ILLINOIS POLLUTION CONTROL BOARD

September

26,

1972

JOHNS-MANVILLE PRODUCTS CORPORATION

(WAUKEGAN

PLANT)

#72—272

v.

ENVIRONMENTAL PROTECTION AGENCY

OPINION AND ORDER OF THE BOARD

(BY SAMUEL

T.

LAWTON,

JR.)

Petition was filed by Johns-Manville Products Corporation re-

questing variances from Rules 651(a) and 652 of the recently adopted

Asbestos Regulations

(Chapter 2, Part VI, Air Pollution, Asbestos

and Spray Insulation and Fireproofing), with respect to eight emis-

sion sources at its Waukegan Plant,

in order to enable installation

of equipment or changes in fabrication which will bring all operations

into compliance on or before April

30,

1973.

The Environmental

Protection Agency has filed a recommendation proposing allowance of

the variances requested,

subject to certain terms and conditions which

have been agreed to by petitioner.

Because of the absence of objection

filed by the public and the indication of approval of the program by

contiguous neighbors,

hearing originally scheduled on the petition

was cancelled by our order of September 12,

1972.

We grant the variances

as requested by the Company subject to the conditions proposed by the

Environmental Protection Agency.

Johns-Manville Products Corporation operates its plant on a

346-acre parcel bordering Lake Michigan on the north end of a four-

mile industrial zone in the City of Waukegan.

The plant

is a combined

operation composed of three separate divisions:

the Residential Pro-

ducts Division, the Pipe Division and the Industrial Products Division.

Each

is engaged in the manufacture of a wide variety of different pro-

ducts using different raw materials with varying degrees of asbestos

usage.

Total asbestos is presently estimated to be 45 tons annually

and serves as a raw material of products with total sales value of

$57,000,000 in 1971.

Asbestos fiber

is received in box cars and bagged in compressed

form in amounts of approximately 100 pounds per bag.

Bags are palle—

tized 10 bags high,

50 per pallet,

to form a solid, block-type load

in order to avoid shifting or breaking in transit.

The petitioner

represents that all potential emission sources of asbestos have been

subject to positive control over a considerable period of time.

---

Many

control

devices

are

those

that

were

provided

with

the

original

installation

of

production

equipment.

Others

represent

second

or

third

generation

replacements

of

the

original

control

system.

Some

equipment

for

control

of

asbestos

emission

has

been

in

use

at

the

plant for

45

years.

Of

a total of

24 emission

sources in

the

plant,

16 are represented to be in compliance

at

the present time,

and

eight emission sources remain to be brought into compliance, which

are

the

subjects

of

the

present variance requests,

It

is estimated that

the

Plant

exhausts

in the range of

540,000 scfm of air from source operations that use asbestos.

About

75,

or

405,000

scfm of this

volume,

is

routed through fabric fil~

ters

that are incorporated

into 18 separate exhaust air handling

systems throughout the Plant.

125,000 scfm of air is ducted through

wet collection devices.

The

remaining 10,000 scfm presently is

connected

to cyclones or control devices of similar efficiency.

Cost

of

existing

control

equipment

associated

with

asbestos

source

opera-

tions,

at

present-otay

values,

is

estimated

to

be

approximately

$2,000,000.

(Pet,

3)

The

petition

goes

into

considerable

detail

in

describing

the

present methods of existing air pollution control and abatement

equipment in operation,

the inspection

procedure

and

surveillance

schedule

to

determine proper performance of each control device,

tfl.e

testing

methods

to

ascertain periodic fiber counts at

emission

points

and the correlation

of

results

recorded.

Emissions

of

asbestos

fiber into the ambient. air are measured,

where

conditions

permit,

using air

samelins

pumps

and

membrane

filters.

The

asbestos

concentration

is evaluated using

20 fields per

sample,

counted

at:

random

using

phase contrast microscopy

at

430 x

magnificarlo

and

counting

only

fibers

that

are

5

microns

or

greater

in

length,

with

a

length—tothreadth

ratio

of

3

to

1

or

greater~

Supervisory

authority

is

provided for all process operations

at

the

plant.

Instruction

in

the potential hazards of exposure

to

asbestos

and

handling

procedures

have

been

formulated

and received

by

each empLoyee.

