ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    March
    22,
    1973
    ENVIRON~4ENTAL PROTECTION
    AGENCY
    ~t72—52
    V.
    )
    FORTY-~EIGHT INSULATIONS,
    INC.,
    a Delaware corporation
    RICHARD
    W.
    COSBY,
    ASSISTANT
    ATTORNEY
    GENERAL,
    APPEARED
    ON
    BEHALF
    OF
    ENV
    IRONNEN
    TAL
    PROTEC TI ON
    AGENCY
    WILSON
    D.
    BURNELL
    OF
    O’BRIEN,
    BURNELL,
    PUCKETT
    &
    BARNETT,
    ON
    BEHALF
    OF
    RESPONDENT
    OPINION
    AND
    ORDER
    OF
    THE
    BOARD
    (BY
    SAMUEL
    T.
    LAWTON,
    JR.):
    Comrlaint
    was
    filed
    against
    Forty-Eight
    Insulations,
    Inc.,
    the
    owner
    and onerator of a mineral wool manufacturing facility located
    in
    the
    Village
    of
    North Aurora.
    The facility includes
    two s1~g
    melting cupolas,
    two
    wool collection chambers,
    two curing ovens and
    two cooling sections.
    The
    complaint alleges
    that since March
    15,
    1971,
    Respondent,
    in
    the
    operation of the foregoing facility,
    emitted con-
    taminants
    into the air so
    as
    to cause air pollution,
    in violation of
    Section 9(a) of
    the Environmental Protection Act and in violation of
    Rules 2-2.11, 3-3.000
    and
    3-3.111 of the Rules and Regulations Governing
    tiie Control
    of Air Pollution.
    The
    entry
    of
    a cease and desist order
    and nenalties in
    the
    maximum statutory amount are sought.
    An answer was filed by Respondent in which it denies the material
    allegations of the complaint
    with
    respect to the causing of air pollutior
    and violation of
    the
    Rules.
    By way of affirmative defense, Respondent
    specifies
    the
    installation of air pollution abatement equipment made
    by
    it during 1969 and subsequent thereto, which, according
    to Respondent,
    have reduced the emission of air contaminants
    so
    as
    to bring its operatic
    into
    compliance
    with
    the
    relevant
    regulations.
    Hearing
    was held on the cc•i~iplaintand answer.
    Briefs were filed
    by both parties.
    In its brief
    (page
    2)
    ,
    the Agency concedes
    that it
    has
    offered
    no
    evidence in support of a
    9(a)
    air
    pollution violation,
    nor
    has
    it
    proved violation of
    the Rules with respect to emissions
    from
    Rcsponclc?ntrs cuoolas or curing ovens.
    The only area of contention re-
    lates to particulate emissions from Respondent’s wool blowing chambers
    Nos.
    1 and
    2.
    We
    find on the basis of the evidence that Pesoondent
    has
    violated
    Rule
    3-3.111
    in respect to emissions from the No.
    1 wool
    blowing
    chamber.
    The
    evidence does not establish
    a violation with
    resoect
    to
    the
    No.
    2
    wool, blowing chamber.
    7
    351

    ~.
    s’~ut
    a
    operation,
    located
    in
    North
    Aurora,
    manufactures
    :mL000:
    ,col
    insulation
    used
    in
    the
    construction
    industry.
    The
    Ros
    ~
    ~cnts.
    ~ra~ion
    consists
    of
    two
    separate
    production lines,
    each
    0cm
    05Cc
    cf
    a
    cucola,
    wool
    collection
    chamber
    (being
    the
    ~ool
    blowes
    cCoi
    rccn~,
    aurinci
    oven,
    cooler
    and cutting and
    eackaqinc
    equlorne(,
    in
    aer:os.
    Tee
    rocess
    vent
    stacics
    through
    which
    contaminants
    arc
    a
    the
    atmosehero
    are
    connected
    to
    the
    specific
    orocess.
    cllcws:
    do~ coth
    oroduction
    lines
    No.
