ILLINOIS POLLUTION CONTROL BOARD

July

19,

1984

VILLA

GROVE

FARMERS

ELEVATOR CO.,

)

)

Petitioner;

)

)

)

PCB 84—53

)

ILLINOIS ENVIRONMENTAL PROTECTION

)

AGENCY,

Respondent.

MR.

DAVID

PRAHL,

OF VILLA GROVE FARMERS ELEVATOR, APPEARED FOR

THE PETITIONER;

MR. JOSEPH

R. PODLEWSKI, JR., ATTORNEYATLAW, APPEARED FOR THE

RESPONDENT.

OPINION AND ORDER OF THE BOARD

(by

B. Forcade):

This matter comes to the Board on a April 26,

1984, Petition

for Variance filed by Villa Grove Farmers Elevator Co.

(~Farmers”)

seeking a three—year variance from 35 Ill.

Adm, Code 212,462(d)

(old Rule 203(d)(8)(B)(ii) of Chapter 2:

Air Pollution),

That

regulation requires induced draft aspiration and a 90

by weight

particulate collection efficiency for dump pit areas.

On

May

31,

1984, the Illinois Environmental Protection Agency (“Agency~)

filed a recommendation that variance be granted with certain

conditions~

Hearing was held June

18, 1984 in Tuscola,

Illinois.

No public

comments

were

received,

Farmers

operates a country corn and soybean grain

elevator

in

Bongard, in Champaign County, about fifteen miles south

and

west

of Urbana,

The

elevator can store 350,000 bushels at

one

time

and handles about 904,000 bushels per year,

receiving

grain

from

the

farmers

for eventual shipment to market by truck

and

rail

(Pet,

pp.

1~2),

The

grain elevator presently consists

of

a

truck

dump

and boot

pit

grain receiving

area,

headhouse

rece:Lvir~g

legs,

a

dryer

leg,

a rack grain dryer,

nine

steel

storage

bins,

a

truck

and

rail

loadout

as well as the associated auxiliary

conveying

equipment

(Rec,

~2),

Farmers plans to tear

down

the

old

wooden

grain receiving and workhouse which had an open

dump

pit and

replace

it with new equipment.

The old structure is obsolete and

new equipment will increase their production rate and make Farmers

more competitive.

The

new equipment is totally enclosed and

will

reduce dumping time by two-thirds

(Pet,

p.

2),

Title

35,

Illinois

Administrative

Code,

Part

212,

Subpart

S

(Agriculture),

places restrictions on

the emissions from grain~

handling

and

drying

operations.

Section

212,462(b) requires

malor

dump

pit

areas to have an induced draft

air

stream,

and,

as

59-59

---

applicable

here~ pollut:Lon

control

equipment

with

a

particulate

collection

efficiency

of

not

less

than

90

by

weight,

Farmers

existing

operation

would

be

subject

to

this

limitation

except for

the

provisions

of

§212. 461 ic);

that

section

provides

an exemption

for

existing

grain

handling

operations

located

outside

of

a

major

population

area.

Since

~armers

presently

qualifies

for

the

exempt:~onr no

new

induced

draft/collection

system

is needed.

Farmers

need

only

comply

with

the

housekeeping

practices

of

§212.461(h).

However, Farmer~sreplacement of

the receiving and

workhouse constitutes modification of

the

facility, and

pursuant

to

§212.462(c)

Farmers modified faci:Lity will he subject to

the

induced draft!90

particulate

collection requirements.

The Agency has described Farmers as

an

insignificant

air

pollution source located in an isolated rural

county

that

is

in

attainment with total suspended particulate

(~TSP~)standards

(Rec. ¶~10,13).

Following an investigation, the Agency

calculated TSP

emissions

before

and

after

the

proposed

modi~

fication

as

follows

(Rec.~

9~

10—12)~

Emissions

Before

Modification

Dump

and

Boot

pit

7,56

tons

per

year

TSP

All other emissions

=

34.36 tons per

year

TSP

Total

Emissions

=

41. 92 tons per year TSP

Emiss:Lons

After

Modification

Dump

and

Boot

pit.

