the

metal parts

industry.

The corrosion inhibiting packaging materials are produced by

impregnating kraft paper with corrosion inhibiting (Cl) solutions.

The

first

step

in

the

RACT

analysis

is

to

determine

for

the

pollutants

in

question

applicable

control

technologies

that

have

practical

potential

for

this

type

of

manufacturing

operation.

The

control

technologies

are

ranked

in

order

of

overall

control

effectiveness.

If

it

can

be

shown

that

the

most

stringent

level

of

control

is

infeasible on

the

basis

of technical

and

economic factors,

then

the

next most stringent

level

of control

is

identified

and

similarly evaluated.

This iterative

process continues

until

the RACT

level under consideration

is

not eliminated by

technical

and economic

factors.

---

Cromwell-Phoenix,

Inc.

May 2003

RACT Analysis

Page 2

This

RACT analysis generally

follows the “top-down”

BACT analysis process described

in

the

USEPA’s

Office

of

Air

Quality

Planning

and

Standards

(OAQPS)

guidance

documents, and is summarized as follows:

•

Applicable

emission

control

technologies

are

identified

that

have

practical

potential for application to the above described manufacturing operations.

•

An efficiency level

is proposed for add-on

controls that would

constitute RACT.

•

Technically infeasible control options are eliminated.

•

The

remaining

control

technologies

are

ranked

in

the

order

of

overall

control

effectiveness.

•

The

most

effective

control

technology

options

are

evaluated

considering

economic impacts.

•

The most effective control option not eliminated is selected as RACT.

Each of the above steps

is detailed in the following sections.

A.

Identification of Applicable VOC Control Technologies

1.

Condensation

Condensation

is

a

basic separation technique

in

which

a gas stream

containing

VOCs

is first brought to saturation and then the VOCs are condensed to a liquid.

The conversion of

a vapor phase VOC

to its

liquid phase can be accomplished by

sufficiently

lowering

the

gas

stream

temperature

and/or

by

increasing

its

pressure.

The

most

common

approach

is

to

reduce the

temperature

of the

gas

stream at constant pressure.

Condensation

systems

are

effective

only

for

gas

streams

containing

high

concentrations of high molecular weight

VOCs

(e.g.

heavy

oils).

The minimum

VOC

concentration

achievable

at

the

outlet

of

a

condensation

system

is

the

saturation concentration for that particular VOC.

Water is the most common and

cost effective coolant. Therefore,

even moderate VOC removal efficiencies

(50)

are

not

achievable

unless

the

vapors

will

condense

at

relatively

high

temperatures.

The exhaust

stream

at

Cromwell-Phoenix

contains

very

low

concentrations

of

relatively

low

molecular weight

(75

—

145

lbs/lb-mole)

VOCs

which

condense

only

at

very

low

temperatures.

Such

temperatures

are

achievable

only

by

---

Cromwell-Phoenix, Inc.

May 2003

RACT Analysis

Page 3

energy-intensive mechanical

refrigeration of the exhaust

gas

stream. Therefore,

condensation is not a technically feasible option.

2.

Adsorption

Adsorption

is

a process by

which compounds such as VOCs

are retained

on the

surface of a solid.

Physical adsorption is a phenomenon where gaseous or liquid

compounds

adhere

to

the

surface

of a

bed of solid

adsorbent particles

that

are

highly porous

and have

very large surface to

volume

ratios.

Activated carbon

is

one

of

the

most

effective

and

most

common

adsorbents

used

for

removal

of

gaseous VOCs

from industrial

exhaust streams. VOC adsorption

onto

activated

carbon

is

a

physical

process

based

upon

attractive

forces

known

as

Van

der

Waals forces.

The magnitude of these attractive

forces

is

primarily

a

function of

the surface area

of the

gaseous molecules and the amount

of surface area of the

solid

that

is

available

for

adsorption.

Other intermolecular

forces

of

attraction

also affect adsorption

ability. At

equilibrium,

the quantity

of gas that

is

adsorbed

onto

activated

carbon

is

a function of the

adsorption temperature

and pressure,

the VOC

being adsorbed,

and the carbon characteristics such as particle size and

pore structure. Activated carbon

is a particularly

effective adsorbent

for gaseous

VOCs

due

to

its extremely high surface area to weight ratio, and

its pronounced

capillary action.

Carbon

adsorption

removal

systems

are

most

effective

for

VOCs

having

molecular weights between approximately

60 and 180.

The molecules need

to

be

“large”

enough

to develop

sufficient

Van der

Waals forces

with

the

adsorbing

media,

yet they can’t be

so large

that the Van

der Waals

forces are so great that

the molecule cannot be

removed

during

the

desorption cycle.

Therefore,

higher

molecular weight

compounds are too

difficult

to

desorb while lower

molecular

weight compounds experience little to no adsorption. The majority of VOCs used

by

Cromwell-Phoenix

have

molecular

weights

in

this

range,

therefore

they

would

be amenable to effective adsorption and desorption.

Also,

given

the

variety

of the

materials utilized

at Cromwell-Phoenix,

it

is

not

practical

to

recover the

solvents

for

reuse.

Solvent recovery

and

reuse

is

most

---

Cromwell-Phoenix,

Inc.

May

2003

RACT Analysis

Page 4

feasible

for

single

solvent

systems.

Also,

it

is

not

feasible

to

recover

such

a

solvent mixture

via

decantation

since the solvents

are water soluble. Therefore,

the

only

technically

feasible

control

option

would

be

to

utilize

an

activated

carbon adsorption

system

as

a

pre-concentrator, and

then thermally

desorb the

solvents,

directing

the

concentrated

stream

to

a

thermal

oxidizer

for

VOC

destruction.

In such a scenario, the volumetric flow rate of the desorption stream

is typically

10

of the volumetric flow rate of the adsorption stream.

While

the limitations

described above

will

reduce the effectiveness

of a

carbon

adsorption

system

and

will

present

some

safety

hazards,

a

carbon

adsorption

concentrator

in

conjunction

with

a

thermal

oxidation

control

device,

for

the

purpose

of

this

RACT

analysis,

will

be

considered

a

technologically

feasible

control option that will be further evaluated.

3.

Liquid Absorption

The process of absorption generally

refers

to

the intimate contact of a mixture of

gases

with

a

liquid

sorbate

(typically aqueous)

so

that

a part of one or more of

the constituents

in

the

gas stream

will dissolve

in the liquid.

These devices are

referred

to

generally

as

wet

scrubbers

and

they

include

packed

bed,

plate,

counter current and cross-current designs.

The

most

effective transfer

result

for an

infinite

scrubber column

is

to

achieve

equilibrium

between

the

gas-phase

and

liquid-phase

compounds.

While

the

VOCs

used

at

Cromwell-Phoenix

are

soluble

in

an

aqueous

sorbate,

their

exhaust concentrations

are

so

low

that

the scrubber

would

exhibit

a

very

low

transfer

efficiency of the gaseous VOCs into the liquid sorbate.

Also, given the polar nature of the organic materials at Cromwell-Phoenix, these

compounds

would not

be readily separable from

the sorbate liquid

for purposes

of recovery.

