ECEIVED
CLERK’S
OFFICE
—
STATEOFILLINOIS
Poflution Control Board
ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
PETITION OF SCA TISSUE NORTH
)
AS 05-04
AMERICA, L.L.C., FOR AN ADJUSTED
)
(Adjusted
Standard
-
Air)
STANDARD FROM:
35111. Adm. Code
)
218.301 and 218.302(c)
)
Prefiled Written Responses to
Questions for SCA Tissue North America, L.L.C.
Pertaining to the Petition
In Compliance with April 28, 2005 Order
McNAMEE, LOCHNER, TITUS & WILLIAMS, P.C.
John
J.
Privitera, Esq.
Attorneys for SCA Tissue North America, LLC
677 Broadway
Albany, New York 12207-2503
Telephone:
(518) 447-3200
DATED:
May
12, 2005
Albany, NewYork
Reproduced on Recycled Paper
C:\DOCUMENTS AND S~TINGS\STROMBEM\LOCALSETTINGS\TEMP\PREFILED
WRITFEN
RESPONSES 541-O5tDOC
Martin
J.
Stromberger, P.E., hereby affirms the truth of the following prefiled testimony.
My business
address and professional
qualifications are
attached
as
Exhibit A.
I
am
generally familiar with the
Alsip
Mifi of SCA
Tissue
North America LLC (SCA)
and have provided technical
support in the
preparation
of
the
pending
Petition
and the
technical
documents
appended
thereto.
Because
the
April 28, 2005 questions generally relate to technical matters, I hereby provide these responses to the
questions posed and will be available atthe hearing on May
17, 2005.
35 IAC 104.406(d)
1.
Is the address on the FESOP in Pet. Exh. D (13101 South Pulaski Rd., Alsip, IL) the address of the
tissue mifi?
Yes.
2.
Would you please identify the downwind area affected?
Is it rural or urban?
The area east of the facffity is urban and primarily industrial (e.g., Clark oil refinery, Robbins waste
incinerator) with some residential.
3.
Please indicate the number of employees at the tissue mill.
There are approximately 68 SCA employees atthe mifi.
4.
The petition on Page 12 states, “SCA utilizes low-VOC photochemically reactive solvents...” Pet.
Exh. B at 15 states that “The cleaning solvent has a
VOC
content of 50 percent.”
Please indicate
what solvents are used to remove the stickies and provide Material Safety Data Sheets (MSDS)
for each.
Please provide a MSDS for the cleaning solventto show the 50
by weight VOM
content.
The MSDS is attached as Exhibit B.
5.
Pet. at 15 mentions USEPA proposed NESHAP at pulp and paper mills.
Do the VOM emissions
from SCA’s cleaning operations include HAPs?
If so, would you please identify what the HAPs
are and what percentage they comprise of the VOMs?
The list of HAPs is attached as Exhibit C and the cleaning solvent contains 0 percent of these
compounds.
2
6.
Please describe how the solvents are stored when not in use.
Are solvent storage containers
vented?
If so, could you please indicate the rate of emissions from the storage containers?
The solvent is delivered in bulk to an outside storage tank.
This solvent storage tankis vented,
however, the vent gases pass through a charcoal ifiter prior to release-to atmosphere.
Based on
USEPA calculation methods and the maximum expected solvent usage rate atthe facifity, potential
VOM emissions from the tank are estimated to be on the order
of
10 pounds per year, not considering
the control provided by the charcoal ifiter.
Considering the ifiter, actual VOM emissions are
negligible, less than 1 pound per year.
7.
How is the solvent application equipment cleaned after use?
External cleaning is limited to paper machine washups or other housekeeping measures.
No internal
cleaning or maintenance of the nozzles is required except during nozzle changeouts as required when
the spray pattern is determined to be less than optimal.
-
8.
How is overspray from the cleaning process handled?
Is overspray captured in a drip pan, or
does it just evaporate?
Whatpercentage of solventused is overspray and what percentage
actually contacts the wire and/or stickies during the soaking stage?
Overspray is wasted cleaning product, so the spray system is designed to minimize overspray.
The
exact percentage of overspray has never beenmeasured.
Virtually all of the solvent spray contacts the
extremely fine mesh multi-layered wire during the soaking stage.
Solvent does drip from the wire during the cleaning process.
In addition,
after soaking, high pressure
water sprays are used to dislodge stickies from the wire.
This solvent and water mixture falls into the
catchall or saveall pans beneath the paper machine and is routed through the water treatment system
on the paper machine.
9.
Pet
Exh. H states that the wire solvent cleaning process “emitted fewer than 4 pounds per hour
of volatile
organic compounds on a rolling monthly average in 2002...”