=

7.56

tons

per

year

TSP

All

other

emissions

5.88

tons per year

TSP

Total

Emissions

=

13.44

tons

per

year TSP

Thus,

while

total

TSP

emissions from Farmers will he reduced

by

approximately

68

as a result of

the

modifications,

the

emis-

sions

attributable

to

the

dump

and

boot

pit

will

remain

constant

at

7,56

tons per

year;

the allowable emissions for the dump pi6

would

be 0,76 tons per year

TSP.

The

cost

of

the

renovation

project for the facility is

$500,000~, about

one~~haifEarmer’s

total

net worth

(Pet.,

p~2).

Technology

for

the

dump

pit

controls

is

available

at

a

cost

or

approximately

$30, 000~ however

this added amount Farmers would

have

to

borrow

would

put

them over

the

limit

of 60

debt to

equity

~et

by

their

lender,

the

Saint

Louis

Bank

of

Cooperatives

(Pet.,

p.

2).

Thus,

Farmers

needs

more

time

to

reduce

the

debt

ratio

before

they

can

borrow

the

funds

necessary

to

finance

the

installation

of

dump

pit

controls,

Farmers

proposes

to

construct

aspiration

equipment

(cyclone),

pit

baffle,

arid

a

dust

bin,

which

the

Agency

believes

would

achieve

compliance

(Rec,,

¶16).

Farmers

proposes

completion

of

the

dunp

pit

pollution

control

equipment

by

September

1,

1987.

~

~

---

3

The Board will grant the requested variance,

The Board

finds that grant of variance will have minimal adverse environ-

mental impact,

since emissions during the variance period will

he

substantially below present emissions and the dump pit will only

be in operation during two harvest seasons

(a total

of 112.5

hours per year).

The Board finds that in view of the minimal

adverse environmental impact, immediate compliance would cause an

arbitrary or unreasonable hardship in that funding requirements

for pollution control equipment would exceed the debt/equity

ratio set by Farmer~slender,

The Board will condition this

variance on submission of a construction permit application and

program schedule for the dump pit

controls,

The Opinion constitutes the Board~sfindings of facts and

conclusions of law in this matter,

ORDER

Villa Grove Farmers Elevator is hereby granted a variance

from 35 Ill.

Adni, Code 212,462(b) subject to the following conditions:

1,

This variance shall expire September

1,

1987.

2,

No later than December 31,

1984, Farmers shall submit

to the Agency an application for a permit to construct

equipment on its new dump pit providing an induced

draft air stream confined and conveyed through air

pollution control equipment having an overall rated and

actual particulate collection efficiency of not less

than 90

by weight,

The equipment shall include,

at a

minimum, aspiration equipment

(H,E,

cyclone), pit

baffles, dust bin, and small dump pit enclosure,

3.

In

addition

to its application for a construction

permit, Farmers shall submit to the Agency no later

than December 31,

1984 a construction program schedule

which will provide a timetable for compliance with

Section 212,462(b)

not later than September 1,

1987.

4,

Within forty-five

(45) days of the adoption of the Board

Order in this proceeding, Farmers shall execute and

forward to:

Mr. Joseph R. Podlewski,

Jr.

Enforcement Attorney

Illinois Environmental Protection

Agency

2200 Churchill Road

Springfield, Illinois 62706

a Certificate of Acceptance and Agreement to be bound

by all terms

and.

conditions

of

this variance,

This

forty—five

(45) day period shall be held in abeyance

for any period during which this matter

is appealed.

The form of the certification shall

be as follows:

59-61

---

CERTIFICATION

Villa Grove Farmers Elevator Company hereby accepts and

agrees to be bound

by all

terms and conditions of the Order of

the Pollution Control Board in PCB NO. 84—53

dated

_________________

1984,

VILLA GROVE FARMERS ELEVATOR CO.

By: _________________________

As

Authorized

Agent

Title

Date

IT

IS

SO

ORDERED

Chairman

J.

D,

Dumelle

concurred.

I,

Dorothy M.

Gum,

Clerk of the Illinois Pollution Control

Board, hereby certify

the

above

Opinion

and

Order

were

adopted on

the

~

day

of

~

1984

by

a

vote of

~

~h~.~ii~n,Clerk

Illinois

Pollution

Control

Board