ILLINOIS POLLUTION CONTROL BOARD

September

6,

1972

CRANE

PACKING COMPANY

(MORTON GROVE PLANT)

V.

)

PCB 72—131

ENVIRONMENTAL PROTECTION AGENCY

CRANE PACKING COMPANY

(CRYSTAL LAKE PLANT)

v.

)

PCB 72—132

ENVIRONMENTAL PROTECTION AGENCY

OPINION AND ORDER OF THE BOARD

(by Mr. Parker):

This Order supplements earlier Orders dated April

4,

1972 and May 17,

1972.

These are related variance proceed-

ings brought upon petitions filed March 31,

1972.

Petitioner

sought variances for its Morton Grove and Crystal Lake plants

from certain of the asbestos emission regulations until

October 31, 1972.

Public hearings were scheduled

(by Board Order dated

April

4,

1972) but cancelled after receipt of

the Agency

Recommendations and a letter from petitioner’s attorneys

dated May

15,

1972 indicating that the Agency recommendations

were acceptable to petitioner.

The Agency recommended

that

the variances be granted subject to certain conditions.

By Order dated May 17, 1972 we granted both variances

subject to conditions specified in several numbered para-

graphs of

the Order.

One condition

(par.

3) was that peti-

tioner report within

45 days on the economic feasibility of

performing

a stack test on emissions from the fabric dust

collector after installation.

We reserved the right, based

upon this report,

to order sudh tests to be performed as

might be necessary.

Petitioner has now notified the Board

(by letter dated

July

5,

1972)

that a stack

test will cost $700 to $1,200

and that petitioner

“does not feel that the expense of

running stack sampling as

a

‘proof of performance’ may be

necessary for compliance with the regulations.”

The Agency

in its reply

(letter dated August 11,

1972)

concedes that

5

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359

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emissions sampling is not absolutely necessary for proof

of compliance with the standards but argues that the $700

-

$1,200 cost of the stack

test is “neither excessive nor

abnormal”.

We have no record beyond these two letters

to look to

for evidence as

to the need for and economic feasibility

of stack testing in this situation.

We find,

however,

that

petitioner has failed to advance persuasive reasons why the

$700

—

$1,200 expenditure for stack testing would not be

reasonable under

the

circumstances here.

This Board has

often emphasized that stack tests give the best indication

of the actual performance of control equipment

(e.g.

see

In re: Emission Standards,

PCB *R7l—23, dated April

13,

1972,

page 9).

We accordingly order that petitioner conduct one or

more stack tests on emissions from the fabric dust collector

after

installation, and report the test results

to the Agency

and to this Board.

The Agency

is then ordered

to advise the

Board whether,

and

the extent to which,

the test results

affect the continuing grant of these variances.

I,

Christan

L. Moffett, Clerk of

the Illinois Pollution Control

Board,

hereby certify the above Opinion and Order was adopted

on

the

c”

day of\&~j~~L/~~

,

1972 by

a vote of

-~‘

to

~

.

.1

~

/fl~~ ~

Christan LJ~Øett

5

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