Therefore, the only practical

means of disposal would

be discharge

to

the

sewer,

where

some

or

most

of

the

VOCs

that

were

absorbed

may re-

volatilize en route to or at the POTW.

For these reasons, it is concluded that

gas

absorption is not a technically feasible control option.

4.

Oxidation

Complete oxidation

converts

gaseous VOCs

to carbon

dioxide,

water and other

various

products

of

combustion.

Oxidation

systems

include

direct

combustion

flares, as well as two

types

of commercially available oxidation control systems

-

catalytic and thermal. These systems are described separately below.

a.

Flares

---

Cromwell-Phoenix, Inc.

May 2003

RACT Analysis

PageS

A flare is

a

direct combustion

device

in

which air and the combustible gases

in

the

exhaust

stream

react

at

the

burner.

Combustion

must

occur

instantaneously

since

there

is

no

residence

combustion

chamber.

The

principal

factors

affecting

flare

combustion

efficiency

are

the

exhaust

gas

heating

value,

flammability

limits,

density

and

effectiveness

of

flame

zone

mixing.

If the concentration

of VOCs

in the exhaust

is at

or above the lower

flammability

level,

then

utilization

of

a

flare

may

be

appropriate.

For

this

reason,

flares

are

typically

used

only

in

the

steel,

petroleum

and

petrochemical industries, as they are inappropriate for most other industries

due

to lower hydrocarbon concentrations. Since the

expected exhaust stream

VOC concentrations

at Cromwell-Phoenix

will be very

low

(roughly

10

-

15

ppmv), flares are not

a technically feasible

option.

b.

Catalytic Oxidation

Catalytic

oxidation

devices

employ

a

catalyst

bed

that

initiates

oxidation

reactions

at

relatively

low

temperatures.

The

exhaust

stream

is

heated

to

approximately 650°Fand passed through the catalyst bed where the oxidation

reactions are initiated without alteration of the catalyst itself.

For

the catalyst

to

be effective, the active sites upon

which

the VOCs

react must

be

accessible,

and

the catalyst must

be

active.

The

build up

of non-combustible particles,

polymerized

materials,

or reaction

of the catalyst with certain

elements can

either

“mask”

or

“poison”

the

catalyst,

thus

making

it

unavailable

for

initiating oxidation

reactions.

While

it would

be

difficult

to

impossible

to design

a

catalytic oxidation

system

to

preclude

the

possibility

of

the

catalyst

being

masked

or

poisoned,

it

is

unlikely

that

the

materials

utilized

by

Cromwell-Phoenix

would

render

a

catalytic control

device

ineffective.

However,

given the low

concentrations of

VOCs

in

the exhaust stream, the temperature

rise

across the catalyst bed

(AT)

would be so low that a poisoned or masked catalyst would likely go undetected,

since there may not

be

a significantly

discernible

change in the AT.

Therefore,

the ongoing

performance of a catalytic oxidation system could not be effectively

ascertained. Despite these technical concerns, and

for purposes of completeness,

catalytic oxidation

will be

considered

a

technically

feasible control

option that

will be further evaluated.

c.

Thermal Oxidation

Thermal oxidation is

a reliable and

effective control technology

that converts

gaseous

VOCs

to

carbon

dioxide,

water

and

various

other

products

of

combustion

at

relatively

high

temperatures,

typically

1350

-

1800°F. The

exhaust gases

are

preheated

in

a heat exchanger and

then

directed

into

the

high temperature

combustion chamber where

the VOCs

are oxidized. In the

case

of

Cromwell-Phoenix,

the

VOC

concentration

will

be

well

below

the

level

that

is

necessary

to

provide

any

appreciable

degree

of self-sustained

combustion.

Therefore,

a

supplemental

fuel

burner

system must

be utilized.

---

Cromwell-Phoenix, Inc.

May

2003

RACT Analysis

Page 6

Primary

heat

exchangers

can

be used

to

raise

the

inlet

temperature

of the

exhaust stream, thus reducing the amount of supplemental fuel required.

Two

categories

of

thermal

oxidizers

are

generally

used:

Recuperative

and

Regenerative.

A recuperative thermal oxidizer uses either a shell-and-tube or

a

plate-to-plate

heat

exchanger

for

heat

recovery,

while

a

regenerative

thermal oxidizer uses a ceramic medium that

is usually stored

in two or more

separate chambers.

Some regenerative

thermal oxidizers employ

a single bed

design with

a

mobile high temperature

oxidation zone. The recuperative-type

thermal oxidizers

operate

with

a

heat

exchanger

effectiveness of up

to

70,

while

regenerative

thermal

oxidizers

employ

heat

exchangers

having

an

effectiveness of up

to 95.

Both

of

these

types

of

thermal

oxidizers

are

technologically

feasible

for

application

at

Cromwell-Phoenix.

Since

the

exhausts

will

contain

low

concentrations

of

VOCs

at

ambient

temperatures,

the

regenerative

thermal

oxidizer

will likely

be

the

more appropriate

control option

from

an

economic

stand point. This is due to its

greater energy recovery capability. However, both

recuperative

and

regenerative

control

systems

will

be

further

evaluated

as

technologically feasible options.

Also, the recuperative system will be evaluated

for use in

conjunction with the carbon adsorption pre-concentrator.

B.

Froposed Efficiency Level of Add-on Controls Which Constitute RACT

Based

on

the majority

of RACT determinations, and

on the control device

efficiency

requirements

of 35

IAC

Part

218

Subparts

F and

H,

a minimum

90

VOC control

efficiency

will

be required

of

an

add-on

control

device.

In

addition,

a

minimum

overall

control

efficiency

of

81

is

required

to

meet

the

Subpart

F

RACT

requirements,

therefore

the

capture

efficiency

should

be

at

least

90

(Overall

Control

Efficiency

(81)

=

Capture

Efficiency

(90)

x

Control

Device

Efficiency

(90)).

To

ensure

the

achievement

of

a

minimum

90

capture

efficiency,

a

permanent

total enclosure

(PTE)

would

likely need

to

be

established

for

the three

coating operations, and perhaps also

to include

the mixing tank.

The costs

for such

an

enclosure are included

in

order

to present

a complete RACT

cost

analysis.

An

approximation of the

cost to fabricate a Permanent

Total Enclosure is

$137,000.

For

purposes of this RACT analysis, it is

assumed

that a control device efficiency of 90

with

100

VOC

capture

efficiency

are

achieved,

and

the costs

of fabricating

and

exhausting a Permanent Total Enclosure are included.

C.

Elimination of Technically Infeasible VOC Control Options

On the basis

of the criteria described above in

Section C,

the following VOC control

options have been determined to be technically infeasible:

---

Cromwell-Phoenix, Inc.

May 2003

RACT Analysis

Page 7

1.

Condensation

2.

Liquid Absorption

3.

Flares

Therefore, these control options will not be further evaluated.

D.

Ranking of Remaining Control Technologies

The remaining three control technologies are ranked below

in Table I in the order of

control effectiveness:

Table I

Range of Control

Control Level for

Pollutant

Technology

Efficiency

(°/o)

RACT Analysis

O/~

VOC

Recuperative Thermal

90

-

99

?