Please indicate the
quantity (pounds) used during asingle cleaning cycle, the duration of a cleaning cycle, and the
frequency of cleaning cycles.
Pet.
Exh. B
at12 states that “wire cleaning is required once to twice
per month but can be required more frequently....and felt cleaning is very infrequent.”
Exh. H
“SolventTrial Results” states that the removal of stickies emitted fewer than 4 lb/hr of VOCs on a
rolling monthly average in 2002.
Please indicate the rate of VOMsused on a strict hourly basis,
during the actual cleaning operation.
Please compare this result to the 8 lb/hr limit of 302.201.
During the last reporting year, SCA had fewer than 100 applications of wire cleaning solvent.
Based
on information from 1995 presented in the Title V permit application for the facility, the facifity
applied approximately 267pounds of solventper cleaning cycle.
The actual solvent application
requires approximately 15 minutes; however, the entire cleaning cycle requires a little over an hour.
3
Therefore, VOM emissions have historically been as high as
133 pounds per hour (as the solvent is
50
VOM) duringa cleaning cycle, which is substantially greater than the 8 pound per hour limit of
302.201. The frequency of cleaning cycles depends entirely on the level of stickies present, the type of
paper being produced, andmany other factors.
Two cleaning cycles mayhave to be completed
“back-to-back” or there maybe weeksbetween cleaning cycles.
Based on 2004 throughput information, the typical amount of solvent applied was approximately 160
pounds per solvent cleaning cycle.
The cleaning solvent application time is similar to that noted
above from the Title Vpermit application.
As a result, the VOM emissions
during a cleaning cycle in
2004 were typically around 80 pounds per hour, which is substantially greater thanthe 8 pound per
hour limit of 302.20 1.
35 IAC 104.406(e)
Pet. at 16 states, “SCA has also concluded that no cleaning alternatives are available that provide
acceptable cleaning characteristics and can reduce VOMemissions below 8 poundsper hour or be
nonphotochemically reactive.”
(Pet. at 16.)
SCA states that it has implemented pollution prevention
changes that have helped to reduce the number of solvent cleanings.
Pet. at 22 states, “...stickies are a
substantial barrier to producing the recycled tissue rolls and the solvent cleaning operations with low
VOM materials and controls described herein are the only demonstrated technology for reducing
and/or eliminating that problem.”
10.
Are you famifiarwith the use of low impactpulping to keep stickies largeso that mechanical
cleaning equipment (such as screens and dissolved air flotation) wifi operate more efficiently?
Have you considered low impact pulping as part of a stickies control program?
Yes.
Low impact pulping would not eliminate stickies.
Low impact pulping would provide, some
reduction in stickies in a manner similar to the changes already implemented at the facility such that
solvent usage on ayearly basis would be somewhat lower.
Solvent usage on a yearlybasis is already
very low.
However, because low impact pulping would not eliminate stickies, some solvent spraying
would stifi be required.
Because of the size
of the paper machine wires, the amount of solvent used
during a spray event would stillbe in excess of 8 pounds per hour.
11.
Has SCA evaluated any chemical products to keep smallstickies from agglomerating into larger
more troublesome sUckles?
Yes, the Buckman Labs Optimyze® is currently in use at the facility.
See response to
15 below.
4
12.
Pet. at 12 mentions the use of a pulp detacifier and wire polymer.
Would you please describe the
role these have in stickies control?
Has SCA evaluated the use of cationic wire andfelt
passivation to keep stickies from accumulating on the felts or wires?
The pulp detacifier binds with the contaminants or “stickies” so that the “stickies” will not adhere to
the wire.
Use
of the detacifier decreases the number of solventcleanings by reducing the amount of
“stickies” that collect on the wire. The wire polymer is a catiortic polymer that is applied to the paper
machine wires to coat the wires and minimize the tendency for stickies to adhere to the wires.
Because of the low solvent application requirements for the felt, feltpassivation has not been
necessary at SCA.
13.
Pet. Exh.
16 contains the results of the solventtrial tests.
Would you please explain what is meant
by “Stripped the wire, no effect on stickles.”
The wire polymer was chemically removed from the wire, but the stickies were not removed.
14.
Besides alternative cleaning solvents, did SCA consider other approaches for chemically
controffing stickies?
Please address approaches such as fixation
of stickies to fiber in sheet
formation, dispersing stickies using solvent and surfactant blends, polymeric stabilization,
stabffized enzymes, or a combination of these?
Besides the alternative solvent trial tests
presented in Pet. Exh. H, haveyou evaluated any of these other approaches on a bench or pilot
scale?
Yes.
SCA has evaluated numerous procedural, raw material, and equipment changes over the past 15
years to reduce VOM emissions associated with stickles control.
