Jude Armitage Bureau Chief Bureau of Air A1021 North Grand Avenue East Springfield, IL 62794
December 1,2017
ArdaghGroup
www.wteigroupxom
Afdsgb Glass Ins, 10194 Crosspoirit SlvsJ, Bute 41
in f t o n a f s o f e , SM 482S S
PO So* 50407 M a r s p s f e , IN 48250
T+1-317-5S8-102 F -. +1-317-558 8853
Dear Ms, Armilage;
I am writing today to request that U S E P A and Illinois E P A consider and approve a modification to the federal Consent Decree entered in 2010 by the United States District Court for the Western District of Washington at Seattle, Civil Action No. 2 H O -C V -T SZ (hereinafter the "G C D "), pursuant to Paragraph 99 thereof.
Specifically, Ardagh G la ss lnc.1 ("A G T ) requests a modification of Paragraph 7.b. to delete reference to the Lincoln plant in Table 2 which establishes a deadline of December 31, 2018 to install N O x emission controls on the glass melting furnace.
Since the date of the G C D , the g la s s container manufacturing market h as seen increased competition from alternative materials, such as P E T and aluminum, and increased imports of containers from China and Mexico. Moreover, the amount of glass bottles produced in the United States for m ass beer, long a stalwart of the gla ss container market, has decreased by 50,000 tons annually. In the current competitive environment, the additional cost of installing BACT-level N O x em issions control equipment at a one-furnace operation would make Lincoln nonwiable. A G I w il have little choice other than to shut down operations at Lincoln, causing the elimination of 153 jobs.
Although A G I is seeking a modification of I s commitment under the G C D , it is important to note that A G I is committed to and mil fulfill the benefit of the bargain as envisioned by all parties when they entered into the G C D . A s discussed more fully below, even without the installation of NOx emissions controls at Lincoln, A G I will have met or far exceeded the anticipated emissions reductions for all pollutants in the G C D by the end of 2019,
The G C D covers all of the A G I furnaces operating in 201 (F at 14 facilities, and for each furnace im poses emission limits and control requirements for NOx, S 0 2 , P M and H 2 S0 4. Am ong the commitments that A G I made in the G C D w as to install the first-ever selective catalytic reduction on a gla ss melting furnace on three furnaces at our Dolton, Illinois plant. That system, anticipated to result in an emission factor of 1,3 lbs. N O x per ton of glass produced, actually achieved*1
1 Ardagh Glass Inc is, by name chan after merger, the successor to Saint Gobain Containers, Inc , the signatory to lie GCD. 1 Due to adverse market conditions as discussed above, two furnaces originally subject to the G C D have been permanently dosed.
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Sierra Club v. EPA 18cv3472 NDCA
Tier 10
ED 002061 00179316-00001
ArdaghGroup W
a n e m issio n rate of 1.0 Ib./ton. After the s u c c e s s o f the S C R at Dolton, A G I installed S C R on 2 additional furnaces.3
It must be noted that A G I h a s m et every obligation under the G C D , installing and im plem enting specified em ission controls and m ethods to reduce e m issio n s o f N O x at 24 furnaces over a 7-year period. W h e n an n o u n c in g the G C D in 2010, U S E P A e stim ated that N O x e m is s io n s from A G I 's facilities would be reduced by 4,162 to n s per year by the end of the 9-year period of implementation (2019). B y ach ie vin g even low er e m issio n s than required to c o m p ly with the G C D for individual furnaces, during the last year of reporting (2016) N O x e m issio n s were reduced by 3,954 tons per year a c ro ss all of A G I 's facilities from the b a se lin e u se d by U S E P A in e stim ating the results o f im plem enting the G C D requirem ents, th u s ach ie vin g 9 5 % of the 20 19 G C D goal. It is anticipated that - even with approval of this req uest - the overall N O x reductions will m eet the g o a l by the end of 2019.
T h is request only a d d r e s s e s N O x e m is s io n s at o n e furnace. T h e e m issio n limits in the G C D for S 0 2 , P M a n d H 2 S 0 4 h a v e alre ad y b e e n m et at the Lincoln facility an d will continue to be m et in the future if this G C D m odification request is approved. In fact, A G I e stim ate s that it will h ave ach ie ve d 2 0 0 % of the anticipated P M reductions and 1 3 0 % of the S 0 2 reductions a c ro ss all of the G C D facilities by the end of 2019.
W e w ould w e lco m e the opportunity to d is c u s s this request with appropriate individuals within your respective agencies.
C c : Rich Tomicek Ty Sibbitt
R ay Pilapil Illinois E P A Bureau of Air, Compliance Section 1021 N. Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276
Robert Kaplan U SEPA REGION 5 77 W. Jackson Blvd. Chicago, IL 60604-3507
Compliance Tracker, AE-17J Air Enforcement and Compliance Assurance Branch U.S. Environmental Protection Agency - Region 5 77 West Jackson Blvd. Chicago, IL 60604
3 U S E P A approved the use o f catalyst imbedded ceramic filters as a form o f SC R .
Sierra Club v. EPA 18cv3472 NDCA
Tier 10
ED 002061 00179316-00002