ILLINOIS POLLUTION CONTROL BOARD

October 25, 1973

WIRCO CASTING, INC.

PETITIONER

v.

)

PCB 73—281

ENVIRONi”IENTAL PROTECTION AGENCY

RESPONDENT

EVERETT E. HART, GENERAL MANAGER, on behalf

of WIRCO CASTING,

INC.

DALE

TURNEP~,ASSISTANT ATTORNEY GENERAL, on behalf of the EN-

VIRONMENTAL PROTECTION AGENCY

OPINION AND ORDER OF THE BOARD (by Mr. Harder)

This action involves a request for a variance extension.

A variance was previously granted under PCB

73-4 which will ex-

pire October 12, 1973. Relief is again sought to operate Petit-

ioner’s cupola type furnace in violation of the applicable Air

Pollution Regulations.

An Agency recommendation was filed suggesting a one—year

grant pending findings at a hearing.

The hearing was held on

September 24, 1973, in New Athens, Illinois.

Wirco Casting, Inc., located in New Athens, St. Clair County,

Illinois, is engaged in the gray iron foundry industry. Petition-

er produces, among other things, castings to be used in the auto-

motive industry. Wirco owns a twenty—ton Ajax indu~tion furnace

along with the subject cupola and other equipment. Said induct-

ion furnace must by necessity be shut down for maintenance peri-

odically, and it is during these shutdown periods that Petitioner

wishes

to

operate its cupola.

The precise rule from which Wirco seeks relief is not men-

tioned in any documents in this action. Studying the “Air Poll-

ution Regulations” indicates that the rule in question may be

203 (a) “Particulate Emission Standards and Limitations for New

Process Emission Sources.” This may be true because Petitioner

nas

not seemed to avail itself of Rule 203 (c)

,

and may have there-

by fallen into a “New

Source” class. This interpretation would

then change the analysis presented in the Agency recommendation,

Page (5).

The

following is a table showing the extent of expected par-

9— 633

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—2—

ticulate emissions from Petitioner’s cupola.

Estimated

Cupola Process Emissions

Allowable

Melt Rate

Weight Rate

Particulates

203 (a) 203 (b)

4 T/hr.

5 T/hr.

22.4 lbs/hr.

6 lbs/hr. 12 lbs/hr.

3 T/hr.

3.75 T/hr.

15.8 lbs/hr.

5.3 lbs/hr. 9.92 lbs/

hr.

The difference

in emissions between the cupola and induction

furnace as calculated by the Agency using Compilation of Air Poll~

utant Emission Factors A.P-42, pp. 7-13, is as

follows:

Cupola Emissions

5.6 lb/T

Induction Furnace

1,5 lb/T

Emissions

Increased Emissions

4.1 lb/T

from cupola

The previous variance was granted subject to a number of con-

ditions, and

in

the main

the conditions were

adhered to. The ex-

ceptions in reporting were very minor and can be excused as simple

misunderstandings.

As mentioned the Agency recommended a grant pending findings.

The findings referred to were:

1. Th&t it

is unfeasible for Wirco to inven-

tory enough items to supply

its needs dur~

ing the down time to offset the use of

the

cupola.

2. That it is economically and technically un~-

feasible to install an additional shell on

the induction furnace to eliminate the down

time on the induction furnace.~

As mentioned in the opinion on PCB 73-4, in addition to Point

(1)

above, more information would be required regarding Petition—

er~sfinancial status if an extension were to be granted.

At

the

hearing held on September 24, 1973, the above points

were all addressed.

Ability

to Stockpile:

Mr.

E. Hart testified at the

hearing

as

to

Wirco’s ability

to

stockDlle castings, The

points made by

Mr..

Hart included the

fact

that stockpiling

was

unf:easihle

because

the Petitioner

is now

working twenty~four hours

a

day

to

keep up.

and that. their lead

times

are such that

shipment

must he right ofi

Lec line ~

,

2

-~3bLt1Oner ~urteer

e3a~me ttac ~hr’r~ ~s ~o

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—3—

room on the property to store castings (H. 5) and that to store

gray iron castings requires a heated and humidifed storage area

to abate rusting (H. 6).

The

use of an additional (spare) shell for

the existing in-

duction furnace was also discussed during the hearings. Mr. Hart

testified that investigation into the use of a spare shell was un-

dertaken. He pointed out that the shell would weigh forty-seven

and a half tons (R. 10)

,

and that installing it would require the

use of a crane. Also removal of the roof of the building would

be required (R. 11). The cost of this unit including installa-

tion would be in the area of $135,000 (R. 16)

.

Perhaps the most

important factor is that even if a spare shell were on hand, the

down time for replacement would be about the same as

a normal re-

pair job CR. 11). It is clear from this testimony that the pur-

chase of a spare shell would be unfeasible.

Included in Wirco’s variance petition (Pg. 14-22) is a fair-

ly detailed financial statement. This statement shows that while

Wirco’s

position is improving, the expenditure required for com-

pliance would impose a hardship on Wirco at this time. Profits

for 1972 were $1,940.59 on sales of 1.8 million dollars, versus

a loss of $74,000 in 1971.