    1
    and
    No,
    2,
    each
    cupola
    nausts
    :irreugn
    a
    multiclone
    into
    a
    common stack.
    The wool
    blowor
    a
    cure
    oven
    for
    ~roduction
    line
    No.
    exhausts
    through a common staci
    a
    roe
    cooler
    exeausts
    through
    a
    third
    and
    separate
    stack.
    Nith
    r’
    to
    oroducticn
    line
    No.
    2
    the
    wool
    blower
    and
    cooler
    exhausts
    to
    sor
    stacks
    and
    two
    stacks
    serve
    :he
    cure
    oven.
    Hearings
    were
    deia’a
    j
    an lgencv
    stack
    test
    could
    be
    cerformed
    and
    the
    ~esults
    evai
    os
    .~oe
    issuc necomes sole±y that
    01
    eeterminL
    ig
    wflct:
    or
    ~5siOrl3
    ~
    wool
    rooms
    and
    cure
    ovens
    for
    each
    production
    1 inc.
    rc~
    cc th~rel
    ~vere in
    Tlolation of Rules
    2—2.11,
    3—3.000
    and
    i—3.ifl
    The
    Acenc~7 test
    of
    the
    ~l
    wool
    room
    ~ius
    oven
    at
    ica.
    1-ri
    P’
    1)
    was
    performed usinq
    a 1/4—inch diameter
    sarrrb
    I ira
    r
    rca.
    .
    :strwc
    ~k.
    100
    and
    Compi.
    Ex.
    6)
    show
    that tufts
    ci mineral
    wool
    ~
    ~r.
    L
    out
    the
    wool
    room
    stack.
    The tufts are tu~ larcTe
    to
    bo
    ;e
    -
    L
    ~c~
    the
    probe
    used
    so
    that
    tile
    results
    of
    iii
    S
    est
    wOu
    ci
    be
    u
    ~crv
    1
    L
    2\n
    ~nspection
    of
    the
    test
    data
    indicates
    tout
    thu
    aenarid
    ‘~
    ii
    L
    ~
    63.7
    lb,hr,
    is
    unreasonable.
    The
    first
    rsut
    rtairuci,
    Li
    ii.
    or
    iowever,
    can be accepted
    as
    ~he
    Le Lal
    amiss
    io
    ~:ureP
    ~t
    wool
    blower
    and
    cure
    oven.
    BotI
    results
    1-mci
    i
    Ins
    ~
    Lu
    V
    at:
    (50.
    will
    be shown
    later.
    The
    mesh
    bag
    Lest
    oerfor:’uul
    by
    .Res’~oncir;a
    Ru
    .
    ;.
    )
    as
    given
    serious
    weight.
    The
    method invoived ca~tar:
    n
    ar~
    ;i
    I
    ~
    sions
    cmi
    Lted
    from
    the
    f1
    wool
    room
    and
    cure
    I’Tcfl.
    1:
    :1 zr
    ‘~
    openings
    in
    the
    bag
    (1/6 mc!.
    x
    1/il
    inch)
    iui
    cci~
    that
    ni
    tic
    I
    much
    of
    the
    emissions
    would
    not
    be
    captured
    s IIIOe
    i.ho
    m±roraci
    wool
    fibers
    individually
    are
    nctcrosconic
    (B.
    328)
    and
    orl~ bncomc’
    V’S
    ((51
    after
    the
    apclication
    of
    binder
    and
    subsequent
    ajctlomcrntton
    as
    Lao;
    enter
    tee blow
    chamber.
    The
    efficiency
    of
    the
    baq
    in
    COi
    lctirtq cots
    sions
    increases
    with
    tioc
    so
    that
    the
    results
    arc
    hiqhl
    do
    o:kiest;
    oh
    the
    duration
    of
    samoling.
    The
    result
    obtained,
    1.7
    lb/br,
    ~hould
    cc
    discounted,
    especially
    since
    information
    to
    determine
    the
    ci lowobi e
    emissions
    was
    not
    known.