90

Oxidation

VOC

Regenerative Thermal

90

-

98

?

90

Oxidation

VOC

Catalytic Oxidation

90

-

98

?

90

VOC

Carbon Adsorption

90

-

98

?

90

Concentrator with

Thermal Oxidation

Control

F.

Evaluation of the Most Effective Control Technologies Not Eliminated

The

most

effective

remaining

control

options

were

evaluated

relative

to

energy,

environmental and

economic impacts.

I.

Economic Impacts

The economic impacts of the above control options were evaluated in accordance

with

the

USEPA’s

OAQPS

Control

Cost

Manual,

by

William

M.

Vatavuk.

Economic

analyses

were

calculated

using

the

most

current

(1999)

version

worksheets

provided

by

Mr.

Vatavuk.

The economic

analysis

anticipates

the

installation of a

single control device for all

controlled processes since this

is

the

most

cost

effective

means

of

control.

It

should

be noted

that,

while

a

single

control device

will

exhibit

the

lowest

economic

costs

for add-on

controls

on

a

$/ton

of

pollutant

controlled

basis,

such

a

configuration

poses

potential

---

Cromwell-Phoenix, Inc.

May

2003

RACT Analysis

Pages

problems

from

an

operational

standpoint.

For

example,

it

would

be

unacceptable to have to shut

down

all

of the controlled operations

if the control

device

requires

preventive

maintenance,

or should

it

malfunction.

Also,

some

costs

such

as ductwork

are

more substantial for

a

central unit than for multiple

control

devices.

Ductwork costs

have not

been included

in this RACT

analysis.

Therefore,

while

a

single central

device

is

the most

cost

effective configuration,

operational and

ancillary factors need

to

be considered

for an

overall

feasibility

determination.

Given

the outcome

of this report, such further in-depth

analysis

is not warranted at this time.

Total annual costs

were determined for the purchase, installation and

operation

of each of the control devices considered.

The total exhaust air flow rate is based

on

the

sum

of the exhaust requirements

of each of the controlled

sources.

The

annual

cost

calculations

for

each

of

the

control

technologies

evaluated

are

included herein.

The

results of the economic cost analyses

for the control

options

evaluated

are

summarized

below

in Table

2.

The annual costs for the control devices are based

on

an

expected life of

10

years and

an

annual interest rate of 7.0.

All

analyses

are

based

on

90

control

of

the

allowed

(potential)

VOC

emissions

that

were

reflected in the March

2002 CAAPP permit

application (Exhibit

200-1) for the

CI

coating operations,

including

the flexo inks

and mixing tanks

(Total

=

16.9

tpy).

Therefore, the annual controlled amount of VOCs is calculated at 15.21

tons.

Table

2

RACT Analysis

-

Overall Plant

Annual Cost per

Ton

Control Option

Total Annual Cost

($)

of VOC Controlled

($)

Recuperative Thermal

1,075,713

70,724

Oxidizer

Regenerative Thermal

468,412

30,796

Oxidizer

558,670

36,730

Catalytic Oxidizer

Carbon Adsorber

376,942

24,783

Concentrator with

a Thermal Oxidizer

---

Cromwell-Phoenix, Inc.

May

2003

RACT

Analysis

Page 9

Based

on

the

annual

costs

per

ton

of

VOCs

controlled

for each of the

control

options

described

above,

none

of

the

control

options

are

deemed

to

be

economically

feasible.

Including

the costs for

the

installation

of ductwork

and

compliance

demonstration

of the control

device and the total

enclosures would

only add

to

the economic infeasibility of each option. Therefore, the actual costs

per

ton of implementing any of the

above control

options

will

be even

higher.

Finally,

as

was

stated

earlier,

while

the

utilization

of

a

single centrally-located

control

device

is

the

most

economically

feasible

option,

it

may

not

be

operationally

feasible

due

to both anticipated

and unanticipated

shut

downs

of

the

control

device.

If

only

a

single

control

device

were

employed,

normal

preventive

maintenance

requirements

or

an

equipment

malfunction

would

require

the shutdown

of

all

CI

coating

operations.

Clearly,

this

would

not

be

acceptable

from

a

production and customer requirement standpoint.

Therefore,

for operational

purposes,

multiple

control

devices would

have

to

be employed

whose costs will be higher than the lowest cost option described above.

2.

Environmental and Energy Impacts

To accomplish

the annual control of

the 15.21

potential

tons

of VOCs

using

the

most

economical control option, approximately

13.5 million cubic feet of natural

gas will

be burned,

resulting in emissions of over 800

tons

of CO2

(a greenhouse

gas),

0.67

tons

of NO~(an

acid

rain

precursor,

criteria pollutant and

an ozone

precursor) and

0.57

tons of CO (an acute

toxic and criteria pollutant). In addition,

over

120,000

kWhr

of

electricity

will

be

consumed

annually.

Therefore,

the

deleterious energy

and

environmental

impacts

would

be

substantial,

while

the

benefits of VOC reduction would

be

minimal.

F.

Selection of the Most Effective Control Option Not Eliminated

All of the most

effective control

technology options

not technically eliminated have

been

shown

to

be

economically

infeasible

since

the

total

annual

costs

for

the

installation

and operation of the least costly option is approximately

$25,000 per ton

of VOC controlled.

It should

be

recalled that

this cost does not

include

the

cost of

ductwork nor does it reflect compliance demonstration

costs (which could

approach

$40,000

-

$50,000) or operationally necessary multiple control devices. Therefore, the

actual control costs

will be considerably

higher.

In

addition, the initial

capital cost

and the substantial annual operating costs would put Cromwell-Phoenix at a serious

economic

competitive

disadvantage.

Therefore,

the

application

of

such

add-on

controls

would

be

detrimental

to

the

viability

of

this

plant.

Finally,

there

are

substantial

environmental

impacts

from

even

the

least

energy

intensive

control

option, including

substantial

emissions

of CO2 from the combustion

of

the natural

gas fuel and VOCs.

G.

Alternative Strategy to Achieve RACT

---

Cromwell-Phoenix, Inc.

May 2003

RACT Analysis

Page 10

Since

the use of add-on controls has been shown

to

be economically

infeasible, it

is

proposed

to minimize

VOC emissions by

continuing to

use Cl coatings that

contain

the lowest

levels

of

VOM possible,

while

still

achieving product

functionality and

quality,

and minimizing VOM emissions from supplemental drying.

The use of non-

VOC solvents such as water, acetone and methyl acetate will

be used to the greatest

degree practicable.

---

C-P RACT

Cost Analysis.xls

5/I

6/2003

Company Name:

Cromwell-phoenix,

Inc.

Location:

Alsip,

Illinois

Process:

CI Paper Coating Operations

TOTAL ANNUAL COST SPREADSHEET PROGRAM

--

RECUPERATIVE THERMAL OXIDIZERS

Describes

the annual operating costs for purchasing,

installing and

operating a recuperative thermal oxidizer to control the above process.

