ILLINOIS POLLUTION CONTROL BOARD

September 30, 1971

NATIONAL GRAY IRON FOUNDRY,

A DIVISION OF MO~JINE

MALLEABLE

IRON COMPANY

#PCB71—178

ENVIRONMENTAL PROTECTION AGENCY

SIDLEY & AUSTIN, ATTORNEYS FOR PETITIONER

FRED C. PRILLAMAN, ATTORNEY FOR RESPONDENT

OPINION OF THE BOARD (BY MR. LAWTON):

Petition was filed by National Gray Iron Foundry, a Division

of Moline Malleable Iron.Company, requesting variance from the Rules

and Regulations Governing the Control of Air Pollution until January 1,

1972, during which time Petitioner will install two Venturi Scrubbers,

replacing existing collection equipment presently operating in the

molding, shake—out, cleaning and core—making areas of its Belvidere

plantand thereby control all non—cupola process emissions.

An Air Contaminant Emission Reduction Program (Acerp) relating

to petitioner’s two cupolas was approved by the Illinoi~sAir Pollu-

tion Control Board on June 18, 1968 (Petitioner’s Exhibit #7, R.37)

which contemplated the installation of wet scrubbers on the cupolas,

all of which wereinstalled, completed and approved in 1969 (Exhibit

#17) by the Board. It does not appear that any emission control

program relating to the so—called in—plant or non—cupola portions

of the operation, consisting of the molding, shake-out, cleaning and

core—baking areas, was ever submitted to the Air Pollution Control

Board, notwithstanding inquiry directed to the petitioner by the

Technical Secretary of the Board dated December 19, 1967 (EPA Exhi-

bit #1, R.73, 219)

The Agency recommends allowance of the variance, subject to

the payment of a penalty and the submission of “a detailed plan for

the control of all emission sources at the plant site so that when

such emissions are controlled they will not, either alone or in

combination with air contaminant emission from other sources,

cause air pollution.” The Agency also recommends

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that a performance bond be posted and that compliance be ascertained

an independent testing firm.

We grant the variance to January 1, 1972, subject to the terms

and conditions hereinafter set forth in the decretal portion of

this opinion.

Petitioner is located in Belvidere, Illinois, and produces

gray and ductile iron castings for automotive, agricultural and

other industries. All operations, including the melting of raw

metal, the molding of the castings, as well as shake—out and clean-

ing processes and the manufacture of cores, take place on the plant

site.

Petitioner employs between 200 and 300 employees operating on

a five-day week. The plant processes approximately 24,000 pounds

of gray iron per hour and uses 150,000 pounds of sand in connection

with its molding and cleaning operations. Excluding the cupola

operation, which is not in issue in the present case, Petitioner’s

process weight rate is 175,000 pounds per hour. 2,000 pounds of

particulate emissions, consisting primarily of sand and foundry

dust are generated each sixteen—hour day, of which only approximate-

ly one-third is collected by equipment to be supplanted by the new

equipment proposed to be installed pursuant to this variance request.

In simple terms, a gray iron operation consists of the melting

of iron ore and scrap in cupolas, which molten metal is poured into

molds, which, after cooling, are removed from the metal by a shake-

out process and cleaned by sand blasting. The casting is then

ground and polished. Cores made of sand and oil are processed at

the plant and used in the mold operation. The shake-out, cleaning,

blasting and core operations all generate a substantial amount of

particulate emissions which presently are controlled inadequately

by two wet collectors and four dry bag collectors, which are to be

supplanted by two Venturi Scrubbers, one to be in the SPO and grinding

room area and another in the so-called Taccone area, Schematic

diagrams representing the present operations and proposed installa-

tions of both of these areas are in the record as Exhibits #27 and #28,

respectively. Pursuant to~permit granted by the Environmental

Protection Agency (Petitioner’s Exhibit #23, R.54), the installation

is approximately 75 completed. The final completion schedule is

for approximately November 1, 1971, and full operation of the new

Venturis will be in effect by January 1, 1972. Upon operation of

the two Venturi scrubbers, emissions from the in—plant operation

would not exceed .05 grains per standard cubic foQt, which is well

within the applicable regulations relating to this operation. One

of the present. wet collectors will be used for control of emissions

from the core—baking operation, which presently aie uncontrolled.

On the basis of the record, the amount of work done to date and the

2

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536

short date proposed for final completion, 

there does not appear

to be 

any reason why the variance should not 

be allowed. Denial

of the variance would impose hardship on the petitioner and its

employees 

and

customers disproportionate with the burden likely to

be suffered by the community if the 

variance is allowed for this

short period.

A more difficult question relates to whether a penalty should

be imposed as a condition to the variance because of petitioner’s

failure to file a proper air contaminant emission reduction program

covering the very operations to which this variance~relates.

There is no question that petitioner filed an implemented Acerp

relative to its cupolas, which, undoubtedly, would have been a

major source of continuing nuisance, hadthese emissions not been

abated. The record indicates that the cupola program was completed

as planned without delay or procrastination on the part of petitioner.

The record also supports the conclusion that notwithstanding petitioner’s

failure to file an Acerp relative to its in-plant operations, it

was pursuing a program of emission control, albeit one that was

not in compliance with applicable regulations. Numerous complaints

relative to petitioner~s operation have been received by the Agency,

many of which are appended to this recommendation, Several witnesses

appeared at the hearing and testified to the nuisance that was being

caused by the operation~ in many cases precluding outdoor activities

and necessitating the d7iosing of windows and deteriorating the paint

on houses. The ±~ecordindicates that some time lag has resulted from

the contractor’s failure to meet its precise time schedule, although

at the present time, the installation program appears to be substan-

tially consistent with that originally contemplated. On balance,

in consideration of petitioner~s abatement program relative to its

primary source of emissions being those from the cupolas, the efforts

pursued by it in correcting the in-plant emissions and the fact

that even at the present time, petitioner appears far ahead of most

foundries within the state in pursuing its obligations to abate its

emissions and improve the environment, this does not appear to be

an appropriate case for a penalty and none will be imposed.

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 be

granted a variance from the Rules and Regulations Governing the

Control of Air Pollution in the operation of its in-plant portion

of its foundries; heretofore described, until January 1, 1972, subject

to the following terms and conditions:

1. Prior to January 1, 1972, petitioner shall install two

Venturi Scrubbers to collect emissions from its molding,

shake—out, cleaning and grinding areas described as the

537

SPO area and Taccone area, so that emissions from all

process sources other than the cupolas will comply

with the Rules and Regulations Governing the Control

of Air Pollution, as applies to petitioner’s operation.

2. Petitioner shall post a performance bond in form satis-

factory to the Agency in the amount of $45,000.00, re~

presenting the approximate cost of the work remaining to

be done to assure complete installation of the two Venturi

Scrubbers by January 1, 1972 and compliance with para-

graph 1 of thi~Order. On or before February 1, 1972,

petitioner shall submit proof that the emissions from its

in—plant operation are in full compliance with all applicuble

regulations of the State of Illinois relative to air

pollution. Such testing shall be conducted by an indepen-

dent testing firm and notice given to the Agency when such

testing shall be conducted.

3. During the period of this variance, petitioner shall n~iL

increase the degree or intensity of its emissions beyoni

those presently being emitted.

I, Regina P. Ryan, Clerk of the Pollution Control Board, certify that

the above Opinion was adopted by the Board on the 30 day of

September       

1971

538