A

system of asbestos removal from clothing is

pro~

vided,

Waste products containing asbestos fiber

are

~o1iected

daily

and

transported

in

enclosed

dump

trucks

for

disposal

within

the

plant

property.

The

Residential

Products

Division

manufactures

asbestos

cement

sheet

products,

roofing

roll

goods

and

roofing

shingles

made

from

organic

and

asbestos

felts

manufactured

at

the

plant,

and

roofing

cement.

500

people

are

employed

in

this

Division.~

Asbestos

is

the

case

material

for

the

asbestos

cement

sheet

products

line

due

to

its

high

heat~resistant

qualities

and

general

resistance

to

caust:ic

chemicals

and

elements

ot

nature.

Rshestos

is

used

in

the

base

felt

5

886

---

in

some

roofing

products,

primarily

rolled

roofing

for

~‘built-up”

type roofs, providing

resistance

to

rotting

and

the

spread

of

fire.

Asbestos

is

also

a

key

ingredient

in

roofing

cement

products

serving

as a hinder

and

stabilizer.

In the Asbestos Cement Sheet Department, dry raw materials

are blended

into a wet

slurry formed into sheets and then cured and

pressed,

Sawing

and trimming operations follow.

Emission of asbes-

tos

from

this source is generated by the mixing and conveying of

asbestos fiber with other ingredients

used

in

asbestos

cement

board

as well as the various finishing operations such as saw-cutting and

sanding of the board.

Three

Parsons fabric bag houses are used to control emissions

from this source and this operation appears to be in compliance with

the Regulations.

In the Roofing Cement Department,

emissions of asbestos

occur

as the result of an air exhaust system at the asbestos fiber bag

opening and fluffing station, over the roofing cement mixer.

An

air

exhaust system reduces exposure of employees at this source.

Petitioner represents that it

is unable to determine whether

concentrations from this operation exceed the maximum two fibers

per cubic centimeters of

air

as provided in the Regulations.

Asbestos emissions may occur from the asbestos paper machine

where

the finished roll of asbestos roofing

felt

is trimmed.

However,

since most

asbestos

fiber involved in

this

operation is bonded in

felt ribbons, little discharge takes place into

the atmosphere.

While

petitioner

does

not

believe

this

source

to

be

in

violation,

because

of the present

inability

to

measure

emissions

at

this

source,

a

variance

is

requested

with

respect

to

this

operation.

Emissions

of

asbestos

may

also

occur

from

the

fiber~-glass

shingle coating operation and while this

is

a relatively minor opera~

tion,

since the petitioner

is unable to

determine

whether

concentrations

of asbestos fibers are discharging into the ambient air in excess of

2 fibers per

centimeter,

variance

is

sought

covering

thi:s opera-

With respect to the

three

departments of the Residential Pro~

duct.s Division requiring

variance,

xiamely,

the

Roofing

Cement

Depart-

ment,

the Asbestos Paper Machine and the

Fiberglass

Shingles

operation,

the

following

program

for

control

is

proposed.

For

the

Roofing

Cement Department, a new Parsons Collector will be installed.

The

hag

opening station has been modified arid a Hoffman

Central

vacuum

system pick-up point has been provided.

‘.3—

5

—

487

---

In order to properly control asbestos emissions from the

Roofing Cement Department and the asbestos paper machine and

to assure compliance with Rules

651(a) and 652,

a Parsons fabric

filter house will be installed at each location.

Purchase orders

have been placed for these units and if the schedule outlined in

the petition has been followed, the units should presently be

operational.

Expenditures totalling $27,400 are anticipated for

these facilities.

With respect to the Fiberglass Shingles Operation,

petitioner

the need of a variance at this source.

Petitioner represents that the installation of the two

Parsons

Fabric

Filter

Bag

Houses

and

the

change

of

formulation

in

fiberglass

shingles

will

assure

that

all

asbestos

emission

sources

in the Residential Products Division of the plant will conform to

Regulation by July 15,

1972, which if presently in effect, would

make moot the request for variances as to the Residential Products

Division.

The Pipe Division is engaged in the manufacturing and market-

ing of asbestos-cement pipe.

Pipe manufactured by this Division is

either ten or thirteen feet in length with an inside diameter ranging

from two to thirty-six inches.