Testing associated with these
changes has almost always been conducted on the paper machine because bench and pilot scale
evaluations have not been able to effectively simulate realmachine-conditions.
All of the approaches enumerated have beenevaluated for implementation.
Some
of the approaches
are being utilized (see response to Questions
11, 12, and 15, for example).
Only Optimyze®
and wire
polymer additives have been demonstrated to be significantly effective.
15.
Is SCA familiar with anew enzyme process given the USEPA’s Presidential Green Chemistry
Challenge Award
(2004Alternative Solvents/Reaction Conditions Award) known as Optimyze®
and manufactured by Buckman Laboratoties?
Yes, this product is currently used in SCA’s paper manufacturing operation.
5
16.
Were any representatives for manufacturers of stickies control products contacted and invited to
SCA’s facffity for guidance on a stickies control strategy andproduct selection or otherwise
closely involved in the trial tests?
Yes. Several manufacturing representatives havebeen actively involved in the selection and
application of stickies control products.
17.
Please describe how is the feltcleaned.
Are the same solvents used to clean the felt and wires?
Would you please indicate howmuch solvent is used to clean the felt and how often?
The felt is continuously cleaned and conditioned with heated water to provide optimum
moisture removal from the sheet.
High pressure showers and low pressure flooded nip
showers are the primary vehicles for the felt cleaning system.
If this equipment is not
sufficiently effective at cleaning the felt, an alkaline cleaning solution is applied.
The paper
machine was
designed
to allow for solvent application
to clean the felt, but cleaning solvent
is not currently applied
to the paper machine felt.
35 IAC 104.406(f)
18.
Would you please discuss the corresponding costs for the process and operational changes that
SCA has implemented to achieve the 93
reduction in VOM emissions?
No cumulative costhas been assigned to this ongoing effort to reduce VOM emissions.
The work has
spanned 15 years, including three owners of the mill and hundreds of equipment and operational
initiatives.
35 IAC 104.406(g)
19.
How much did SCA spend to redesign and change equipment and cleaning operations to reduce
VOM emissions from 182 tpy to
10 tpy?
See response to Question 18 above.
20.
Exh. B, App, E, Page 1 of each
of the Control Costs Results Summaries, indicates that costs are
based on maximum annual production of 90,000 ADTP per year.
The FESOP in Pet. Exh. A on
Page 4 defines ADT as air-dried ton
of finished paper.
Please describe how ADTP relates to
Machine Dried Tons (MDT) and ifthere is aconversion for ADTP to MDT.
ADT and IVIDT are essentially the same.
6
21.
Pet. at 3 indicates the current production rate is 200 tons per day of product.
Would you please
clarify if this air dried tons (ADT) or machine dried tons (MDT)?
ADTand MDT are essentially the same.
22.
The petition at 13 indicates that current production rates approximately-doubled from the 1990
rate of 36,900 MDT/year whichwould be
73,800 MDT/year.
On Page
14, the petition states that
the VOM emission rate for the 1997-2000 timeframe averaged 0.6 lb VOM/MDT for the solvent
cleaning operations.
Multiplying (36,900 MDT x 2) x 0.6 lb VOM/MDT yields 22 tons/year.
However, Exh.
B at 15 indicates the total maximum VOM emissions from solvent cleaning
operations are
10 tpy, and the actual rate is closer to 7 tons per year.
Would you please clarify
how the emission rate of 0.6 lb VOM/MDT and the current production rate of 200 tons per day
yield the VOM emissions of 7 to
10 tons per year.
The emission rate of 0.6 lb VOM/IvIDT and the production rate of 200 tons per day do not correlate to
a VOMemission rate of 7 to 10 tons per year.
The information from Exh. B at 15 documenting
maximum VOM emissions from solvent cleaning operations as
10 tp-y and actual VOM emissions
from solvent cleaning as closer to
7 tons per year is reflective of operations during the year 1999.
Georgia-Pacific Corporation, the previous owner of the facility interpreted solvent usage trends for
1999
as typical and stated that maximum solventcleaning VOM emissions were 10 tons per year.
In
2001, Georgia-Pacific Corporation submitted documentation to the EPA stating that theybelieved
1999 emissions were inordinately low and that maximum solvent cleaning VOM emissions would
likely be more on the order of 25 tons per year.
23.
Could you describe how other tissue paper mills using recycled stock handle stickies control?
Similar machines producing similar grades of paper at other SCA facilities are using similar
approaches to handle stickies control forrecycled stock.
24.
Pet. at 20 states,
“...
.there wifi be no adverse incremental impact on the environment as aresult of
the Adjusted Standard....”