    Forty—Eight’
    a
    high
    volume
    sariraler
    test
    (Beau.
    Lx.
    16)
    solves
    the
    cronlem
    of
    measuring
    emissions
    comnosod
    cart
    lv
    of
    larqe
    clumos,
    The
    sare’J
    e
    nrobo
    was
    La
    inch
    in
    diameter
    and
    large
    volumes
    of
    the
    f-i
    wool
    room plus oven
    stack
    gas
    ;‘ero sari~lod.
    One would
    ex~’ect
    tiic
    resul’s
    of
    this
    test,
    8.8
    to 22-3
    tb/hr
    o
    he
    qreator
    than
    the
    Aqeric
    ‘‘~
    Lest
    (Comal.
    Lx.
    5)
    since
    larqe
    nartic
    Les
    were
    captured.
    ‘ia11.5
    was
    the
    case
    for only one of
    the
    four
    rosulta ootainod.
    rpisere
    ;Jao
    some
    ou~Stioxi,
    7
    352

    during the hearing,
    of the quality and accuracy of the equipment
    used and test procedures followed during this
    test.
    Examination of
    the equipment and test material
    (Compl.
    Ex.
    8, Joint Ex.
    1)
    does not
    indicate any serious errors in performing the test.
    The stack test performed by Forty-Eight Insulations,
    Inc. on the
    #1 oven
    (Resp.
    Ex.
    13,
    14)
    contained errors admitted by
    the Respondent
    (P.
    445)
    .
    The errors found from an examination of the exhibits include
    not correcting volumes for pressure and not preparing
    the collection
    thimble properly for weighing.
    The result obtained, however,
    3
    lb/hr,
    is crobably accurate within 20
    considering these errors.
    Finally,
    tests of the #2 wool room mentioned by Forty-Eight Insula-
    tions,
    Inc. hut not included as an exhibit,
    had emission results of
    4.94
    lb/hr
    for the #2 wool room and 0.28
    lb/hr for the #2 cure oven
    (R.
    419)
    The test data
    is given in answer No. l2b to the Interrogatories of the
    Complainant and, based on the process weight,
    shows compliance for both
    the
    #2 wool
    room and #2 cure oven.
    The results also show that about
    95
    of the emissions,
    if totalled, would originate in the wool room.
    Much
    testimony concerned the use of emission factors
    in estimating
    the
    particulate emissions from the wool blowing chambers.
    Table
    8-16
    of AP-42 sets emissions for wool rooms at 17 lb/ton of charge weight
    and this value was used originally by the Agency
    (Compl.
    Ex.
    3)
    .
    The
    respondent produced evidence that showed that the emission
    factor
    was
    based on test results from AP—40
    “Air Pollution Engineering Manual”
    and that the test results included one unrealistic test result which
    would he dropped from future editions of
    the Manual
    (Resp.
    Ex.
    8,
    8a)
    The
    Agency then calculated a new emission factor for wool blowers of 4.4
    lb/ton
    by
    omitting the bad test result
    (Compl.
    Ex.
    9)
    and used it to
    calculate revised estimates of emissions
    for use in its case.
    The
    estimated emissions and the allowable emissions for
    the
    wool blowers
    are the following:
    Particulate Emissions
    Revised
    Allowable
    Unit
    Original Estimate
    Estimate
    Emissions
    #1 wool room
    70.6 lb/hr
    18.3 lb/hr
    8.6 lb/hr
    #2 wool room
    59.0 lb/hr
    15.3 lb/hr
    7.6 lb/hr
    rI~he
    significance of
    these estimates
    is lessened by the existence of
    the
    stack test data which we will use as the basis of our decision.
    One area of controversy concerned the determination of emissions
    allowed
    by
    Rule 3-3.111.
    The Rule sets limits for processes based
    on the process weight rate and applies directly to single sources.
