ILLINOIS POLLUTION CONTROL BOARD
    March 28, 1972
    IMPERIAL SMELTING
    CORPORATION
    v.
    )
    PCI3
    71—393
    ENVIRONMENTAL PROTECTION AGENCY
    Supplemental Statement by
    Jacob
    D.
    Dumelle
    While I agree and voted for the grant of the variance
    I do not
    agree with Paragraph
    4
    of the Order requiring stack tests on each
    piece of control equipment.
    The opinion on page
    3 states:
    3.
    Stack tests will be required by Imperial.
    This is
    necessary so that the Agency and Imperial know
    whether the equipment installed is in compliance
    with the law.
    On its face this
    is dangerous language.
    It would require stack
    tests on all control equipment everywhere in Illinois at an enormous
    cost.
    I do not think the Board wants
    to make that blanket require-
    ment.
    In the BoarcUs discussion it was brought out that stack tests
    were a means of accumulating needed technical data on new control
    technology.
    I agree with that.
    But stack tests are expensive and
    we are here imposing a costly requirement of perhaps $3,000 to $5,000.
    Should not the U.S. Environmental Protection Agency, with its
    national control technology needs, be the agency to decide where
    research is needed?
    In this case the stipulation showed emissions only 23.2
    over
    the
    standard.
    It seems obvious that a 95
    efficient wet scrubber if pro-
    perly operated and 99
    efficient baghouses will easily meet the stan-
    dard and the opinion so states
    (p.2, paragraph 4).
    Stack tests then
    should not have been required.
    Member
    4

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