The IEPA’s recommendation concurs, stating, “the proposed adjusted
standard will not impair compliance with the applicable ozone standards...”
(Rec. at 15).
In a
previous similar adjusted standard from 218.301, AS
04-1 for Crownline Boats, Inc., the petitioner
provided an Ambient Air Quality Impact Analysis to support its assertion that Crownline’s
impact on ambient air quality is insignificant.
(AS 04-1, App. 16).
The instant petition does not
provide an analysis to show no adverse incrementalimpact on ozone.
Would you please provide
an ozone impact analysis using an appropriate methodology such as the USEPA Method,
“VOC/NO~
Point Source Screening Tables” by Richard D. Scheffe, September 1988 (see attached).
7
The maximum permitted VOM emissions from the facffity are 75 tons per year (tpy).
Of this facffity-
wide emission level, approximately 25 tpy are associated with solvent cleaning VOM emissions.
If it
is conservatively assumed that compliance with the Subpart G requirements would result in the
complete elimination of solvent cleaning VOM emissions, the incrementalVOM emission increase for
use in conjunctionwith the “VOC/NO~
Point Source Screening Tables” (Scheffe Table) would be
approximately 25 tpy.
This may certainlybe an overstatement of the VOM emission reductions that
would be achieved by Subpart G.
No NO~
emissions are associated with the solvent cleaning
operations.
The Scheffe Table (Table 1 of the document) does not address VOM emissions as low as
25 tpy.
The
lowest entry in the table is 50 tpy.
For a VOM to NO~
ratio of greater than 20, as appropriate for the
solventcleaning emissions, the estimated increment in ozone concentration is 0.004 parts per million
(ppm).
To determine the equivalent ozone concentration incrementfor a 25 tpy VOM emission rate,
we multiplied the ozone concentration incrementassociated with a50 tpy VOM emission rate (0.004
ppm) by the ratio of emission rates (25 tpy/5O tpy) to generate an ozone concentration incrementof
0.002 ppm associated with the solvent cleaning operation.
Based on the Scheffe Table, 0.002 ppm would be the maximum increase in ozone concentration
associated with the proposed adjusted standard.
The eight-hour ozone standard is 0.08 ppm.
Thus,
the maximum increase in ozone concentration would be 2.5 percent of the applicable standard.
Becausecompliance with Subpart C would not completely eliminate solvent cleaning VOM emissions
at the facility, the actual increase in ozone would be less than this value.
25.
If SCA were to experience a growth in production, could you please comment on how such
growth would affect the VOM emissions on an annual basis in comparison to the data provided
for the 2000 production year?
By estimating a larger figure to represent potential increased VOM
emissions 5 to
10 years in the hiture, how would the ozone increment change?
The ozone increment calculated in Item 24 above is representative of the maximum expected cleaning
solventusage at the facifity.
Maximum VOM emissions from the facffity are limited by permit.
SCA
does not anticipate that maximum emissions from the facility 5 to
10 years in the future will be greater
than the maximum emissions reflected in Item 24 above.
Affirmed:
~
J~1~
Martin
J.
Stromberger
Dated:
___________________
8
EXHIBIT A
9
DIRECT TESTIMONY OF MARTIN
J.
STROMBERGER, P.E.
Q.
Please state your name, business affiliation and address.
A.
My name is Martin J. Stromberger.
I am a Project Manager and Manager ofTechnical
Operations in the Milwaukee Office at RMT,
Inc.
(RMT).
My business address is 150 N.
Patrick Boulevard, Suite 180, Brookfield, WI
53045-5854.
I have over 24 years of experience in air pollution regulatory compliance.
As a Project
Manager
and Manager of Technical Operations, I provide guidance, direction, and’
oversight to project managers and technical staff for air permitting, compliance
demonstration,
and other environmental compliance
projects for clients.
Q.
What is the business of RMT?
A.
RMT
is an environmental
and
management consultant providing services to
a wide
range of businesses across the United States.
Our services include regulatory permitting
and compliance management, environmental planning and remediation, innovative
technology applications, health and safety management, risk management, engineering
design, and construction management.
Q.
Please describe your educational history.
A.
I have a B.S. degree in General Engineering from the University of Illinois
—
Urbana/Champaign (January 1981).
I have a M.S. degree in Environmental Engineering
from the University of Cincinnati (March 1985).
C:
\DOCUMENTS
AND SETINGS\HILL\
LOCAL SEUINGS\TEMPORARYINTERNET FILES\OLK5\
DI
Q.
Whatprofessional licenses or certifications do you hold?
A.
I am a Professional Engineer licensed in Wisconsin and Massachusetts.
