ILLINOIS POLLUTION CONTROL BOARD
March
3,
1977
HOMER
GRAIN COMPANY,
)
Petitioner,
)
v.
)
PCB 76—312
)
ENVIRONMENTAL PROTECTION AGENCY,
)
)
Respondent.
OPINION
AND
ORDER OF
THE
BOARD
(by Dr. Satchell):
On December
6, 1976 Homer Grain Company petitioned the
Pollution Control Board for a variance from Rule 203(d) (9) (B)
of the Board’s Chapter 2: Air Pollution Control Regulations
(Chapter 2).
The Environmental Protection Agency’s
(Agency)
recommendation in this matter was filed on February 1,
1977.
Homer Grain seeks a variance from Rule 203(d) (9) (B)
of
Chapter 2 until October
1,
1978 in order to install certain
air pollution equipment.
April
30,
1977 is the date by which
Homer Grain is required to achieve compliance with this regu-
lation.
Homer Grain operates a grain handling and drying
operation in Homer, Illinois in Champaign County.
Homer
is a
city of approximately 1400 people.
The facility is engaged
in
receiving, storing, cleaning, drying, handling and shipping
whole kernel grain.
The elevator employs
12 people with an
annual payroll of $200,000 per year and purchases approximately
$300,000 worth of operating supplies in Champaign County.
Approxi-
mately 10,000,000 bushels of grain are received and shipped every
year.
In the qrain facility are several dump
piU
do~cribedby the
Agency
d S
lo!
Iows
Dump pit Bi, annual throughput
-
2,000,000 bushels
Dump
pit B2, annual throughput
—
250,000 bushels*
Dump
pit B3, annual throughput
—
850,000 bushels
Dump pit Gl, annual throughput
-
3,400,000 bushels
Dump pit G2, annual throughput
-
2,600,000 bushels
Dump pit Cl, annual throughput
—
less than 300,000
bushels.
*“~n
air pollution control scheme will be installed on pits Bl,
132
and B3,
since they receive dry grain in excess of 300,000
bpy each.”
(Pet.
2).
25-39
—2—
There are three grain dryers with individual capacities of
6,000
bushels per hour
(BPH), 4,000 BPH and 1,500 BPH.
There
are also numerous storage units and numerous items of convey-
ing equipment at the facility.
By December
1,
1976 all three
dryers
should have been in compliance with Rule 203(d) (9) (C)
of Chapter
2.
Emission controls on dump pits Bl,
B2, and B3 are sched-
uled to be installed and placed in operation no later than
December 31, 1977.
The elevator has an elevated belt con-
veyor for which a dust collection control is presently being
installed and is due to be placed in operation during the
early part of 1977.
The Agency states that it has discussed the proposed
control program with representatives of Homer Grain on
several occa~ionsduring the past few months and has learned
additional facts not specified in the variance petition.
Presently,
Petitioner does not intend to install pollution
control equipment on major dump pits Gi and G2 due to sev-
eral factors.
Both dump pits are quite small
in actual
volume which makes the pits unsuitable for retrofitting
conventional aspiration type controls.
Furthermore, Peti-
tioner has not yet ascertained whether the operation of these
two dump pits causes excessive emissions.
Both dump pits are
used primarily for the receiving of wet corn which makes the
emissions much less than if the pits received dry corn.
Dur-
ing the harvest season these pits are run almost on a constant
basis.
Because of these factors the Agency states
it is willing
to allow Homer Grain to operate pits Gl and G2 after the con-
trols are installed on the other
dump
pits to see whether the
operation of pits Gi and G2 causes excessive emissions.
Accord-
ing to the Agency,
if excessive emissions are created Homer
Grain has agreed to control the pits satisfactorily or cease
using them permanently.
Operation of pits Gi and G2 subse—
quent
to December
31, i977 will be
done
For
purposes
of
receivinq
WUL
qrdi
ii
only.
Homer
Grain also stated to the Agency that other emission
sources wou1d~be controlled.
This includes
a conveyor belt that
transfers grain from the dryers to storage units.
According to
the Agency this conveyor belt will be controlled no later than
October
1,
1978.
The Agency further states that Homer Grain
agreed to control the railroad loadout system no later than
October
1, 1978 and to replace cyclones
at the top of the work-
house by October
1,
1978.
The Agency has observed the cyclones
25
—
40
—3—
to be frequently clogged and ineffective as emission controls.
During the Agency investigations in the past there has been
evidence of poor maintenance concerning the cyclones and the
elevated conveyor belt; however, this should be remedied with
equipment with reduced maintenance requirements.
The Agency has not received full details on the emission
control equipment for the railroad load out system;
however,
the Agency has received several aspects of this program, in-
cluding construction permit applications and has found the
program to date favorable.