COST BASE DATE: April 1988

ti)

VAPCCI

~2)

3rd Quarter 2001

107.8

INPUT PARAMETERS

--

Gas flowrate

(scfm)

:

20000

--

Reference temperature

(oF)

:

77

--

Inlet gas temperature

(oF)

:

80

--

Inlet gas density

(lb/scf)

:

0.0739

--

Primary heat recovery

(fraction)

:

0.70

--

Waste gas heat content

(BTU/scf)

:

0.061

--

Waste gas heat content

(ETU/ib)

:

0.83

--

Gas heat capacity

(BTU/lb-oF):

0.255

--

Combustion temperature

(OF)

:

1600

--

Preheat temperature

(OF)

:

1144

--

Fuel heat of combustion

(ETU/ib)

:

21502

--

Fuel density

(lb/ftj)

:

0.0408

DESIGN PARAMETERS

--

Auxiliary Fuel Reqrmnt (lb/mm):

10.842

(scfm)

:

265.7

--

Total Gas Flowrate

(scfm)

:

20266

CAPITAL COSTS

Page 1 of

4

Recuperative

---

C-P RACT Cost Analysis.xls

5/16/2003

Equip~nentCosts

($)

Incinerator:

~

0

heat

recovery:

0

© 35

heat recovery:

0

~ 50

heat recovery:

0

5

70

heat recovery:

254,639

PTE Containment or other capital costs

Total Equipment Cost--base:

254,639

--escalated:

343,344

Instrumentation:

0

Sales Tax:

10,300

Freight:

17,167

Purchased Equipment Cost

($)

:

405,145

Direct

Installation Costs:

Foundations

& Supports:

32,412

Handling

& Erection:

56,720

Electrical:

16,206

Piping:

8,103

Ductwork and Insulation:

4,051

Painting:

4,051

Direct Installation Cost:

121,544

Site Preparation:

0

Buildings or PTE:

137,000

Total Direct Cost:

663,689

Page

2 of

4

Recuperative

---

C-PRACT Cost Analysis.xls

5/16/2003

Indirect Installation Costs:

Engineering:

40,515

Field Expenses:

20,257

Contractor Fees:

40,515

Start-Up:

8,103

Performance Test:

4,051

Contingencies:

12,154

Total Indirect Cost:

125,595

Total Capital Investment

($)

:

7e9,284

ANNUAL COST INPUTS

Operating factor

(hr/yr)

:

8760

Operating labor rate

($/hr)

:

16.48

Maintenance labor rate

($/hr)

:

18.13

Operating labor factor (hr/sh)

:

0.5

Maintenance labor factor

(hr/sh)

:

0.5

Electricity price

(s/kwh)

:

0.069

Natural gas price

($/mscf)

:

6.00

Annual

interest rate

(fraction):

0.070

Control system life

(years)

:

10

Capital recovery factor:

0.1424

Taxes,

insurance,

admin.

factor:

0.04

Pressure drop

(in. w.cJ:

19.0

ANNUAL COSTS

Item

Cost

($/yr)

Wt.

Factor

W.F. (cond.)

Operating labor

9,023

0.008

Supervisory labor

1,353

0.001

Maintenance labor

9,925

0.009

Maintenance materials

9,925

0.009

Natural gas

838,016

0.779

Electricity

45,387

0.042

Overhead

18,136

0.017

0.045

Taxes,

insurance,

administrative

31,571

0.029

Page 3 of

4

Recuperative

---

C-PRACT Cost Analysis.xls

5/16/2003

Capital recovery

112,376

0.104

0.134

Total Annual Cost

1,075,713

1.000

1.000

(1

Original equipment costs reflect this date.

2)

VAPCCI

=

Vatavuk Air Pollution Control Cost Index

(for thermal

incinerators)

corresponding to year and quarter shown.

original

equipment cost,

purchased equipment cost,

and

total capital investment

have been escalated to this data via

the VAPCCI and control equipment

vendor data.

Latest indexes included herein.

Costs

for

20000

RACT Cost Summary Table

acf~s.t.em

1 purchased Equipment Cost

(PEC)

405,145

2 Total Direct Cost

(includes

PEC)

663,689

3

Total

Indirect

Cost

4 Total Capital Investment

(=

2+3)

789,284

S Annual Direct Operating Costs

913,630

6 Annual Indirect Operating Costs

49,707

7 Annual Capital Recovery Costs

8 Total Annual Costs

(=

5+6+7)

1,075,713

Oxidizer VOC Control Efficiency

90

Annual VOC Input to the Control Device

16.9 tons

Annual VOC Emissions

Controlled

15.21

Annual VOC Emissions after controls

1.69

Annual Cost of Control Device

$

70,724

S/ton Controlled

Page 4

of

4

Recuperative

---

C-PRACT Cost Analysis.xls

5/16/2003

Company Name:

Cromwell-Phoenix,

Inc.

Location:

Alsip,

Illinois

Process:

CI Paper Coating Operations

TOTAL AN!~DALCOST SPREADSHEET PROGRAM- -REGENERATIVE THERMAL OXIDIZER

(RTO)

Describes the annual operating costs for purchasing,

installing and

operating a regenerative thermal oxidizer to control the above process.

COST BASE DATE:

December 1988

1)

VAPCcI

2)

3rdQuarter200l

110.8

INPUT

PARAMETERS

--

Gas

flowrate

(scfm)

:

20000

--

Reference

temperature

(oF)

:

77

--

Inlet

gas

temperature

(oF)

:

80

--

Inlet

gas

density

(lb/scf)

:

0.0739

--

Primary

heat

recovery

(fraction)

:

0.95

--

Waste

gas

heat

content

(BTU/scf)

:

0.061

--

Waste

gas

heat

content

(ETU/ib)

:

0.83

--

Gas

heat

capacity

(BTtJ/lb-oF)

:

0.255

--

Combustion

temperature

(oF)

:

2000

--

Heat

loss

(fraction)

:

0.01

--

Exit

temperature

(oF)

:

176

--

Fuel

heat

of

combustion

(BTU/lb)

:

21502

--

Fuel

density

(lb/ft3)

:

0.0408

DESIGN PARAMETERS

Auxiliary Fuel Requirement

(lb/mm)

:

1.966

(scfm)

:

48.2

Total

Gas

Flowrate

(scfm)

:

20048

Page1 of 4

Regenerative

---

C-PRACT Cost Analysis.xls

5/16/2003

TOTAL CAPITAL INVESTMENT

($)

3)

(Cost correlations range:

5000 to 500,000 scfm)

PTE Containment or other capital costs

137000

®

85

heat recovery--base:

0

-

-escalated:

0

®

95

heat

recovery--base:

1,016,304

I

I

--escalated:

1,368,558

ANNUAL

COST

INPUTS

Operating factor

(hr/yr)

:

8760

Operatmng labor rate ($/hr)

:

16.48

Maintenance labor rate

(s/br)

:

18.13

Operating labor factor

(hr/sb)

:

0.50

Maintenance labor factor

(hr/wk)

:

1.00

Electricity price

(S/kwh)

:

0.069

Natural gas price

($/mscf)

:

6.00

Annual interest

rate (fraction)

:

0.070

Control system life

(years)

:

10

Capital recovery factor:

0.1424

Taxes,

insurance,

admin.

factor:

0.04

Pressure drop

(in. w.cJ:

20.0

ANNUAL COSTS

Item

Cost

(5/yr)

Wt. Factor

W.F.(cond.)