C:\DOCUMENTS AND SETFINCS\FIJLL\LOCAL SETFINGS\TEMPORARY INTERNET FILES\OLK5\
DI
EXHIBIT B
10
VVVJVj~
MATERIAL SAFETY
DATA SHEET
P~n~IOF1C&
Coipoiatiori
74
hudSon
Ave
Ten~flyNJ 07570
PENSOLr
LOVO Li 15C
Page
1
of
4
Date
Prepared;
February 22,
1 995
MSDS
No.:
47:654080
SECTION
1
PRODUCT IDENTIFICATION &:EMERGENCY
INFORMATiON
PRODUCT NAME:
PENSOLV
LOVO
Li 1~C
GENERAL USE:
Degreaser
PRODUCT DESCRIPTION:
Solvent/solvent
blend
GENERIC
I NGREDIENTS:
Proprietary ~end
EMERGENCY TELEPHONE NUMBERS:
PENETONE
201-561-3000
CHEMTREC
600424-9300
SECTION 2 HAZARDOUS
INGREDIENT SECTION
This product
Is
hazardous
as
defined
In
29 CFR1~i3.12Q0.
OSNA HAZARD:
COMI3U$IIBLE
OSHA HAZARDOUS
INGREDIENTS
EXPOSURE
t,IMITSfl
hrs. 1WA
(ppm)
CAS#
OSHA Pa.
ACGII-1 TLV
Suophier
Prupnetaiy
blend
—
500
:100
SECTION 3
HEALTh
I NFIORMATI ON &
PROTECTION
EMERGENCY OVERVIEW:
Clear, light amber combustible
liquid wIth
fruIty odor.
Irritating to eyes, skin,
and
respiratory tract.
POTENTIAL HEALTH EFFECTS:
EYE
CONTACT:
Slightly
irritating
hut
does
net Injure
eye
tissue.
111gb vapor
concentrations
may
be
Irritating.
SKIN CONTACT:
Fpequcnt or protonjed contact nviy irritite or dry the skin
or cause d~rmarrUs
Skin contact may
aggravate
an existing
dermatitis
condition.
INHALATION:
High vapar/aerosol cancentretions (greeter than the
I LV)
are irlilaung to ilie respiratory tract md
remy cauee he9daches
dizziness
anesthesia
drowsiness
unconsciousness
and other central newous system effects
INGESTION:
Small amounts oIthis
liquid may be drawn into the lungs by either swallowing
orvomiting~This
may cause
severe and
delayed heahth effects such as
inflammation
ofthe
lungs and infection ci
the bronchi
lngcstion may cause
imntation of
tho digestive tract and
diarrhea.
PENSOLV LOVO
LI1SC
Page;
2:of4
Date Prepared:
February 22,
~g95
MSDS No.~4766-4080
CHRONIC:
TIns product contains a
material which when ingestcd
in 1-irgu amounts lids caused kidne
and liver damage in laheratory
animals.
FIRST AID
MEASURES:
EYE
CONTACT:
Flush
eyes
with
large amounts of water.
See physician
immediately.
SKIN CONTACT;
Flush
skin with
large
amounts of water
Use soap
if available
Remove contaminated clothing and iaundei
before reuse
II skin
irrildiron develops
or persists
consult physician
INHALATION:
Remove person to fresh air
Administer oxygcn
or arlificidl
aspiration
as
needed
Call a
physician immediately
INGESTION:
:
If Sallowed
DO
NOT INDUCE VOMITiNG.
Use
a stomach
pump.
Call
a
physician
Immediately.
WORKPLACE EXPOSURE CONTROLS:
PERSONAL PROTECTION:
Safety
glasses are recommended for
all
workplace
conditions.
Solverrl resistantglovea should be
used.
Other protective
gear
inclcding splash proof geggle.~
or facy shickl
rubber
boots
apron
gauntlets
or
rain qear should be
worn
depending on how the product is used.
VENTILATION:
None
needed u rider rrorrrial use coriditions
ror enclosed areas
or where large
-in aunts of toe product are being
used
the
use of tans or other machank al ventilation
is recomntondcd
An organic vapor mask or
a particle mask shanK
be
used:if theproduct it sprayed.
DO NOT MIST THIS PRODUCT.
Use
coarse spray only.
SECTION 4
FIRE & EXPLOSION HAZARDS
FLASH
POINT:
t2rF “ICC
FLAMMABLE LIMITS
not determined
AUTOIGNITION TEMPERATURE:
not determined
GENERAL HAZARD:
COMBUSTIDLE LIQtJID
Cm
form cornbustibk. mixtures at or
above ti’e fiash point
Containers
can
rupturc
and explode under
fire
conditions due
to pressure
arid v-ipor buildup
FiRE FIGHTING:
Either allow fire to
burn
out under
controlled conditions or
eirtrnguish ~tith
v atar
foam
or dry
ctierracaI
Cool exposed
00
ntalnars:with water
spray.