The Petitioner and the Agency have
agreed upon a schedule for construction permit applications for
all control ç~eviceswhich have not yet received construction
permits.
Homer Grain has replaced three rack type dryers with
column type dryers at a cost of $550,000.
It is not clear
from the petition that this was solely for the control of
emissions.
Other expenditures to control emissions are pro-
jected to be approximately $300,000
(Rec.
5).
The nearest ambient air monitoring station to Homer is
in Champaign,
a distance of fifteen miles.
During 1975, at
the Champaign station, the average annual geometric mean for
particulate matter was 46 micrograms per cubic meter, well
within the allowable standards.
During the same period the
maximum 24-hour concentration was not exceeded.
In 1976 one
sample has exceeded the 24—hour maximum.
The Agency does not
regard this
as necessarily characteristic of the air quality
within Homer, Illinois.
Petitioner states that investment in pollution control
devices have created cash flow problems and that should acceler-
ation of the plan be necessary the business would be jeopardized.
The Agency states that since Petitioner’s program is substantial
and reasonable
it recommends that the Board endorse the program
subject to express conditions.
The Agency states that complaints have been received about
Petitioner’s operations in the past.
One complainant in par-
ticular expressed doubt as to whether Petitioner’s program was
adequate.
The Board has received one objection to the grant of
variance which gives a detailed complaint.
Petitioner’s com-
pliance plan as presented by the Petitioner and the Agency if
properly pursued should eliminate many if not all of the
objector’s complaints.
25
—
41
—4—
Petitioner’s hardship is apparently one of time.
Petitioner cannot do an adequate job of controlling
particulate matter by April
30,
1977.
The Board agrees
with the Agency that the program proposed
is reasonable.
Under these circumstances the Board will grant Petitioner
a variance subject to the Agency’s suggested conditions.
In addition, the Board will require a performance bond for
$100,000
to be posted with the Agency with release based
upon compliance.
This Opinion constitutes the Board’s findings of fact
and conclusions of law in this matter.
ORDER
The Pollution Control Board hereby grants Homer Grain
Company a variance from Rule 203(d) (9) (B)
of the Chapter
2:
Air Pollution Regulations until October 1,
1978 subject to
the following conditions:
1.
Only grain that needs conditioning shall be placed
in dump pits designated as Gl and G2 after Decem-
ber 31,
1977.
2.
A construction permit application for an emission
control system for the dump pits designated Bi, B2,
and 33 shall be submitted to the Agency no later than
July
1,
1977.
That emission control system as des-
cribed in the construction permit application shall
achieve compliance with all applicable standards no
later than December 31, 1977.
3.
The dry grain conveyor system, designated as Cony.
Dl on page 15 of the variance petition, shall be
equipped with an emission control system capable of
achieving compliance with all applicable standards
no later than October 1, 1978.
4.
A construction permit application for an emission
control system for the railroad load out process shall
be submitted no later than July 1,
1977.
That emission
control system as described in the construction permit
application shall achieve compliance with all applicable
standards no later than October 1,
1978.
5.
A construction permit application for an emission
control system to replace the cyclones on top of the
25 —42
—5—
workhouse shall be submitted to the Agency no
later than ~Ju1y1,
1978.
That emission control
system as described in the construction permit
application shall achieve compliance with all
applicable standards no later than October
1,
1978.
6.
The elevated, reversible conveyor belt which
traverses Maple Street shall be equipped with
an emission control system capable of achieving
compliance with all applicable regulations no
later than April
1,
1977.
7.
Petitioner shall post a performance bond in the
amount of $100,000 with the Agency to assure the
construction required for compliance.
The bond
will be submitted to:
Environmental Protection Agency
Control Program Coordinator
Division of Air Pollution Control
2200 Churchill Road
Springfield, Illinois 62706
8.
Within thirty-five days of this order Homer Grain
shall execute and forward to the:
Control Program Coordinator
Division of Air Pollution Control
2200 Churchill Road
Springfield, Illinois 62706
a Certification of Acceptance and Agreement to be
bound to all terms and conditions of this variance.
The form of that Certification shall be as follows:
CERTIFTC1~TION
I
(We),
______________________________,
havinq read and
fully understa;d±ngthe Order of the Illinois Pollution
Control Board in PCB 76-312, hereby accept said Order and
agree to be bound by all the terms and conditions thereof.
Signed by_
Title
Date
IT IS SO ORDERED.
25
—
43
—6—
I, Christan L. Moffett, Clerk of the Illinois Pollution
Control Board, hereby c~tifythe above Opinion and Order
were adopted on the
~
day of
¶~44.~L
,
1977 by a
vote of
.~.
c~
.
.
Christan L. Moffe4
lerk
Illinois Pollutioi4~-ControlBoard
25-44