Operating

labor

9,023

0.019

Supervisory

labor

1,353

0.003

Maintenance

labor

943

0.002

Maintenance

materials

943

0.002

Natural

gas

151,939

0.324

Electricity

47,260

0.101

Overhead

7,357

0.016

0.042

Taxes,

insurance,

administrative

54,742

0.117

Page 2 of

4

Regenerative

---

C-P RACT Cost Analysis.xls

5/16/2003

Capital

recovery

194,852

0.416

0.533

Total

Annual

Cost

468,412

1.000

1.000

(1)

Base

total

capital

investment

reflects

this

date.

2)

VAPCCI

Vatavuk Air Pollution Control Cost Index

(for regenerative

thermal oxidizers)

corresponding

to year and quarter shown.

Base

total capital investment

has been escalated to this date via VAPCCI and

control equipment vendor data.

Latest indexes included herein.

(3)

Source: Vatavuk,

William M. ESTIMATING COSTS OF AIR POLLUTION

CONTROL.

Boca Raton,

FL:

Lewis Publishers,

1990.

COMPARISON OF REECO/DUPONT, COsT-AIR, AND MANUAL RIO COSTS:

(1st

cUr.

‘91

$)

Flow (scfm)

REECo

($)

Manual

($)

a

Manual/REECo

COST-AIR

(5)

b

C-A/REECo

2,000

340,000

371,061

1.09

640,305

1.88

5,000

425,000

423,946

1.00

713,363

1.68

10,000

500,000

512,087

1.02

835,125

1.67

25,000

850,000

776,511

0.91

1,200,413

1.41

50,000

1,500,000

1,217,217

0.81

1,809,225

1.21

100,000

2,850,000

2,098,629

0.74

3,026,850

1.06

a

Escalated from

April.

‘88 to 1st

quarter ‘91

and

multiplied by installation factor

of 1.416

(1.2*1.18).

Range of correlation:

10,000 to

100,000 scfm.

b

Escalated from Dec. ‘88 to 1st quarter ‘91. Costs pertain to 95

heat recovery units.

Range of correlation: 5,000 to 500,000 scfm.

Page3 of 4

Regenerative

---

C-P RACT Cost Analysis.xls

5/16/2003

Costs

for

20000

RACT Cost Summary Table for RTO

scfm

system

1 Total Capital Investment

1,368,558

2 Annual Direct Operating Costs

211,461

3 Annual Indirect Operating Costs

62,099

4 Annual Capital Recovery Costs

194.Pc2

5 Total Annual

Costs

(=

2+3+4)

468,412

Oxidizer VOC Control Efficiency

90

Annual VOC

Input to the Control Device

16.9 tons

Annual VOC Emissions Controlled

15.21

Annual VOC Emissions after Controls

1.69

Annual Cost of Control Device

$

30,796

$/ton Controlled

Page 4 of 4

Regenerative

---

C-PRACT Cost Ana!ysis.xls

5/16/2003

Company

Name:

Cromwell-Phoenix,

Inc.

Location:

Alsip,

Illinois

Process:

CI Paper Coating Operations

TOTAL ANNUAL COST SPREADSHEET PROGRAM--CATALYTIC INCINERATORS

(FIXED)

Describes the annual operating costs for purchasing,

installing

and operating

a Catalytic Oxidizer to control the above process.

COST REFERENCE DATE:

April 1988

Cl

VAPCCI

2

3rdQuarter200l

109.8

INPUT

PARAMETERS

--

Gas

flowrate

(scfm)

:

20000

--

Reference temperature

(oF)

:

77

--

Inlet gas temperature

(oF)

:

80

Inlet gas density

(lb/scf)

:

0.0739

--

Primary heat recovery

(fraction)

:

0.70

--

Waste gas heat content

(BTU/scf)

:

0.061

--

Waste gas heat content

(ETU/ib)

:

0.83

--

Gas heat capacity

(BTU/lb-oF)

:

0.248

--

Combustion temperature

(oF)

:

650

--

Preheat temperature

(OF)

479

--

Fuel heat of combustion

(BTU/lb)

:

21502

--

Fuel density

(lb/ft3)

:

0.0408

DESIGN PARAMETERS

--

Auxiliary Fuel Reqrmnt (lb/mm)

3.870

(scfm)

:

94.9

--

Total

Gas Flowrate

(scfm)

:

20095

--

Catalyst Volume

(ft3)

:

38.9

Page

1 of

4

Catalytic

---

C-PRACT Cost Analysis.xls

5/16/2003

CAPITAL COSTS

Equipment Costs

(5)

--

Incinerator:

@

0

heat

recovery:

0

5

35

heat recovery:

0

5

50

heat recovery:

0

5

70

heat recovery:

344,811

--

Other

(auxiliary equipment,

etc.):

0

Total Equipment Cost--base:

344,811

--escalated:

409,261

Instrumentation

40,926

Sales Tax

12,278

Freight

20,463

Purchased

Equipment

Cost

($):

482,928

Direct Installation Costs:

Foundation

&

Supports

38,634

Handling & Erection

67,610

Electrical

19,317

Piping

9,659

Ductwork &

Insulation

4,829

Painting

4,829

Buildings or PIE:

137,000

Total

Direct

Cost:

764,807

Indirect

Installation

Costs:

Engineering

48,293

Field Expenses

24,146

Contractor

Fees

48,293

Start-Up

9,659

Performance Test

4,829

Contingencies

14,488

Total

Indirect

Costa:

149,708

Page 2

of

4

Catalytic

---

C-P RACT Cost Analysis.xls

5/16/2003

Total

Capital

Investment

($)

914,514

ANNUAL COST INPUTS

Operating

factor

(hr/yr)

:

8760

Operating

labor

rate

($/hr)

:

16.48

Maintenance labor rate

(5/br)

:

18.13

Operating labor factor

(hr/sh)

:

0.0

Maintenance labor factor

(hr/sh)

:

0.5

Electricity price

(S/kwh):

0.069

Catalyst price

($/ft3)

:

650

Natural gas price

(S/mscf)

:

6.00

Annual interest rate

(fraction):

0.07

Control system life

(years)

:

10

Catalyst life

(years)

:

2

Capital recovery factor

(system)

:

0.1424

Capital recovery factor

(catalyst)

:

0.5531

Taxes,

insurance,

admin.

factor:

0.04

Pressure drop

(in. w.cj:

21.0

ANNUAL COSTS

Item

Cost

($/yr)

Nt.

Factor

N.F.(cond.)

Operating labor

0

0.000

Supervisory labor

0

0.000

Maintenance labor

9,925

0.018

Maintenance materials

9,925

0.018

Natural gas

299,160

0.535

Electricity

49,742

0.089

Catalyst replacement

15,110

0.027

Overhead

11,910

0.021

0.057

Taxes,

insurance,

administrative

36,581

0.065

Capital recovery

126,317

0.226

0.292

Page 3

of

4

Catalytic

---

C-P RACT Cost Analysis.xls

5/16/2003

Total Annual

Cost

558,670

1000

1.000

1

Original

equipment costs reflect this date.