HAZARDOUS COMBUSTION PRODUCTS:
Sntolce, fumes,
and
oxtdes ofcarbon:
4:
SECTION
5
SPILL CONTROL MEASURES
LAND SPILL:
Eliminate sources of ignition.
For small spills, use absorbent niateilul
such
as towels or absorbent powdem.
Put all material
into proper waste di
posal container with
lid tightly covered
Solvent soaked materials may spontaneously combuat.
For
larger spills
dike spill
recover freo liquid
and
u
e absorbent material to dry area
Putali material
into appropoite waste
containers.
WATER SPILL:
Rcrnove
product frorni water surface by skimming or auth suitable
ibsoroents
If altowtd
by local eilvironrnerital regulatory
agencies,
you may use
a suitable dispersant.
PENSOLV LOVO LIISC
Page:
3of4
Dale Prepared:
February fl
:1995
MSDS
No.:: ~l766-408O
SECTION
6
HANDLING
& STORAGE
STORAGE TEMPERATURE1 °F:
ambient.
DO
NOT STORE ABOVE
120
Deg.
F,:
GENERAL
Keep
away froni heit cources
open flanres
acid
olher ignition sources
Do not store
near strong oxidants
SECTION 7
TYPICAL
PHYSICAL & CHEMICAL
PROPERTIES
_____________-
VAPOR PRESSURE, mm Hg at20°C
lets than 2
VAPOR DENSITY (Air
=
1):
greaterthan
:1:
WT
ORGANIC
VOL.ATILES:.
50
pH:
nd
applicable
BOILING
POINT1 °F:
greaterthan 300
EVAPORATION
RATE, Acetone
=
1:
less than
0.05
SOLUBILITY
IN WATER:
forrris weak emulsion
SPECIFIC
GRAVITY at 75’P:
0.820
ODOR AND APPEARANCE:
clear light amber liquId with fruity odor
SECTION 8
REACTIVITY DATA
GENERAL:
This
product
Is stable
and
hazardous polynierization
will not occur.
INCOMPATIBLE MATERIALS AND CONDITIONS TO AVOID:
Strong
oxIdizing :agenth.
SECTION 9
REGULATORY:INFORMATION
DEPARTMENT
OF::TJD~NSPORTATION
(DOT):
PROPER SHIPPING NAME
COMIJUS
I ISLE LIQUID
NO S
contains petroleum hydrocarbons
HAZARD
CLASS:
COMBUSTIBLE LIQUID
IDENTIFI CATION NUMBER:
not
applicable
PAOKING GROUP:
lit
LABEL:
npt applicable for nionibulk
FLASH POINT:
122”FTCC
pH:
not applicable
TSCA:
The ingredients
in
this product
are listed onthe
TSCA.
inventory.
CERCLA:
This
product coirtains
rio reportable C’tRCl A
materi,L,
We
reoonimcnd
you
contact local authorities to determine
if
there may he other local reporting requinamenils.
RCRA HAZARD
CLASS:
DOOl
lgnIbble hazardoys waste
PENSOLVLOVO LII5C
page: :4ou
Pate Prepared:
February
22,
1995
MSDS Nb~4756-4080
SARA TITLE III:
311/312
HAZARD
CATEGORIES:
Acute
health.
Fire
313
REPORTABLE INGREDIENTS:
None
CALIFORNIA PROPOSIT1ON
65
INFORMATION:
The
product docs not Contain anychemicals recognized by the state ofCalrfernra to cause canc~r
anther brrtlr detects
or
reproductive harm,
SCAQMD
INFORMATION:
Is
there a photachenlIcally reactive material
present?
Yes
What is the
bj volume of photociremicaliy
reactive mate
~
about 50
What is the VOC content?
about
42
g/l
What is :th~
vapor
prpssirre
of VOC’s?