    —3—
    7
    353

    At
    Forty—Eight
    Insulations,
    Inc.
    the
    #1
    wool
    room
    and
    #1
    cure
    oven vent through a common stack.
    The respondent argued that
    the
    allowable
    emissions
    are
    calculated
    separately
    for
    the
    wool
    room and the oven and then added to get the allowable emission for
    the stack
    (R.
    416,
    Resp.
    Ex.
    10)
    .
    It would then comoare the
    actual stack emission with this value.
    We
    agree with
    tile Agoricy
    that each source must be treated individually
    as to
    both
    actual
    and allowable emissions, which for the #1 wool room and #1 cure
    oven means that the allowable emissions are calculated separately
    and compared individually
    with
    the actual emissions from each of
    the two sources.
    To do as Respondent suggests would encourage
    manifolding dirty sources with clean sources
    to achieve compliance
    by
    averaging,
    that
    is,
    compliance
    by
    dilution.
    In view of the foregoing,
    it
    is necessary to determine
    the
    relative contributions to the measured stack emissions from the #1
    wool room and #1 cure oven.
    From all indications, most of
    the
    emissions
    originate in the wool room.
    Testimony
    (R.
    416)
    indicated that 90
    of
    the stack volume flow came from
    the
    wool room,
    10
    from the cure oven,
    which,
    if the particle concentrations were equally distributed, would
    mean 90
    of the particulate emissions are charged
    to
    the
    wool room.
    Respondent’s stack test of the #1 oven showed particulate emissions of
    approximately
    3 lb/hr which,
    if compared to total
    411 wool room plus
    #1
    cure oven
    stack emissions
    in the range of
    9 to
    22 lb/hr measured by other
    tests
    (Compl.
    Ex.
    5,
    Resp.
    Ex.
    10)
    ,
    would mean a
    #1 wool room contribu-
    tion of from 66
    to 86.
    In addition,
    the test of
    tho
    #2
    line referred
    to previously showed 95
    of the emissions from
    tile
    wool
    blower and
    cure oven came from
    the
    wool room.
    The conclusion drawn
    is,
    that at
    the very minimum, based on the record,
    66
    of
    the particulate emissions
    from the #1 wool room plus
    #1 oven stack arc emitted by the #1 wool
    room.
    Using the above analysis,
    the emissions measured by
    the
    stack tests
    can be compared to the allowable emissions ;i.ccording
    to- Rule 3-3.111
    with the following results:
    Party
    Reference
    Measured
    #1 Wool Room Emissions
    #1 cure oven emissions
    Stack
    Measurcd*
    Allowed
    Measured*
    Allowed
    Emissions
    Agency
    EPA Ex.5
    17.1 lb/hr
    11.3
    lb/hr 7.8 lb/hr
    5.8 lb/hr
    7.8 lb/hr
    65.7
    43.4
    7.8
    22.3
    7.8
    Forty—
    Resp.
    Ex.
    8.8
    5.8
    7.8
    3.0
    7.8
    Eight
    10
    22
    3
    14
    7
    7
    6
    7
    6
    7
    6
    11.2
    7
    4
    7
    4
    3
    8
    7 4
    12.2
    8.1
    6.2
    4.1
    6.2
    *Based on 66
    for wool room,
    34
    for cure oven.
    —4—
    7
    35~1

    The conclusion
    is that the
    411 wool room
    is
    in violation of
    Rule 3-3.111 but that the #1 cure oven
    is not.
    Documentation of emissions from the #2 production line was not
    as extensive.
    The Agency’s case is based on the emission factors
    and shows
    (Compi.
    Lx.
    9)
    estimated emissions of 15.3 lb/hr compared to
    allowable emissions of 7.6 lb/hr for the #2 wool room.
    The Agency also
    concedes that based on
    the
    record, the #2 cure oven
    is probably in
    compliance.
    In rebuttal, Forty-Eight Insulations,
    Inc. referenced
    (B. 418—419)
    a
    test which showed particulate emissions of 4.9 lb/hr
    compared to allowable emissions of 5.9 lb/hr
    from the #2 wool room.