Pipe manufactured by this division

is used principally by municipalities, building contractors, school

systems, subdivision developers, communication systems, public gas

and electric systems, water systems,

sewer lines, sewage disposal

systems,

storm drain systems disposal of industrial waste water and

telephone and electrical conduit systems.

Raw materials used are

silica, portland cement and asbestos.

Asbestos

is an essential in-

gredient because it

is relatively unaffected when buried underground,

does not disintegrate or rust and is highly resistant to acids and

mold.

Asbestos used

as a raw material in this Division is processed

in the Fibre Willow area.

Most emissions from this source appear to

be in compliance with the Regulations.

One emission source in the

Pipe Division which is not in compliance with the Regulations

is the

Bayard Chip Collector Cyclone which removes dust and chips from the

piping after machining,

drilling and sawing.

A second emission source in the Pipe Division is the Pangborn—

Parsons—Rees Bag House which petitioner believes may exceed the

two-fiber per cubic centimeter limit.

Variance is sought with respect

to emission from the Pangborn—Parsons—Rees Bag Collector and the

Bayard Chip Collector.

The Pangborn-Parsons-Rees Bag House Collector

will be replaced with a new 1200 Bag Parsons Bag House.

Location

of this new Bag House will require a shifting of machines and some

remodeling of the facilities.

It

is contemplated that the new bag

—4—

5

—

488

---

house will be operative by November 30,

1972.

It is also proposed

that the Bayard Chip Collector Cyclone will be connected to the

new Bag House after October

7,

1972.

During the period of the variance to November 30,

1972 the

Pangborn—Parsons—Rees Bag Collector will be in compliance with

Rule 651(a), approximately 90-95

of the time.

The Bayard Chip

Collector will be kept under constant surveillance to minimize

emission of particulates and it

is anticipated that

no

visible

emissions will be present in the ambient air approximately 90-95

of the time during the variance period.

The cost of replacement of

the Pangborn—Parsons-Rees Bag Collector and

the

connection of the

exhaust of the Bayard Chip Collector at the new bag house is esti-

mated at $135,000 plus an additional $23,000 to cover the need for

replaced equipment and new piping.

Additional installations have

been made which relate to facilities that are not the subject of the

variance, namely, the Parsons Wet End Bag House and the Wheelabrator

Coupling Aisle Bag House at

a total expenditure of $164,000, and

the installation of

a new fiber bag opener and replacement of duct

work at the wet end and willow area at an estimated $78,000 expen-

diture which will minimize asbestos fiber emissions during fiber

handling operations.

The Industrial Products Division uses asbestos as a raw

material in its manufacture of packing and friction materials, semi-

rigid asbestos millboard,

and high temperature molded superex insul-

ation.

The Packing and Frictions Material Department manufactures

a line of asbestos-based products,

including clutch facings, brake

linings and brake blocks for automotive,

truck, railroad and indus-

trial applications and friction products for power transmissions and

braking applications.

The Millboard Department manufactures semi-rigid

asbestos millboard products used in high temperature heat production

applications and asbestos gasket material.

The Superex Department

manufactures high temperature molded blocks used for industrial

insulation.

825 people are employed in this division.

Asbestos is

used in packing and friction materials because of its superior heat

resistant qualities and frictional characteristics.

It

is used

in millboard because of its heat-resistant qualities and tensile

strength imparted by its fibrous nature.

Superex insulation utilizes

asbestos fiber for all of the foregoing reasons as well as the bonding

benefits the fiber presents and the minimizing of overall material

density.

Eleven separate fabric filter collection systems and three

wet

scrubbers

are

utilized

in

the

-Industrial

Products

Division

for

control

of

asbestos

emissions.

Of sixteen emission sources

in the Industrial Products Divi-

sion,

all but three are in compliance with the regulations.

Emissions

in the Packing and Friction Materials Department result from the

mixing, molding and finishing operations.

Dry and Wet mixing opera-

tions are controlled by dry bag collectors and appear to be consistent

—5—

5

—

489

---

with

current

Peguiations.