As mentioned above Petitioner by his own statement (R. 5)

says: ‘~Weare working to capacity twenty-four hours a day.” This

would seem to indicate a healthy business outlook, and must be con-

sicicred in any future extensions.

Petitioner makes his hardship case on the fact that a loss

of

production time would constitute a loss of accounts (H. 8)

“Q. What: I was getting at then there is a

good probability a customer that needs

it (parts) on this short—term basis

would go elsewhere if you had to be

closed down a week or a week and a half.

A. Yes, that is true. That has ~ap~ened

to us, We had a breakdown or two when

it was demonstrated,”

In.

that this

is

a variance extension the

other

hardship

van-

ebbs are assumed to apply:

e.g., the possible layoff of production

personnel

(90 employees). Wirco also states that the cost of corn—

ps:Lance Would be proni.oiteve

~n that the oniy two alternates

are:

1. Purchase of a spare induction furnace

$20

(~

---

—4—

2. Purchase of controls for the

cupola

furnace

-

$100,000.

Petitioner suggests that

the

cupola “may” be replaced

within

five years as business

conditions allow. During

this time Petition-

er requests operation of the cupola for a period of 56 days per

year.

The effect on the environment by the use of Petitioner’s cup-

ola must now be explored. Wirco is located in a sparsely settled

area one-half mile outside the city limits of New Athens, a town of

2,000 people.

No

complaints have been received by the Agency re-

garding

the

operation of Petitioner’s cupola.

The

closest residence

to Petitioner’s foundry is 413 feet, and a total of six residences

are

within

2,062 feet of

the

foundry.

Agency’s exhibit ~1 contains a dispersion model, the last line

stating

(H. 30)

,

“The chances of Wirco creating a general pollution

oroblen: are very rninimal.’~ The Air Quality Standards regarding par-

ticulates are:

Primary: 260

ug/m3

and

Secondary: 150 ug/m3

-

max. 24

hr.

conc.

The air quality as renorted in the June 1973 “Air Ponit~’ring

Network Report” by the

Illinois Environmental Protection Agency

was 76 ug/m3 max. 24 hrs. for the closest station.

The Agency recoimnends a 25—day/year variance.

Testimony (H.

20) by Petitioner is that 40 days/year is a bare minimum.

In its

closing statement (H. 33) the Agency tends to agree that 40 days/

year would be more appropriate.

The Board agrees.

One further point,as in PCB 73-4

Petitioner is again put

on

notice that should it request an extension of this variance a de-

tailed financial statement will be required to ascertain whether

Petitioner can move up

its five year program to purchase a new

in-

duction furnace.

Proof will also be required as to whether Petit-

ioner is working twenty—four hours per dayr seven days a week, to

produce enough parts via

its induction furnace so as to make up

for

lost production time wuile said furnace is down for maintenance.

The Board will not continue to grant extensions without a firm

commitment on Petitioner’s

part as to a definite comnliance date,

or a very strong financial hardship case.

This Opinion constitutes

the findings of fact and conclusions

of law of the Board.

ORDER

IT IS THE ORDER of the Pollution Control Board bliat a var

iance he granted to Wirco Casting, Inc., until October 12, 1974,

subject to the following conditions:

9— 636

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—5--

I. Petitioner shall not operate its gray iron cupola

furnace in excess of the following limitations:

A) The gray iron cupola furnace shall not be op-

erated in excess of 40 days during the period

of this variance.

B) During any one day of operation, the gray iron

cupola shall not exceed thirty (30) tons of

gray iron castings.

C) The operation of the gray iron cupola shall

not have a melt rate that exceeds four (4)

tons per hour.

II. Petitioner shall maintain and keep in good operating

order and operate during all times when the gray iron

cupola is operating its afterburners and wetcap con-

trol devices on the gray iron cupola.

III, Petitioner shall inform the Agency of the projected

operation of the gray iron cupola

furnace, in writ-

ing, at least forty-eight

(48) hours prior to the

use of the gray iron cupola.

IV. After each period of operation of Petitioner’s gray

iron cupola furnace,Petitioner shall supply to the

Agency, in writing, forty—eight (48) hours after such

period of operation

the

following information concern-

ing its gray iron cupola:

A)

The number of days during the period of operation

that Petitioner operated its gray iron cupola.

B) The daily iron casting production for each day

Petitioner operated its gray iron cupola.

V. Petitioner shall submit to the Agency, with any request

for variance extension, information on the financial

position of the company and any other data to substant-

iate Petitioner’s claim that it is unable to purchase

control equipment on its cupola or purchase an addit-

ional induction furnace.

VI. The gray iron cupola shall be operated only in accord-

ance with Paragraph I of this Recommendation, and then

only when it is absolutely necessary that the induction

furnace be shut down for maintenance and repair. The

cupola and induction furnaces shall never be operated

concurrently.

IT IS SO ORDERED.

9—637

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—6—

I, Christan L. Moffett, Clerk of the Illinois Pollution

Control Board, certify that the above Opinion and Order was adopt-

ed by the Board on the ~

day of

&

,

1973, by a

voteof _____to ~

9— 638