    This
    test
    was
    performed
    at
    a
    low
    average
    process
    rate
    but
    the
    data
    was
    not challenged by the Agency.
    The Agency’s claim in their Brief
    that
    no evidence was
    introduced
    to support the test is not accurate
    since the test data
    is contained in answer l2b to their interrogatories.
    We
    therefore find
    that
    the
    emission test for the
    412 wool room shows
    compliance.
    It
    is
    our conclusion, therefore,
    that the #1 wool room is
    in
    violation of Rule 3-3.111, but that the other
    process equipment is
    not.
    The
    #1 wool room emits up to twice the allowable emissions based
    on valid stack test results.
    Respondent had submitted
    an Acerp to the Air Pollution Control
    Board
    on
    April
    15,
    1968,
    which
    identified
    twelve
    sources
    of
    emission
    on
    the
    two production
    lines
    (Resp.
    Ex.
    15)
    .
    A
    revised
    plan
    called
    for control of emission from six sources, namely,
    cupolas
    1 and 2,
    wool
    rooms
    1
    and
    2,
    cure
    ovens
    1
    and
    2
    (B.
    511)
    .
    The
    specific
    control
    ec~uinmentincluded multiclones on the cupolas, fine mesh belts on the
    wool rooms and double pass cure ovens
    (B.
    512)
    .
    All
    equipment
    had
    been
    installed
    and
    was
    in
    operation
    by
    July
    of
    1971
    (Reso.
    Ex.
    15)
    $291,000
    had.
    been
    expended
    for
    purchase
    of
    equipment
    and
    its
    installa-
    tion
    (Reso.
    Lx.
    16,
    17).
    We believe that
    Respondent has made a reason-
    ble effort
    to abate its oollutional discharges.
    However,
    more must
    be done
    to bring
    its #1
    wool room into compliance.
    This undoubtedly
    will
    call
    for
    the
    development
    of
    a
    program
    to
    abate
    the
    emissions
    from
    this
    narticular
    source.
    We
    will
    give
    Respondent
    60
    days
    in
    which
    to
    develop
    such
    a
    program
    and
    an
    additional
    60
    days
    to
    bring
    its
    operation
    in
    this resoect
    into compliance.
    A penalty
    of
    $500.00
    is
    imposed
    for
    violation
    of
    Rules
    2—2.11,
    3—3.000
    and
    3-3.111
    of
    the
    Rules
    and
    Regulations
    Governing
    the
    Control of Air Pollution.
    This opinion
    constitutes the findings of fact and conclusions
    of
    law
    of
    the Board.
    IT
    IS
    THE ORDER
    of
    the
    Pollution
    Control
    Board
    that:
    1.
    Respondent submit
    a program for abatement of
    the
    pollutional
    discharge
    from
    its
    #1
    wool
    room
    within
    60 days from the date hereof and cease and desist
    violation of the particulate regulations with respect
    thereto
    within
    120
    days
    after
    receipt
    of
    this
    order.
    —5—
    7
    355

    2.
    Penalty in the amount of $500
    is assessed against
    Respondent for violation of Rules
    2-2.11,
    3-3.000
    and 3-’3.lll of the Rules and Regulations Governing
    the Control of Air Pollution,
    as a result of particulate
    emissions from its
    #1 wool room.
    Penalty shall be paid
    by certified check or money order to the State of Illinois
    addressed
    to:
    Fiscal Services Division,
    Environmental
    Protection Agency,
    2200 Churchill Drive, Springfield,
    Illinois 62706.
    Payment shall be made
    no later than
    April
    27,
    1973.
    I, Christan Moffett, Clerk of the Illinois Pollution Control Boa~çd
    certify that the above Opinion and Order was adopted on the
    ~
    day of March,
    1973, by
    a vote of
    44
    to
    r~
    ~
    ~
    ‘‘1
    /2
    —6—
    7
    356

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