less than 2
rrrrnr Hg
at20t
SECTION
10
NOTES
HAZARD RATING
SYSTEMS:
HM1S
NFPA
KEY
HEALTH
1
•t
4= Severe
FLAMMABILITY
2
1
3
Serious
REACTIVITY
~t
Q
:
2
=
Moderate
1
=
Slight
0
=
Minimal
REVISION SUMMARY
SUPERSEDES ISSUE
DATE
None
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EXHIBIT
C
11
EPA List of 188 Hazardous Air Pollutants
CAS Number
Chemical Name
75070
Acetaldehyde
60355
Acetamide
75058
Acetonitrile
98862
Acetophenone
53963
2-Acetylaminofluorene
107028
Acrolein
79061
Acrylamide
79107
Acrylic acid
107131
Acrylonitrile
107051
Allyl chloride
92671
4-Aminobiphenyl
62533
Aniline
90040
o-Anisidine
1332214
Asbestos
Benzene (including benzene from
71432
gasoline)
92875
Benzidine
98077
Benzotrichloride
100447
Benzyl
chloride
92524
Biphenyl
117817
Bis(2-ethylhexyl)phthalate (DEHP)
542881
Bis(chloromethyl)ether
75252
Bromoform
106990
1
,3-Butadiene
156627
Calcium cyanamide
Caprolactam
105602
(See Modification)
133062
Captan
63252
Carbaryl
75150
Carbon disulfide
56235
Carbon tetrachloride
463581
Carbonyl
sulfide
120809
Catechol
133904
Chloramben
57749
Chlordane
7782505
Chlorine
79118
Chloroacetic acid
532274
2-Chloroacetophenone
108907
Chlorobenzene
510156
Chlorobenzilate
67663
Chloroform
107302
Chloromethyl
methyl ether
126998
Chloroprene
Cresols/Cresylic acid
(isomers and
1319773
mixture)
95487
o-Cresol
108394
m-Cresol
106445
p-Cresol
98828
Cumene
94757
2,4-D, salts and esters
3547044
DDE
334883
Diazomethane
132649
Dibenzofurans
96128
1,2-Dibromo-3-chloropropane
84742
Dibutylphthalate
106467
1 ,4-Dichlorobenzene(p)
91941
3,3-Dichlorobenzidene
Dichloroethyl
ether (Bis(2-
111444
chloroethyl)ether)
542756
1 ,3-Dichloropropene
62737
Dichlorvos
111422
Diethanolamine
121697
N,N-Diethyl aniline (N,N-Dimethylaniline)
64675
Diethyl sulfate
119904
3,3-Dimethoxybenzidine
60117
Dimethyl
aminoazobenzéne
119937
3,3’-Dimethyl
benzidine
79447
Dimethyl carbamoyl chloride
68122
Dimethyl formamide
57147
1,1-Dimethyl hydrazine
131113
Dimethyl phthalate
77781
Dimethyl sulfate
534521
4,6-Dinitro-o-cresol,
and salts
51285
2,4-Dinitrophenol
121142
2,4-Dinitrotoluene
123911
1,4-Dioxane
(1 ,4-Diethyleneoxide)
122667
1 ,2-Diphénylhydrazine
Epichiorohydrin (l-Chloro-2,3-
106898
epoxypropane)
106887
1 ,2-Epoxybutane
140885
Ethyl acrylate
100414
Ethyl benzene
51796
Ethyl carbamate (Urethane)
75003
Ethyl chloride (Chloroethane)
106934
Ethylene dibromide (Dibromoethane)
107062
Ethylene dichloride (1 ,2-Dichloroethane)
107211
Ethylene glycol
151564
Ethylene imine
(Aziridine)
75218
Ethylene oxide
96457
Ethylene thiourea
75343
Ethylidene dichloride
(1 ,1-Dichloroethane)
50000
Formaldehyde
76448
Heptachlor
118741
Hexachlorobenzene
87683
Hexachlorobutadiene
77474
Hexachlorocyclopentad iene
67721
Hexachloroethane
822060
Hexamethylene-1 ,6-diisocyanate
680319
Hexamethylphosphoramide
110543
Hexane
302012
Hydrazine
7647010
Hydrochloric
acid
7664393
Hydrogen fluoride (Hydrofluoric acid)
Hydrogen
sulfide
7783064
(See Modification)
123319
Hydroquinone
78591
lsophorone
58899
Lindane
(all isomers)
108316
Maleic anhydride
67561
Methanol
72435
Methoxychlor
74839
Methyl
bromide (Bromomethane)
74873
Methyl chloride (Chloromethane)
71556
Methyl chloroform
(1,1,1 -Trichloroethane)
78933
Methyl
ethyl ketone (2-Butanone)
60344
Methyl
hydrazine
74884
Methyl iodide (lodomethane)
108101
Methyl
isobutyl ketone(Hexone)
624839
Methyl isocyanate
80626
Methyl methacrylate
1634044
Methyl tert butyl ether
101144
4,4-Methylene bis(2-chloroaniline)
75092
Methylene chloride (Dichloromethane)
101688
Methylene diphenyl diisocyanate (MDI)
101779
4,4-’-Methylenedianiline
91203