MoLain~,

nandling

and

finishcnc

T

mixed

ani

mold ‘cc

ater~a~s

d:

oroduce

some

emiss’con

of

xscsl~

fibers into the

amrs Lent ~_c

Toe excaust

iron. three weigh

cro

produce

ersiss con

:~r ec-ces

~f

Regulations

fcc

which

a

coii~

:‘i

‘cc

or

is

proposed.

iihew~se,

Ut.

finishine

of

molded

friction

mater

thrcuqh

the

eec

oi

crindes~s,

saws,

driils,

sanders

and

other

rac~

:‘c:~

equipment

procuoc

enissrc

~‘iiscLarqed

into

five

separate

c~

cal

water

spray

scrubber-n

win cO.

at

the

present

time

emit

asboscos

fiber

in

excess

of

two

f ~ht~i5

per

cubic

centimeter

as

provided

the Regulation.

The

Millooard

Department

processes

asbestos

in

a

beater

ccci

which

produces

emissions

of

asbestos

in

excess

of

Regulation

icmU:n,

A

x’cLcxrry

is

sort-formed

in. the

heater

operation

and

cut

into

reoten—

gular

sheets,

dried

and

then

trimmed

and

packaged

in

other

parts

of

the

plant.

bcadina

oi

asbestos

into

the

beater

process

ma:~cause

ernissior.s

before

the.

sl-urr~

IS

formed.

A

Roto-c lone

Wet

Scrufrcn-

type

fax:

is

used

-io

remove

dust:

that

may

escape

before

thoroucp:

wetting

occurs.

This

operation

produces

emissions

that

in

al~

probability

exceed

the

Regulatory

limits,

Asbestos

raw

material

cs

handled

ln

the

mixing—molding

rums

of

the

Superex

Department

wnere

emissions

of

asbestos

fiber

int’c

the

ambient

air

occur.

Hare

agarn

the

mixing

operation

to

PtOL

‘ci?

a

slurry

creates

the

em_ssions

no-cub

Emissions

are

disc:rxarqed

initial:Ly

into

a

duct

leading

to

a

wet

Ducon

scrubber.

Howevec

~

visual

emissions

have

been

observed

and

this

:portion

of

the

ope: e~

is subject to

further

ccmrecttce.

ln

summary,

the

following

facilities

of

the

Industrial

Products

Diviseon

require

additional

controls

to

achieve

comd.

tn-

the

manifold

Ducon

wet

scrubber

system

and

weigh

booth

stacks

‘cc

Packing

and

Friction

materials

deoartrnents,

the

Roto

Clone

we-n

scrus-

her

in

the

Miliboard

Department

and the

Ducon

wet scrubber in the

Superex

Department.

In

order

to

bring

the

dry

mixed

material

a5i3:5-

tos

fiber

emissions of

the

Packing

and

Friction

Materials Departund;

into

compliance,

petitioner

has

engaged

in

a

product

re-formulatren

program

to produce

a damp

mix

formula reducing emission of ascesc:r

fiber.

Petitioner

anticipates

that by February 28,

1973,

a succecs-

ful damp mix formula

will

be

developed bringing emissions from

:Jra

weigh booth operation into compliance.

An anticipated $200,004

will be spent on this program.

To bring emissions in the Molded

Friction Materials Department into compliance, the five wet Ducon

scrubbers will be replaced with a new dry bag collector program

utilizing high efficiency cyclones and baghouse co’llectors

in

series.

An expenditure of $390,000

is programmed for this installa-

tion.

It is anticipated

that. by April

30,

1973,

this facility

wi1

he operational and in compliance with appropriate Regulations.

---

f.

cricg

the

Millboard

cperatiens

‘cntc’

compliance,

opera-

tiona2

acqes

xill

be

instituted

to

riniraize

Lee

asbestos

emission

durina

do

cca cer

m’cxcng

operation.

Ingredients

will

be

added

to

the

heecmss

:u,

their

paper

containers,

eliminatinc

dust,

This

change

wi?

rep::

re

extensive

modification

in

existing

mixing

equipment

which

toe

pet:tioner

anticipates

will

be

achieved

by

April

30,

1973,

An

expenditure

of

$59,000

is allocated fo~

this

program.

Ic

‘cring

the

Superex

Department

into

compliance

with

the

P~equ-

lations,

petitioner

anticipates

the

use

of

a

replacement

ingredient

for

asheoto~

for

which experimentation is

presently

under

way.

