ILLINOIS POLLUTION CONTROL BOARD

June 21, 1973

THE CELOTEX

CORPORATION

)

#73-123

v.

ENVIRONMENTAL PROTECTION AGENCY

)

JOHN L. PARKER AND E. GERALD REYNOLDS,

APPEARED

ON

BEHALF

OF

THE CELOTEX CORPORATION

FREDERICK ENTIN, ASSISTANT ATTORNEY GENERAL,

APPEARED

ON BEHALF

OF ENVIRONMENTAL PROTECTION AGENCY

OPINION

AND

ORDER OF THE BOARD (BY

SAMUEL

P.

LAWTON, JR.):

The Celotex Corporation has filed an amended petition for

variance seeking relief from the provisions of Rule 3-3.111 of the

Rules and Regulations Governing the Control of Air Pollution and

from Chapter 2, Rule 203(a) of the Air Pollution Control Regulations

to enable particulate emissions in excess of the above Rules from

its asphalt saturator and filler dryer and heater, both located in

its Wilmington plant, until March 21, 1974.

Hearing was held on the petition on May 23, 19!3. The Agency

has filed a recommendation based on the original petition in which it

recommends allowance of the variance, but on a shorter time frame

than proposed by petitioner. On the basis of the amended variance

petition and the views expressed by Agency personnel at the hearing,

it does not appear that the Agency has

any

serious differences with

the petitioner relative to the variances proposed.

We grant the variances as requested in the petition until

March 21, 1974.

The Celotex Corporation is a Division of the Jim Walter Corpora-

tion, a national producer of building.materials. The Celotex Corpora-

tion manufactures roofing and other building material composed chiefly

of asphalt-treated felt products. Wilmington has a population of

4,335 and is located approximately 16 miles south of Joliet,

in Will

County. The principal component parts of the Celotex plant (Petition-

er’s Ex. 4-6) consists of a felt mill and a roofing mill. In

the

felt mill, wood and paper are pulped and formed into sheet felt

which becomes the base for the roofing products (R. 31). This, in

turn, is fed to the roofing mill where it is saturated

with hot li-

quid asphalt contained in a dip tank known as the asphalt saturator. ThE

liquid asphalt flow rate to the saturator is approximately 16,500 pounds

per hour (R. 32). The saturated felt is then either cooled or rolled

for use as roofing felt or building paper or is coated with

8

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345

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stabilized

asphalt and surfaced

with granules and

sand to

make

composition roofing.

In the coating and. surfacing operation, the

sand used as a filler is simultaneously dried and heated in a

rotary kiln, Dry sand exits the kiln at

25,000

pounds per hour.

The dry sand is then sized in screening equipment and blended with

asphalt, following which the mixture is applied to

the asphalt

saturated deit.

The emission sources, which

are the

subject of this

proceeding, are located within and adjacent to

the

roofing mill

(R.

28—29)

,

(Petitioner~s Ex, 4)

These emission sources are the

three exhaust stacks from the asphalt saturator and

the

filler dryer

and heater exhaust stack and related equipment.

Air contaminants

discharged from the asphalt saturator constitute particulate

matter

esti.mated at 45 pounds per hour, both solid and liquid, and small

quantities

of 502 and hydrocarhons,for which latter emissions no

variance is sought.

The 45 pounds per hour estimated emission rate for oarticuiatss

is based on similar asphalt saturating processes (14. 121—123).

The

air contaminants discharged from the filler dryer and heater constitute

solid particulate matter and water vapor~~ The estimated particulate

emission rate is 25 pounds per hour based primarily on screen analyses

To control emissions from the aspha:Lt saturator

Detit:ioner

proposes the installation

of 40 ,000 CFM high energy air fi:Ltration

system

known

as a HEAF unit.

Ex:taust gases from the three saturator

stacks will

be

drawn through a perforated drum covered with a fibur~

glass mat. and then will pass through a York dc—mister pad, which is

a packed bed acting as a detrainer

~or liquid droplets.

it :i a aetimated

that this

unit

will remove between

90

and

95

of particulate emissions

from

the saturator (R.

l26~l34),

The unit will

cost

approximately

$61,800 (R, 129).

Particulate

emissions from the filler dryer and

heater and associated equipment will be controlled by the installatic,n

of an aerody;ae series ~‘SV” dust collector,

through which emissions

from the filler dryer and heater stack will he passed, and, in addition,

a baghouse of approximately 4,000 CFM to handle emissions from the trans-

fer points, bucket elevator and Rotex screen.

Anticipated efficiency of

the aerodyne would. he

95.

The aerodyne unit, with fans, will cost

in excess

of $4,000 and the

baghouse

approximately $3,400.

Baghouse

removal efficiency is estimated at

99.

P:Lans have been made with Commonwealth Edison~ ~

for

the necessary electrical

power which will

entail the installation of

a new

transformer. The proposed schedule

for

compliance is as

follows:

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346

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Item

Completion Date

Equipment order

June 6, 1973

Equipment delivery including

engineering design and construction

permit

~pp1i~fi~n~

26 weeks December 6, 1973

Equipment installation

6 weeks January 17, 1974

I week

January 24, 1974

Debugging and final stack test

4 weeks March 21, 1974

We believe an adequate dhowir~gof hardship has been made to

justify the allowance of the variances proposed. A denial of variance

does not necessitate shut-down of the plant. The Company presumably

has the option to remain in violation and take its chances on the

possible imposition of a penalty. ~This, however, does not present

an alternative which the Board would favor. The record does support

petitioner’s contentions that suspension of operation or termination

of the facilities involved would have a serious econortic impact on

the Company, its employees and its customers, causing disruption of

the line of production relating to operations beyond thos.e immediately

involved in the resent proceeding. Furthermore, the schedule for com-

pliance is a relatively short one, considering the ragnitude of the

instailatic.n involved and the degree of compliance that w.ill be achieved

once the program is completed.

The record likewise supports the economic dependency of the Wil-

mington community on the continuing operation of the petitioner’s

facility. We believe the hardship on the Company, its employees and

customers and the comrnun.ity, if the variance is denied, is far greater

than any continuing burden on the surrounding area in allowing the

present particulate ~emissions to continue until the abatement program

is completed in March of 1974. While there was some evidence that

petitioner’s emissions produced a nuisance impact on portions of the

community, the evidence was not extensive nor particularly persuasive,

and. em do not feel of a sufficient magnitude to justify a denial of the

vamiances sought. The Agency has indicated that it does not oppose

the variance allowance.

This opinion constitutes the findings of fact and conclusions

of law of the Board.

I. Variances from Rule 3-3,111 of the Rules and Regulations

Governing the Control of Air Pollution and Rule 203(a) of

tie Air Pollution Control Regulations, are granted to The

Celotex Corporation to enable the emission of marticulates

in e.xces.s of the foregoing Rules until March 21, 1974,

---

pending installation

of abatement equipment as set

forth in the amended petition of petitioner and speci-

fied in the

foregoing

Opinion, with respect to its

asphalt saturator and filler dryer and heater facilities.

2. Petitioner shall file on or before July 6, 1973, in

form satisfactory

to the Agency, a performance bond in

the amount of $70,000, guaranteeing installation of

all abatement equipment as specified in its

petition

and the record herein, by March 21, 1974. The bond

shall be mailed to: Fiscal Services Division, Illinois

Environmental Protection Agency, 2200 Churchill Drive,

Springfield, Illinois 62706.

I, Christan Moffett, Clerk of the Pollution Control Boa~d, certify

that the above Opinion and Order was adopted on the

,2i~

day of

June,

1973, by a vote of

4

to

c~

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