Naphthalene
98953
Nitrobenzene
92933
4-Nitrobiphenyl
100027
4-Nitrophenol
79469
2-Nitropropane
684935
N-Nitroso-N-methylurea
62759
N-Nitrosodimethylamine
59892
N-Nitrosomorpholine
56382
Parathion
Pentachloronitrobenzene
82688
(Quintobenzene)
87865
Pentachlorophenol
108952
Phenol
106503
p-Phenylenediamine
75445
Phosgene
7803512
Phosphine
7723140
Phosphorus
85449
Phthalic anhydride
1336363
Polychlorinated
biphenyls (Aroclors)
1120714
1,3-Propane sultone
57578
beta-Propiolactone
123386
Propionaldehyde
114261
Propoxur(Baygon)
Propylene dichloride (1,2-
78875
Dichloropropane)
75569
Propylene oxide
75558
1 ,2-Propylenimine (2-Methyl aziridine)
91225
Quinoline
106514
Quinone
100425
Styrene
96093
Styrene oxide
1746016
2,3,7,8-Tetrachlorodibenzo-p-dioxin
79345
1,1 ,2,2-Tetrachloroethane
127184
Tetrachloroethylene (Perchioroethylene)
7550450
Titanium tetrachioride
108883
Toluene
95807
2,4-Toluene diamine
584849
2 ,4-Toluene
d iisocyanate
95534
o-Toluidine
8001352
Toxaphene (chlorinated camphene)
120821
1,2,4-Trichlorobenzene
79005
1,1 ,2-Trichloroethane
79016
Trichloroethylene
95954
2,4,5-Trichlorophenol
88062
2,4,6-Trichlorophenol
121448
Triethylamine
1582098
Trifluralin
540841
2,2,4-Trimethylpentane
108054
Vinyl
acetate
593602
Vinyl bromide
75014
Vinyl chloride
75354
Vinylidene chloride
(1,1-Dichloroethylene)
1330207
Xylenes
(isomers and mixture)
95476
o-Xylenes
108383
m-Xylenes
106423
p-Xylenes
0
Antimony Compounds
Arsenic Compounds (inorganic
including
0
arsine)
0
Beryllium Compounds
0
Cadmium Compounds
0
Chromium Compounds
0
Cobalt Compounds
0
Coke Oven
Emissions
0
Cyanide Compounds
(Note
1)
0
Glycol
ethers (Note 2)
0
Lead Compounds
0
Manganese Compounds
0
Mercury Compounds
0
Fine mineral fibers (Note 3)
0
Nickel Compounds
0
Polycylic Organic Matter (Note 4)
0
Radionuclides (including radon)
(Note 5)
0
Selenium Compounds
NOTE: For
all
listings above which contain the word “compounds” and
I
X’CN where X
=
H’ or any other group where
a formal dissociation
2 Includes mono- and
di- ethers of ethylene glycol, diethylene glycol,
n
=
,
2, or 3
R
=
alkyl
or aryl groups
R’
=
R,
H,
or groups which, when
removed,
yield glycol ethers with the
(See Modification)
3 Includes mineral fiber emissions from facilities
manufacturing or
4 Includes organic compounds with
more than one
benzene ring,
and
5 A type of atom which
spontaneously undergoes radioactive decay.
RECEIVED.
CLERK’S OFFICE
MAY
132005
STATE OF ILliNOIS
Pollution Control Board
Direct Dial (518) 447-3337
Direct Fax (518) 447-3368
E-mail:
Privitera@~m1tw.com
May
12,
2005
VIA OVERNIGHT DELIVERY:
Mr. Bradley P. Halloran
Hearing
Officer
Illinois
Pollution Control Board
James R. Thompson Center, Suite 11-500
100 West Randolph
Chicago, IL
60601
RE:
Docket AS-Q5-04
SCA Tissue North America,
LLC
Dear Mr. Halloran:
On behalf of SCA Tissue North America,
LLC (SCA),
attached are two copies ofthe requested
responses
to
questions posed by
the
Illinois
Pollution
Control Board’s technical
personnel in
regard to
the petition of SCA Tissue North America,
LLC for an
adjusted standard
from
35
Ill.
Adm. Code 218.301
and 218.302(c).
The
questions
posed
by
the
Illinois
Pollution
Control
Board
are
listed
on
the
attached
submission,
followed by SCA’s response to the questions through consulting
engineer,
Martin J.
Stromberger.
Please note that three attachments accompany SCA’s response to
the questions.
JJIP/klh
Enc.
cc:
Clerk, IPCB
Robb Layman, Illinois Environmental Protection Agency
ATTORNEYS
AT
LAW
677
Broadway, Albany, New York
12207-2503
(518) 447-3200
~
Fax
(518) 426-4260
www.mltw.com