Field

testing

of

the

revised Superex

blocks

is

necessary

for

evaluation

of

the

new

product.

Petitioner

anticipates

than

chin

reformulation.

and

experimentation

will

be

achieved

by

December

31,

1972.

In

summary,

the

following variances

are

requested

for

the

particular

ft’.

lities

of petitionert

s

operation

to

the

dates

specified.

DiviScon

a

if

Source

of

Emission

and

Abatement

nr:eedure

to

be

installed

Variance Requested

To

1)

Resident.ia

Products

Devislon

Source ci emissions

—

Asbestos

paper

machine

Abatement

procedure

—

Parsons

Fabric

Filter

House

July

15,

1972

2~

Pioe

U

xvi smsn

Source

of

eir~conons

—

Pipe machine room

Abatemern

prn’eaure

*

Parsons

Sac

House

November

30,

1972

U

,x~ciustr~

-

coducts

Division

t~

~

and

Frictions

~taterial

Dect~

‘c:roe

of

emissions

-.

‘~h

booth

stack

~orexrent

procedure

—

ange

in

Product

Formulation

February

23,

19’i

our-ce

of

emissicns

—

nduct

manufac curnng

and

finishing

curt

inery

nxterornt

procedure

-

~‘~lrces

and

dry

bag

collectors

-

-

-

-

semen

April

30,

1Y13

‘h

P~U’s oil

Department

~r~ii’

?

:f

emissions

—

Beater

Fi:Ll

Station

~‘

be

once

procedure

Aoiii:oaticn

~f

~oai_ng

Procedure

iu.: m:cx

Department

-scone

U’

emnssion

—

Superex

Srrmu:Laticg

the

reins

in.

Procedure

—

Jhanqe

in

drcduc:

urums :~o

eLiminatinc Asbestos

---

The recommendation of the Agency proposes

the granting of

the variances as requested,

subject to the terms and conditions

hereafter noted.

In touring the plant, Agency representatives

observed spillage from multi-ply craft bags containing raw asbestos.

Portable and mobile vacuums were used

to clean up the spills.

The

Agency states that overall housekeeping was

found to be efficient

throughout the entire plant.

Some

odors were detected within the

plant resulting from solvents and chemicals,

but none were detected

outside.

No visible emissions were observed within the plant or

emanating from the plant.

No objection has been filed with the Agency

to the granting of the variances.

Interviews with six residents

nearest the plant disclosed no objection to the variance application.

The Agency recommends that the variances be granted subject

to the following terms and conditions, all of which have been agre~.d

to on oral represenation by counsel for petitioner before this Boail.

“1.

All necessary permits shall be obtained, including

permits for modified beaters in the Millboard Depart-

ment of the Industrial Products Division,

2.

Monthly reports shall be submitted to the Agency in

writing, outlining the progress made in achieving

compliance.

3.

Where compliance is

to be achieved by the installation

of air pollution control equipment, within 30 days

of the completed installation of such equipment,

petitioner shall submit to the Agency for its approval

results of stack tests performed on such equipment.

Testing shall be done in accordance with Rule 651

by an independent testing organization acceptable

to the Agency,

and the Agency shall be notified 7 days

in advance of testing so that Agency personnel may wit-

ness the tests.

4.

Within

30 days of the Boardrs Order in this case,

Petitioner shall submit to the Agency in writing:

(1)

a procedure to prevent bag breakage and

(2)

a procedure outlining spillage clean up operations.

5.

Petitioner shall obtain a bond in

a form acceptable

to the Agency in an amount necessary to ensure com-

pliance with the Order entered by the Board in this

case.”

—8—

5

—

492

---

In its petition,

the petitioner goes

into a detailed analysis

of the consequenceswhich would result from a denial of the variances

sought, premised on the abandonment of operation because of non-

compliance

to April

30,

1973, when compliance would be achieved.

The petitioner’s allegations of hardship detail the substantial un-

employment which would ensue from a plant

shut-down

and

the

depriva-

tion of petitioner’s products to the many customers, both public and

private, presently dependent on them.

No useful purpose would be

served

in this opinion by an exhaustive discussion of the many hard-

ships

that would be imposed on the company, its employees and its

customers if the variances were denied.

