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