Illinois Association of

Springfield, IL 62704

Aggregate Producers

(217) 241-1639

John Ilenriksen, Executive Director

Fax (217) 241-1641

Glenda Schoening, Office Manager

Email iaap@hansoninfosys corn

flecember

RECEIVED

CLERK’S

17,2004

OFFICE

DEC 20

20134

Dorothy

Gunn,

Clerk

Illinois

Pollution

Control

Board

STATE OF ILLINOIS

100 W. Randolph,

Suite

11-500

Pollution Control Board

Chicago,IL6O~O.l

Re

Proposed New and Updated Rules for Measurement and Numerical Sound Emission

ç~C)

Standards / Amendments to

35

III. Adm. Code 901 and 910

I

Docket R03-9~

Final Comments

Dear Ms. Gunn:

The following final comments are submitted by the Illinois Association ofAggregate Producers

(IAAP), in accordance with Hearing Tipsord’s November 29, 2004 order entered in the above-

referenced rulemaking.

Blasting

operations at aggregate mines are regulated by the Illinois Department of Natural

Resources (IDNR)

in

accordance with the Section 65 of the Surface Mined-Land Conservation

and ReclamationAct (215 ILCS 7

15/6 5)

JDNR has promulgated regulations that subjectthese

blastmg operations to air blast or ground vibration monitoring, or both, as necessary to prevent

property damage and protect public safety

Both IDNR

and IAAP members employ highly

trained

seismograph operators to monitor air

blasts and ground vibrations

at quarries,

as required by State

law.

These

personnel use

seismographs with a low frequency response of 2.0 Hertz. As outlined in Dane Tittman’s

November 4, 2005 testimony, 2.0 Hertz instruments are the industry standard

for monitoring

quarry blasting. (Hearing Transcript, pp.16, 40-41). Mr. Tittman also testified that the 133 dB

maximum air over pressure limit in IDNR’s rules is a limit employed nationally to limit air blast

damage from the detonation ofexplosives. (Hearing Transcript, pp.16-17, 39-40, 42).

IDNR regulations do an excellent job protecting the general public from the impacts of air over

pressure that result from quarry blasting. Therefore, the IAAP respectfully submits that the

Illinois Pollution Control Board’s rules should be amended to defer to IDNR’s enforcement of

the Illinois aggregates industry in conformance with Section

6.5

of the Surface Mined-Land

Conservation and Reclamation Act

Buy The Goods And Services Of Our Associate Members

---

In the event that the Board elects to begin regulating quarry blasting operations, the IAAP

submits that Section 901.109(b) ofthe pending rulesshouid be amended to read as follows:

Section 901.109

Highly-Impulsive Sound From Explosive Blasting

b)

Compliance with outdoor peak sound pressure level limits in the following table

shall constitute prima facie level limits ofthis rule whenmeasured on such

receiving Class A orB land.

Equivalent Maximum Sound Pressure Level (Peak) Limits

in

Decibels

Lower Frequency Limit of

Receiving Class A Land

Receiving Class if Land

Measuring System for Flat

(dB)

(dE)

Response, a Variation from

Linear Response Of±or

-

3dB(Hz)

p0.1

135

140

~ 2.0 but greater than 0.1

4~ 133

447133

~60butgrcaterthnn20

130

135

These proposed amendments eliminate the references to 0.1 instruments (laboratory-grade

monitoring devices not used

in

the field) and 60 instruments (monitoring devices no longer

manufactured) In addition, these proposed amendments bring the air blast levels at both Class A

and Class B land to 133 dB, the limit employed nationwide to limit air over pressure from the

detonation ofexplosives In short, these amendments will ensure that our industry is subjected to

a single regulatory standard, whether our members are monitOring’ by 1DNR, the Board’ or by

interested citizens.

0

itive Director

of‘Aggregate Producers

Docket R03-9 Service List