Petitioner has taken exten-

sive

measures,

both

before

and

after

the

adoption

of

the

Asbestos

Regulations

to

bring

its

operation

into

compliance.

The

regulations

are new and the proposed schedule of compliance appears reasonable

in

consideration

of

the

size

of

the

operation,

the

proliferation

of

emission

sources

and

the

results

to

be

achieved.

The

programs

proposed

for

the

facilities

not

presently

in

compliance

appear

well-considered

and

not

demanding

of

inordinate

time

for

accomplishment.

We

believe

that the hardship imposed on the company and others if the variances

were denied to greatly exceed the burdens resulting to the community

in

permitting

petitioner

to

continue

its

present

emissions

until

April 30,

1973,

as the outside date,

pending implementation of its

compliance

and

abatement

program.

We

grant

the variances for the

periods

proposed

in

the

petition,

subject

to

the

terms

and

conditions

suggested

by the Agency,

as set forth in our Order.

This Opinion constitutes the findings of fact and conclusions

of law of the Board.

IT

IS THE

ORDER

of

the

Pollution

Control Board that petitioner,

Johns-Manville Products Corporation, be allowed to emit asbestos

fibers into the ambient air in excess of the limits provided in

Rul~651(a) and 652 of the Asbestos Regulations

(Chapter 2, Part VI,

Air Pollution,

Asbestos and Spray Insulation and Fireproofing)

from the following listed facilities, for the periods of time

specified,

to enable installation of abatement procedures as indi-

cated, subject

to the terms and conditions hereinafter set forth.

Division

and

Source

of

Emission

and

Abatement

Procedure

to

be

Installed

Variance

requested

to

1)

Residential Products Division

Source

of

emissions

-

Asbestos

paper

machine

Abatement

procedure

-

Parsons Fabric Filter House

July 15,

1972

2)

Pipe

Division

Source

of

emissions

—

Pipe machine room

Abatement

procedure

-

Parsons Bag House

November 30, 1972

—9—

5

—

493

---

3)

Industrial Products Division

(a)

Packing and Frictions Material Dept.

(i)

Source of emissions

-

weigh booth stack

Abatement procedure

-

Change in Product Formulation

February 28,

1973

(ii)

Source of emissions

—

Product manufacturing and finishing

machinery

Abatement procedure

-

Cyclones and dry bag collectors

in series

April

30, 1973

(b)

Miliboard Department

Source of emissions

-

Beater Fill Station

Abatement procedure

-

M~c1ific~1-inn

of

Beater Loading Procedure

April

30, 1973

(c)

Superex Department

Source of emission

—

Superex Formulating

Station

Abatement Procedure

—

Change in Product

Formulation Eliminating Asbestos

December 31, 1972

I.

All necessary

permits

shall be obtained, including

permits for modified beaters in the Miliboard Depart-

ment of the Industrial Products

Division.

2.

Monthly reports shall be submitted to the Agency

in

writing

outlining the progress made in achieving

compliance.

3.

Where

compliance

is

to be achieved

by

the

installation

of air pollution control

equipment,

within

30 days

of

the

completed

installation of such equipment.

Petitioner shall submit to the Agency for its approval

results of stack tests performed on such equipment.

Testing shall be done in accordance with Rule 651

by

an independent testing organization acceptable

to

the

Agency,

and

the

Agency

shall

be

notified

7 days

in

advance of testing so

that

Agency personnel may

witness

the

tests.

4.

Within

30

days

of

the

Board’s Order in this case,

Petitioner

shall

submit

to

the

Agency

in

writing:

(1)

a

procedure to prevent bag breakage, and

(2)

a

procedure

outlining

spillage

clean-up

operations,

---

5.

During

the

period

of

this

variance,

Petitioner

shall keep all presently operating abatement

equipment and devices

in working order and shall

continue all asbestos control practices presently

being pursued so

as not to increase the intensity

or frequency of asbestos emissions over those

which presently exist at the plant.

6.

Petitioner shall post a bond in the amount of

$100,000 in a form acceptable

to the Environmental

Protection Agency,

to ensure compliance with

the

Order entered by

the

Board in

this

case.

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

Illinois

Pollution Control Board,

certify that

the

above Opinion and Order was adopted on the

day

of

~

1972, by

a vote of

U’

to

___-,

—11—