2

VAPCcI

=

Vatavuk Air Pollution Control cost

Index

(for catalytic

incinerators)

corresponding

to year and quarter shown.

Original

equipment cost, purchased equipment cost,

and

total capital investment

have been escalated to this date via the VAPCcI and control equipment

vendor data.

PACT Cost Summary Table

1 Purchased Equipment Cost

(PEc)

482,928

2

Total Direct Cost

(includes

PEc)

764,807

3

Total Indirect Cost

149,708

4 Total

capital Investment

(=

2+3)

914,514

S Annual Direct Operating Costs

383,863

6 Annual

Indirect Operating Costs

48,491

7 Annual capital Recovery Costs

126,317

8

Total Annual Costs

(=

5+6+7)

558,670

Oxidizer VOC Control Efficiency

3)

90

Annual

VOC Input to the Control Device

16.9

tons

Annual VOC Emissions Controlled

15.21

tons

Annual VOC Emissions after

Controls

1.69 tons

Annual

Cost

of

Control

Device

$

36,730

perton controlled

Page 4 of

4

Catalytic

---

C-PRACT Cost Analysis.xls

5/16/2003

Company Name:

Cromwell-Phoenix,

Inc.

Location:

Alsip,

Illinois

Process:

CI Paper Coating Operations

TOTAL ANNUAL COST SPREADSHEET PROGRAM-- CARSON ADSORSER CONCENTRATOR W/THERMAL OXIDIZER

This spreadsheet describes the annual operating costs for a carbon adsorption concentrator system

operating

in

coniunction

with

a

recuperative

thermal

oxidizer

controlling

the

10

desorption

stream.

STAGE

I

VOCREMOVAT.

~CAPEON

AnSORPER

CONcEWrRAI0~

COST

BASE

DATE:

Third

Quarter

1989

2

VAPCCI

3

3rd Quarter 2001

105.7

INPUT PARAMETERS:

--

Inlet stream flowrate

(acfm)

:

20000

Inlet stream temperature

(oF)

:

80

--

Inlet stream pressure

(atm)

:

1

--

VOC to be condensed:

Propylene Glycol

--

Inlet hOC flowrate

(lb/hr)

:

3.86

--

hOC

molecular weight

(lb/lb-mole)

:

76.10

--

hOC

inlet volume fraction:

1.665572E05

--

hOC

inlet

concentration

(ppmv):

16.7

--

hOC inlet partial pressure

(psia)

:

0.0002

--

Required hOC removal

(fraction)

0.950

--

Freundlich isotherm equation constants for hOC

(see Table

1 below)

hOC number

(enter Table

1

# or zero,

i

lOll

K:

0.412

M:

0.389

--

Yaws isotherm equation constants

(see Table

2 below)

VOC number

(enter Table

2 #or zero,

if

84

1.40474

0.18738

—0.02663

--

Adsorption time

(hr)

:

8.0

--

Desorption time

(hr)

:

4.0

--

Number of adsorbing vessels:

2

--

Superficial carbon bed velocity (ft/mm)

:

75

--

Carbon price

($/lb)

:

3.00

Page

1 of

10

Carbon Adsorber

-

Recup

---

C-P RACT Cost Analysis.xls

5/16/2003

--

Material of construction

(see list below): 4)

1.3

DESIGN PARAMETERS:

--

Carbon equilibrium capacity--Freundlich

(lb vOC/lb

0.0162

0.3926

--

Carbon

working

capacity

(lb

hOC/lb

carbon):

0.0081

--

Number of desorbing vessels:

2

--

Total number of vessels:

4

--

Carbon requirement,

total

(lb)

7611

--

Carbon requirement per vessel

(lb)

:

1903

Gas flowrate per vessel

(acfm)

:

10000

--

Adsorber vessel diameter

(ft)

:

13.029

--

Adsorber vessel

length

(ft)

:

4.476

--

Adsorber vessel surface area

(ft2)

:

449.87

--

Carbon bed thickness

(ft)

:

0.476

--

Carbon bed pressure drop

(in.

w.cj:

5

1.609

CAPITAL COSTS

Equipment Costs

(5)

--

Adsorber vessels

163,333

--

Carbon

22,833

--

Other equipment

(condenser, decanter,

etc.)

135,321

Total equipment cost

($)--base:

290,259

--escalated:

340,246

Instrumentation:

34, 025

Sales Tax:

10,207

Freight:

17,012

Purchased Equipment Cost

(5)

:

401,490

Direct Installation Costs:

Foundations

&

Supports:

32,119

Handling

& Erection:

56,209

Electrical:

16, 060

Piping:

8,030

Ductwork and Insulation:

4,015

Painting:

4,015

Direct Installation Cost:

120,447

Page 2 of

10

Carbon Adsorber

-

Recup

---

C-PRACT Cost Analysis.xls

5/16/2003

Site Preparation:

Suildings or PTE Constr:

137,000

Total

Direct

Cost:

658,937

Indirect Installation Costs:

Engineering:

40,149

Field Expenses:

20,074

Contractor Fees:

40,149

Start-Up:

8,030

Performance Test:

4,015

Contingencies:

12,045

Total

Indirect

Cost:

124,462

Total

Capital

Investment

(5)

:

783,399

($/acfm)

:

39.2

ANNUAL COST INPUTS:

Operating factor

(hr/yr)

:

8760

Operating labor rate

($/hr)

:

16.48

Maintenance labor rate

($/hr)

:

18.13

Operating labor factor (hr/sh)

:

0.5

Maintenance labor factor

(hr/sh)

:

0.5

Electricity price

($/kwhr)

:

0.069

Recovered hOC value

($/lb):

0.0000

Steam price

(s/bOO

lb)

:

7.50

Cooling water price

(5/1000 gal)

:

0.20

Carbon replacement labor

($/lb)

:

0.05

Overhead rate

(fraction)

:

0.6

Annual interest rate

(fraction):

0.070

Control

system

life

(years)

:

10

Capital recovery factor

(system)

:

0.1424

Carbon life

(years)

:

5

Capital recovery factor

(carbon):

0.2439

Taxes,

insurance,

admin.

factor:

0.04

Page 3 of 10

Carbon Adsorber

-

Recup

---

C-P RACT Cost Analysis.xls

5/16/2003

ANNUAL

COSTS:

Item

Cost

($/yr)

Nt.

Factor

W.F. (cond.)

Operating labor

9,023

0.045

Supervisory labor

1,353

0.007

Maintenance labor

9,925

0.050

Maintenance materials

9,925

0.050

Electricity

3,785

0.019

Steam

887

0.004

Cooling water

81

0.000

Carbon replacement

6,107

0.031

Overhead

18,136

0.091

0.244

Taxes,

insurance,

administrative

31,336

0.158

Capital recovery

107,973

0.544

0.702

Sub-Total Carbon Adsorber Annual costs

198,531

1.000

0.964

Recovery credits

0

Carbon Adsorber Annual costs

(w/credit)

198,531

(5/million acf)

18.89

Notes:

1

This program has been based on data and procedures

in Chapter

4

of

the

OAQPS CONTROL COST MANUAL

(5th edition)

2

Sase equipment costs reflect this date.

