ILLINOIS POLLUTION CONTROL BOARD

November 15, 1989

ROWE FOUNDRY & MACHINE

COMPANY,

Petitioner,

)

PCB 89—122

(Variance)

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

DANIEL O’CONNELL APPEARED ON BEHALF OF THE PETITIONER.

JAMES O’DONNELL APPEARED ON BEHALF OF THE RESPONDENT.

OPINION AND ORDER OF THE BOARD (by J. Marlin)

This matter comes before the Board on an August 1, 1989

Petition for Variance Extension filed, by Rowe Foundry & Machine

Company (Rowe). Rowe requests an extension of the variance

granted in PCB 81—49 and extended irrPCB 88—21. Rowe requests an

extension of a variance from 3.3 Ill. Adm. Code 216.381 which

prohibits the emissions of carbon, monoxide from a cupola if the

concentration of carbon monoxide in the gasses emitted from the

cupola exceeds 200 ppm corrected 

50 excess air.

A hearing was held at Clark County Courthouse, Marshall,

Illinois, on September 27, 1989. No members of the public

participated in the proceedings. The Illinois Environmental

Protection Agency (Agency) filed its Recommendation on September

28, 1989.

Background

The facts of this case remain substantially unchanged from

those outlined in the Board Order PCB 88-21 of February 23,

1989. Therefore, only a brief outline of the facts are included

herein.

Rowe operates a gray—iron foundry for the production of

counterweights. The facility is located in Martinsville, Clark

County, which is considered an attainment area for carbon

monoxide.

The subject of this variance extension is a Whiting No. 9

Cupola. The cupola is charged with approximately 3,300 pounds of

~oundry coke, 1400 pounds of limestone and 28,000 pounds of scrap

on per hour. A scrubber controls particulate emissions.

bon monoxide emissions remain uncontrolled.

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2

History

Rowe was granted a five year variance on February 10, 1983,

(PCB 81—49). On February 23, 1989, Rowe was granted a 

variance

extension until August 1, 1989, (PCB 88—21). Rowe now requests

extension of variance until February 1, 1990.

Hardship

Rowe states in its petition that it can neither immediately

comply with Section 216.381 nor fulfill the original compliance

plan because of schedule disruptions that were not forseeable

when it submitted its original compliance plan. (Pet. 19—15).

Rowe states that unforeseen problems with the supplier of

the charging system and electrical demand restrictions placed on

the starter for the blower motor by Central Illinois Public

Service Company have caused unavoidable delays in construction of

the new cupola and scrubber system. (Pet. at 15). Rowe states

that shutting down operations is the only means to achieve

immediate compliance. (Pet. at 16).

The Agency in its recommendation states that Rowe had made

satisfactory progress during the variance extension granted in

PCB 88—21. (Ag. Rec. at 4). Also the Agency states that Rowe

has expended approximately $380,000 toward installation of the

new equipment. (Ag. Rec. at 4).

Therefore the Board finds that Rowe has presented adequate

proof that immediate compliance would constitute an arbitrary or

unreasonable hardship.

The Board hereby grants Rowe’s requested variance extension

from 35 Ill. Adm. Code 216.831 until February 1, 1990. However,

the Board grants the variance subject to certain conditions, set

forth in the Order below.

This Opinion constitutes the Board’s findings of fact and

conclusions of law in this matter.

ORDER

The Board grants extension of variance to Rowe Foundry

Machine Company from 35 Ill. Adm. Code 216.381 until February 1,

1990, subject to the following conditions:

1.

Rowe 

will continue to pursue the construction and

installation of a new

cupola 

with a

carbon monoxide

control system and shall achieve compliance by February

1, 1990.

2.  Rowe shall submit quarterly reports to the Agency on the

operation of the cupola.

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3

3.  Rowe shall implement and maintain the housekeeping and

maintenance plan set forth below:

A.  The size of the scrap iron pieces entering the

cupola shall be small enough so as to prevent

clogging of the cupola, thus necessitating the

momentary shutdown of the pollution control

equipment. At no time shall Rowe attempt to melt

pieces of iron longer than 30 inches.

B.  All of the necessary replacement parts, including

fan blades and bearing sets, for the pollution

control equipment shall be on hand.

C.  Ensure that all pollution control equipment and

associated ductwork on the existing cupola are

maintained such that emissions from the source

continue to be emitted solely from the top of

Rowe’s existing stack.

D.  Implement a detailed housekeeping program designed

to keep the facility’s roofs, interior working

areas and adjacent outside areas clean of

particulate matter and those areas of the plant

free of foundry sand where the use of the sand is

not required for the molding in cooling of metal.

The housekeeping program shall consist of sweeping

all hard outside surface areas at least weekly.

Foundry sand shall be regularly swept up on the

inside of the foundry buildings and scooped off the

production floors. Accumulations of particulate

matter shall be removed from the roof at least

monthly.

Rowe shall inform all plant personnel of the

housekeeping and maintenance plan and that plan

must be complied with at all times.

4.  Rowe shall be limited to operation of the cupola twice

weekly.

5.  Rowe shall be limited to a production of 12.79 tons of

iron poured per hour.

6.  Rowe shall dismantle and remove the current cupola upon

completion of construction of the proposed system.

7.  Rowe shall verify with documentation to the Agency’s

Division 

Water Polution Control that the existing

wastewater treatment facility is adequate to handle the

discharge from the proposed cupola and scrubber system.

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8.  Rowe shall not violate the National Ambient Air Quality

Standards for carbon monoxide.

9.  Rowe shall submit any necessary permit applications to

continue to operate its current cupola no later than 45

days after grant of the variance extension.

10. Within 45 days after the date of this Order, Rowe

Foundry & Machine Company shall execute and send to the

Agency a Certificate of Acceptance of this variance by

which it agrees to be bound by the terms cnd conditions

contained herein. The executed Certificate shall be

sent to:

Illinois Environmental Protection Agency

Attention: James O’Donnell

Enforcement Programs

P.O. Box 19276

2200 Churchill Road

Springfield, IL 62794—9276

The 45—day period shall be held in abeyance for any

period during which this matter is appealed. Failure to

execute and forward the Certificate within 45 days

renders this Variance void and of no force and effect.

The form of the certification shall be as follows:

CERTIFICATION

I, (We)                       

having read

the Order of the Illinois Pollution Control Board in PCB 89—122,

dated November 15, 1989, understand and accept the Order,

rcali~ing that such acceptance renders all tern~ an~ c~niitior~s

thereto binding and enforceable.

Petitioner

Authorized Agent

Title

Date

11. Quarterly reports shall be sent to:

Mr. John Justice, Regional Manager

Division of Air Pollution Control

Illinois Environmental Protection Agency

2009 Mall Street

Collinsville, IL 62234

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Section 41 of the Environmental Protection Act, Ill. Rev.

Stat. 1987 ch. 111 ~ par. 1041, provides for appeal of final

Orders of the Board within 35 days. The Rules of the Supreme

Court of Illinois establish filing requirements.

IT IS SO ORDERED.

I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify that the above Order was adopted on

the

/..6~

day of  

1989, by a vote

of

7-~

Dorothy M./,i~unn, Clerk

Illinois ~ollution Control Board

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