ILLINOIS

IOLLU~IONCDNTRDL

BOARD

February

15, 1979

KELSEY-HAYES WMPANY,

GUNITE

DIVISION,

Petitioner,

v.

)

PCB 78—115

ENVIBONMENTAL

P1OTECPION

AGENCY,

Respondent.

OPINION

AND

ORDER OF THE BOARD

(by Mr. Goodman):

On April 24, 1978 Kelsey—Hayes

Ccrapany,

Gunite Division (Kelsey—Hayes)

r~uested

variance

fran the Board’s

Air

Pollution Control Requlation for its

foundry

facility in Rockford,

Illinois.

No hearing was held in this matter,

and

the

Board has received no public

canment.

Kelsey-Hayes c~nsand operates a

foundry

located

in Rockford, Illinois

which

manufactures

autarotive specialties.

Their products utilize grey iron

produced

in

four gr~’

iron

cupolas and

lcw carbon steel

produced in

four

electric

arc

furnaces.

The

metals

thus

produced

are

poured into

nolds,

and

the

resulting

castings

are

machined

and

tested

before

marketing.

The

plant

enploys,

approximately

850

people

with

a

total

payroll

in

excess

of

$18,000,000

per

year.

The

subject

of

this

variance

petition

is

the

electric

arc

melting

opera-

tion

used

to

produce

the

steel

for

the

casting

operation.

Steel

is

produced

in

four

top

charged

arc

furnaces

all

having

nine

foot

diameter

shells

and

a

nc*ninal

capacity

of

six

tons

per

hour.

A

typical

charge

for

the

furnaces

consists

of

approximately

50

returns

and

50

purchased

scrap

including

5

turnings

and

20

bundles.

The

furnaces

maintain

a

typical

charge-meltd~n-

refining-tapping

cycle

consuming

approximately

60

minutes.

Notwithstanding

the

fact

that

Kelsey-Hayes

has

Agency-issued

operating

permits

for

the electric

arc furnaces,

there

have

been

several

violations,

particularly

with

respect

to particulate

emissions

that

were

not

being

ade-

quately

captured by

the

baghouse.

Upon

investigation,

Kelsey-Hayes

has

agreed

to

inplement

certain

improvements

which

they

estimate

will

cost

approximately

$230,000.00

and

will be

caipleted

by

June

30,

1979.

These improvements include

increased

maintenance

and

house-keeping

of

the

equipnent,

utilization

of

sane

additional

~uipnent,

elimination

of

the

use

of

oily

turnings

in

the

charge,

plugging

the

taphole

during

the

melt

cycle,

and

the

installation

of

a

new

baghouse

and

canopy

collection

system

over

each

furnace

for

control

during

the

charging

and

tapping

cycles.

The

Agency is

of

the

opinion

that

the

Kelsey—Hayes

project

ccinpletion

schedule

is

reasonable

and

that

upon

caupletion

it

will

result

in

canpliance

with

the

Board’s

rules

and

achieve

an

emission

reduction

of

approximately

300

tons

of

particulate

matter

per

year.

2

The

melting

facility

is

located

in

a

commercial

and

industrial area with

a

few

residential

areas

closely

adjacent.

The

two closest

monitoring

sites

to

the

Keysey—Hayes

plant

recorded

annual

geometric

means

for

total

suspended

particulates

of

44

micrograms

per

cubic

meter

and

55

micrograms

per

cubic

meter

in

1977.

Both

of

these

figures

fall

below

the National

Ambient

Air

Quality

Secondary

Standard.

The

Board

finds

that

Kelsey-flayes

has

acted

in

good

faith

and

was

unaware

of

the

particulate

emissions

f

ran

the electric

arc

furnaces

until

being

notified

by

the

Agency.

Considering

the

acceptable

program presented

by

the

company

for

alleviation

of

the

prthlem

and

the

lack

of

ambient

air

quality

prthlems

in

the

area,

the

Board

finds

that

it

would

be

an

arbitrary and

unreasonable

hardship

to

deny

the

variance

sought

herein.

The

Board

finds

that

Kelsey-Hayes

is

presently

unable

to

comply

with

the

Regulations.

We

will

order

the

company to

comply

with

certain

conditions

including

execution

of

the

schedule

of

canpliance

contained

on

pages

2—7

of

its

November

21,

1978

amendment

to

its

Petition

for

Variance.

This

Opinion

constitutes

the

finding

of

fact

and

the

conclusions

of

law

of

the

Board

in

this

It

is

the Order of

the

Pollution

Control

Board

that:

1)

Kelsey—Uayes

Company,

Gunite

Division

be

granted

variance

from

Rules

202

and

203

of

chapter

2

of

the

Board’s

Air

Pollution

Control

Regulations

for

its

electric

arc

furnace

facility

in

Rockford,

Illinois

until

June

30,

1979

subject

to

the

following

conditions:

a)

Kelsey-Hayes

Company

shall

execute

the

compliance

program

as

proposed

in

Section

2

of

the

amendment to

its

petition

for

variance

filed

with

the

Board

November

21,

1978,

which

amend-

ment

is

incorporated

by

reference

as

if

fully

set

forth

herein;

b)

Kelsey-Hayes

shall

submit

its

progress

reports

to

the Agency

every

t~

months starting

within

35

days

of

the

date

of

Order.

Reports

shall

be

submitted to

the Agency

at:

Environmental

Protection

Agency

Division

of

Air

Pollution

Control

Control Program

Coordinator

2200

Churchill

Road

Springfield, Illinois

62706

c)

Kelsey-Hayes shall apply to the Agency for all

necessary

opera-

ting

permits

within

35

days

of

the

date

of

this

Order;

d)

Kelsey—Hayes shall execute a

performance

bond as

required by

the

Environmental

Protection

Act

in

the

amount

of

$2000.00.

32—53 8

---

3

The

Bond

shall

be

submitted

to

the

Agency

at

the

address

noted

in

subparagraph

(b)

above;

e)

Within

45

days

of the

adoption

of

this

Order,

the

Kelsey-Hayes

Cc*tipariy

shall

execute

and

forward

to

the

Environmental

Protec-

tion

Agency

at

the

adress

noted

in

subparagraph

(b)

above

a

Certification

of

Acceptance

and

Agreement

to

be

bound

to

all

terms

and

conditions

of

this

Order.

The

45

day

period

shall

be

held

in

abeyance

during

any

period

this

matter

is

being

appealed.

The

form

of

said

certification

shall

be

as

follows:

CERfiFICATION

I

W,

_______________________,

having

read

and

fully

understanding

the

Order

of

the

Illinois

Pollution

Control

Board

in

PCB

78—115,

hereby

accept

said

Order

and

agree to

be

bound

by

all

of

the

terms

and

conditions

thereof.

SIGNED____________________________________

TITLE_________________________________

DATE__________________________________

2)

Kelsey-Hayes

is

hereby

notified

that

it

may

be

liable

for

non-

compliance

penalties under Section 120 of the Clean Air

Act

should

it

fail

to

achieve

compliance

with

the

Regulations

by

June

30,

1979.

I, Christan L. Moffett, Clerk of the

Illinois

Pollution

Control

Board,

hereby certify

the

above

Opinion

and

Order

were

adopted

on

the

j,~

~“

day

of

__________,

1979

by

a

vote

of

~

Ch1~LoE~7

d’~

Christan L. Moffett, (~1erk

Illinois Pollution Control Board