3

VAPcCI

=

vatavuk Air Pollution Control Cost Index

(for carbon

adsorbers)

corresponding to year and quarter shown.

Sase equipment

cost,

purchased equipment cost,

and total capital investment have been

escalated to this date via the vAPcCI and control equipment vendor data.

4

Enter one of the following:

carbon steel--b’;

316 stainless steel--

‘1.3’; Carpenter 20

(CB-3)--’l.9’;

Monel-400--’2.3’;

Nickeb-200--’3.2’;

titanium--‘4.5’

5

This

is the carbon bed pressure drop ONLY.

There will be additional pressure drop

through the ductwork

.

For estimating ductwork pressure

losses,

see chapter 10

of

the

OAQPS CONTROL COST MANUAL

(5th edition)

Page 4 of

10

Carbon Adsorber

-

Recup

---

C-PRACT Cost Analysis.xls

5/16/2003

Table

1.

Freundlich Constants

for Selected Compounds

63

Correlation Range

(psia)

hOC

hOC

number

K

M

Temperature

(F)

Minimum

Maximum

Benzene

1001

0.597

0.176

77

0.0001

0.05

Chlorobenzene

1002

1.05

0.188

77

0.0001

0.01

cyclohexane

1003

0.508

0.210

100

0.0001

0.05

Dichloroethane

1004

0.976

0.281

77

0.0001

0.04

Phenol

1005

0.855

0.153

104

0.0001

0.03

Trichboroethane

1006

1.06

0.161

77

0.0001

0.04

Vinyl chloride

1007

0.200

0.477

100

0.0001

0.05

m-Xylene

(low-pressure

1008

0.708

0.113

77

0.0001

0.001

m-Xylene

(high-pressur

1009

0.527

0.0703

77

0.001

0.05

Acrylonitrile

1010

0.935

0.424

100

0.0001

0.015

Acetone

1011

0.412

0.389

100

0.0001

0.05

Toluene

1012

0.551

0.110

77

0.0001

0.05

63

These constants fit the following equation:

Q

=

K(P)~M

where:

Q

=

equilibrium adsorption capacity

(lb/lb carbon)

P

=

hOC

partial pressure

(psia at

1

atm

& listed temperature)

Table

2.

correlation Constants

for Yaws IsothCorrelation Ranges

(ppmv)

voc

hOC

number

A

B

C

Minimum

Maximum

Phosgene

6

-0.64469

0.60428

-0.02986

10

10000

Carbon

tetrachloride

9

1.07481

0.28186

-0.02273

10

10000

Chloroform

11

0.67102

0.36148

-0.02288

10

10000

Formaldehyde

18

-2.48524

0.69123

-0.00375

10

10000

Methyl chloride

21

-1.91871

0.62053

-0.00549

10

10000

Carbon

disulfide

35

-0.18899

0.47093

-0.01481

10

10000

Tetrachioroethylene

39

1.40596

0.20802

-0.02097

10

10000

Vinyl chloride

55

-0.98889

0.66564

-0.04320

10

10000

b,l,2-Trichloroethane

59

1.17163

0.27791

-0,02746

10

10000

Page

5 of

10

Carbon Adsorber

-

Recup

---

C-PRACT Cost Analysis.xls

5/16/2003

Acetonitrile

60

-0.79666

0.63512

-0.02598

10

10000

Methyl

isocyanate

61

-1.07579

0.85881

-0.06876

10

10000

Acetaldehyde

69

-1,17047

0.62766

-0.02475

10

10000

Ethylene glycol

84

1,40474

0.18738

-0.02663

10

121

Ethyl

mercaptan

87

0.00552

0.40506

-0.01802

10

10000

Acrybonitrile

93

0.07669

0.49986

-0.03500

10

10000

Acrolein

97

-0.29632

0.49437

-0.02471

10

10000

1,3-Butadiene

168

-0.03359

0.34764

-0.01297

10

10000

Methyl ethyl ketone

194

0.46525

0.37688

-0.02801

10

10000

n-Butane

213

0,03071

0.34304

-0.01596

10

10000

l,2,4-Trichlorobenzene

331

1.68304

0.09456

-0.00998

10

566

chlorobenzene

336

1.02705

0.30619

-0.03353

10

10000

Nitrobenzene

340

1.64859

0.06109

0

10

329

Benzene

341

0.81119

0.28864

-0.02378

10

10000

Phenol

345

1.45599

0.10349

-0.01086

10

10000

Toluene

466

1.11466

0.20795

-0.02016

10

10000

m-Cresol

469

1.61982

0.04926

0

10

149

o-Toluidine

474

1.58104

0.05475

0

10

339

Styrene

528

1.35701

0.13495

-0.01451

10

8044

m-Xylene

533

1.31522

0.14019

-0.01457

10

10000

o-Xylene

534

1.33404

0.13931

-0.01494

10

8722

p-Xylene

535

1.31115

0.14069

-0.01458

10

10000

71

Constants fit

the

following equation:

Q

=

O.01*1OAA

+

S(bogy

)

+

C(logy

)

A~

where:

Q

=

equilibrium adsorption capacity

(lb/lb carbon)

y

=

VOC concentration

(ppmv at 77

F,

1

atm)

Source:

Yaws,

Carl

L.

et al.,

“Determining VOC Adsorption Capacity,” Pollution Engineering,

February 1995,

pp.

34-37.

Page

6 of

10

Carbon Adsorber

-

Recup

---

C-PRACT Cost Analysis.xls

5/16/2003

TOTAL ANNUAL COST OF THERMAL OXIDIZER FOR DESTRUCTION OF VOcs IN cONCENTRATED DESORPTION EXHAUST STREAM

STAGE

II VOC DESTRUCTION

-

RECUPERATIVE THERMAL OXIDIZER

COST SASE DATE: April 1988

13

VAPCCI

2

3rd Quarter 2001

107.8

INPUT PARAMETERS

--

Gas

flowrate

(scfm)

:

2000

--

Reference temperature

(oF)

:

77

--

Inlet gas temperature

(OF)

:

150

--

Inlet gas density

(lb/scf)

:

0.0739

--

Primary heat recovery

(fraction):

0.70

--

Waste gas heat content

(BTU/scf)

:

0.061

--

Waste

gas heat content

(STU/lb)

:

0.83

--

Gas heat capacity

IBTU/ib-oF)

:

0.255

--

Combustion temperature

(oF)

:

1600

--

Preheat temperature

(OF)

:

1165

--

Fuel heat of combustion

(BTU/lb)

:

21502

--

Fuel density

(lb/ft3)

:

0.0408

DESIGN PARAMETERS

Auxiliary Fuel Reqrmnt

(lb/mm)

:

1.047

(scfm)

:

25.7

--

Total Gas Flowrate

(scfm)

:

2026

CAPITAL COSTS

Equipment Costs

(5)

--

Incinerator:

®

0

heat recovery:

0

Page 7 of

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5/16/2003

C-P RACT Cost Analysis.xls

@ 35

heat recovery:

