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
—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
—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
—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
—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