© 50

heat recovery:

© 70 ~ heat recovery:

Other Capital Costs

Total Equipment Cost--base:

I

I

--escalated:

Instrumentation:

Sales Tax:

Freight:

Purchased Equipment Cost

($)

143, 178

193, 054

0

5,792

9,653

Direct Installation Costs:

Foundations & Supports:

Handling & Erection:

Electrical:

Piping:

Ductwork

& Insulation:

Painting:

Direct Installation Cost:

Site Preparation:

Other

(Specify)

Total Direct

Cost:

Indirect Installation Costs:

Engineering:

Field Expenses:

Contractor Fees:

Start-Up:

Performance Test:

Contingencies:

Total

Indirect

Cost:

16,680

29,190

8,340

4, 170

2, 085

2,085

62,550

271,048

20,850

10,425

20, 850

4,170

2, 085

6,255

64,635

0

0

143,178

208,499

Total Capital Investment

($)

:

335,683

Page8of

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C-P RACT Cost Analysis.xls

5/16/2003

ANNUAL

COST

INPUTS

Operating

factor

(hr/yr)

:

8760

Operating labor rate ($/hr)

:

16.48

Maintenance labor rate

($/hr)

:

18.13

Operating labor factor

(hr/sh)

:

0.0

Maintenance labor factor

(hr/sh)

:

0.5

Electricity price

($/kwh)

:

0.069

Natural gas price

($/mscf)

:

6.00

Annual interest rate

(fraction)

:

0.070

Control system life

(years)

:

10

Capital recovery factor:

0.1424

Taxes,

insurance,

admin.

factor:

0.04

Pressure drop

(in.

w.c.)

:

19.0

ANNUAL COSTS

Item

Cost

($/yr)

Mt.

Factor

W.F. (cond.)

Operating labor

0

0.000

Supervisory labor

0

0.000

Maintenance labor

9,925

0.056

Maintenance materials

9,925

0.056

Natural gas

80,893

0.453

Electricity

4,537

0.025

Overhead

11,910

0.067

0.178

Taxes,

insurance, administrative

13,427

0.075

Capital recovery

47,794

0.268

0.343

Total Annual Cost for Thermal Oxidizer

178,411

1.000

1.000

(1

Original equipment costs reflect this date.

2

VAPCCI

=

Vatavuk Air Pollution Control Cost Index

(for thermal

incinerators)

corresponding to year and quarter shown.

Original

equipment cost,

purchased equipment cost, and total capital investment

have been escalated to this data via the VAPCCI and control equipment

vendor data.

Page9 of 10

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C-P RACT Cost Analysis.xls

5/16/2003

TOTAL ANNUAL COST:

CARBON ADSORBER CONCENTRATOR w/

THERMAL

OXIDIZER

Sub-Total Annual Cost Carbon Adsorber Concentrator

198,531

Sub-Total Annual Cost Thermal Oxidizer VOC Control

178,411

Total Annual Cost Carbon Adsorber/Thermal Oxidizer

376,942

Costs for One

20000

RACT Cost Summary Table

scfm system

1 Purchased Equipment Cost

(PEC)

609,989

2 Total Direct Cost

(includes

PEC)

929,985

3 Total Indirect Cost

189.096

4 Total Capital Investment

(=

2+3)

1,119,082

5 Annual Direct Operating Costs

146,366

6 Annual Indirect Operating Costs

74,809

7 Annual Capital Recovery Costs

155767

8 Total Annual Costs

(=

5÷6+7)

376,942

Oxidizer VOC Control Efficiency

90

Annual VOC Input to the Control Device

16.9 tons

Annual VOC Emissions Controlled

15.21

Annual VOC Emissions after Controls

1.69

Annual Cost of Control Device

$

24,783

$/ton Controlled

Page 10 of 10

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---

IIUIHX2L

---

TRADE

SECRET

C~O~

~

CONFIDENTIAL BUSINESS INFORMATION

BEFORE

THE ILLINOIS POLLUTION CONTROL BOARD

IN

THE MATTER OF:

)

AS_____

Petition of Cromwell-Phoenix, Inc.

)

(Adjusted Standard)

for

an Adjusted Standard from 35

)

Ill. Adm. Code Subpart F, Section

2 18.204 (c)

)

(the “Paper Coating Rule”)

AFFIDAVIT OF FRANCIS HOULIHAN IN

PETITION FOR AN ADJUSTED STANDARD

I Francis Houlihan, declare under penalty ofperjury that the following is true and correct:

1.

I am the President ofCROMWELL-PHOENIX,

E~TC.(“CROMWELL”).

2.

I have served in that capacity since CROMWELL was formed.

3.

CROMWELL is an Illinois corporation located in

Alsip, Cook County, Illinois.

4.

CROMWELL

employs 31

people at this location.

5.

CROMWELL is a manufacturer ofcorrosion inhibiting (“CI”) packaging materials

for the metal parts industry.

6.

7.

CROMWELL believes that it is the only manufacturerofcorrosion inhibiting

packaging materials in Illinois.

8.

CROMWELL produces

CI packaging materials by impregnating kraft paper with

corrosion inhibiting solutions.

QBCHI\338495.

1

---

r

9.

10.

The carrier solution is comprised of high molecular weight Volatile Organic Material

(“VOM”) and water.

11.

The vapor pressures ofthe VOM components are very low

and therefore their

evaporation is minimal.

12.

13.

The purpose ofthe carrier solution is to transport the CI compounds into the paper,

retain them, and ultimately facilitate their gradual migration to the customer’s

wrapped metal parts over a prolonged period oftime.

CI packaging materials have up

to

a five year shelf life.

14.

The only regulated emissions from the production

of CI packaging materials are the

relatively low emissions ofVOM.

CROMWELL selects the impregnation coating

and carrier constituents based upon their ability to be retained in the product for a

prolonged period oftime.

Therefore, the emissions of VOM are very low by design.

15.

Low vapor pressure VOM carrier compounds are utilized and the finished packaging

material is rewound on a cylindrical core immediately after the solutions

are applied,

thereby physically encapsulating the product and

further impeding the volatilization

ofthe liquid

faction components.

In addition, the vast majority (90)

ofthe products

are produced without using dryers.

16.

Infra-red (“IR”) drying is only required when the CI solution contains a greater

percentage ofwater.

The excess water must be driven off using the IR dryers.

This

process also drives off some VOM.

17.

CROMWELL has attempted to

develop a CI solution reformulation which would

reduce the as-applied VOM content (less water) to the greatest degree practicable

while still providing sufficient solids dissolution, retention, and migration.

However,

as the amount ofwater in

the solution is increased, so does the need to utilize the IR

dryers to drive offexcess water.

Along with the increased evolution ofwater will be

an associated proportionate increase in VOM emissions for the equivalent CI product

produced.

18.

Achieving compliance with the applicable limitations of35 IAC Part 218 Subpart F

requires that either the VOM content ofthe CI solutions be reduced or that add-on

controls be applied.

QBCHI\33

8495.1

---

19.

Achieving the VOM content levels in the CI coatings that are called for in 35 IAC

Part 218 Subpart F

(35