RECE~V~D
CLERK’S OFFICE
ORIGINAL
JAN032005
STUART M. MAMBR
ROGER
B. HAUGHEY
LOTT H.
THOMAS
WILLIAM J.
BRINKMANN
DAVID
A. BAILIE
CRAIG J. CAUSEMAN
MICHAEL K.
CORNYN
RICHARD R.
HARDEN
DAVID
E. KRCHAK
BRUCE
B.
WARREN
JOHN
M.
STURMANIS
BIANCA T.
GREEN
KENNETH D.
REIFSTECK
MELISSA
A. THOMAS
CHARLES A. LEFEBVRE
BRYAN A. PERRERO
CHRISTOPHER M. KANIS
DAMIAN P.
MARSHALL
Ms. Dorothy M.
Gunn,
Clerk
Illinois Pollution Control Board
100 W. Randolph,
Suite 402
Chicago,
IL
60601
STATE OF ILUNO~S
3~v~tj~contro;
Bo~rr~
(190 1-1990)
WALLACE M. MULLIKEN
(1913- 1967)
OF COUNSEL
GEORGES. MILLER
TELEPHONE: 217-351-1500
FAX:
217-355-0087
E-MAIL:
tmh~B).1rnh-Iaw.corn
www.Inlh-Iawcom
RE:
People v. Alloy Engineering & Casting Company
PCB 01-155
(RCR1~Enforcement
-
Air, Water)
Dear Ms.
Gunn:
Enclosed
for
your
information
and
filing
is
a
Notice
of
Comp1etioi~ prepared
in
behalf
of
Alloy
Engineering
&
Casting
Company.
I would
ask that
this notice
be brought
to the attention
of
the
Board,
as
appropriate,
such
that
this matter
is
dismissed.
If
there
is
a preferred
method
for securing
the
dismissal,
please
advise
DEK/cjm
Enclosure
c:
Mr. Robert Stanford
Mr. Joe Wells
Sincerely,
THOMAS,
MAMER & HAIJGHEY, LLP
David
E.
Krchak
THOMAS, MAMER & HAUGHEY, LLP
LAWYERS
NATIONAL CITY
BANK BUILDING
30 MAIN
STREET, STE 500
CHAMPAIGN, ILLINOIS
6 1820-3629
MAILING
ADDRESS: P0 BOX
560
CHAMPAIGN,
ILLINOIS 61824-0560
krchak@tmh-law.com
December 27,
2004
ORIGINAL
REGE~VED
CLERK’S OFFICE
ILLINOIS POLLUTION CONTROL BOARD
JAN
032005
PEOPLE OF THE STATE OF
ILLINOIS,
p~~~r~oard
Complainant,
v.
)
PCB 01-155
(RCR~Enforcement
-
Air, Water)
ALLOY ENGINEERING
AND
CASTING COMPANY,
-
Respondent.
NOTICE
Now
comes
the
Respondent,
Alloy
Engineering
and
Casting
Company,
a Nevada corporation,
by its
attorneys,
Thomas,
Mamer
&
Haughey,
LLP,
by
David
E.
Krchak,
and
as
a
Notice
in
this
matter, provides as follows:
1.
On
February
4,
2003,
the
Respondent
executed
a
stipulation
to
resolve
pending
matters
in
this
case,
which
Stipulation
for
Settlement
was
executed
by
the
Illinois
Environmental
Protection
Agency
on
January
31,
2003,
and
the
Attorney General,
State of Illinois,
on February
6,
2003.
2.
The Stipulation and Order was the subject
of a public
hearing
in Champaign,
Illinois,
on March
25,
2003.
On July
10,
2003,
the
Illinois
Pollution
Control
Board
unanimously
found
that
the
Stipulation
was
an
appropriate
resolution
to
the
matter,
and
incorporated
the
following
provisions
of
the
Stipulation into their Order:
A.
Alloy pay a civil
penalty
of
$75,000.00 no later than
October
8,
2003.
B.
Alloy
perform
three
Supplemental
Environmental
Projects
(SEP’s) within two years of the entry of the Order.
3.
On
October
1,
2003,
the
Respondent
submitted
a
cashier’s
check
in
the
sum
of
$75,000.00
drawn
on
Central
Illinois
Bank
and
payable
to
the
Illinois
Environmental
Protection
Agency,
designated
to
the
Environmental
Protection
Trust Fund.
4.
The
first
SEP
involved
the
implementation
of
electronic
photohelic
controls
to
improve
the
pulsing
cleaning
system
of
emission
control
devices.
This
SEP
was
to
be
completed by September
1,
2003.
The Illinois EPA was advised on
August
25,
2003,
that the project was completed and the controls
were
implemented.
Mr.
Darwin
Fields
of
the
Illinois
EPA
confirmed on November
13,
2003,
that the installation had indeed
been completed.
(See
Exhibit
1,
letter from Lawson
“Joe”
Wells
to Ms. Crystal Myers-Wilkens dated November 14,
2003.)
5.
The
second SEP involved the repair and replacement
of
emission
control
ducting.
The
deadline
for
that
project
was
July
17,
2005.
The
Illinois
EPA was
advised
on May
7,
2004,
that
the project
had
been
completed.
(See
Exhibit
2,
letter
2
dated
May
14,
2004,
from
Lawson
“Joe”
Wells
to
Ms.
Crystal
Myers-Wilkens.)
6.
The
third
SEP
required
the
implementation
of
broken
bag detectors
in exhaust stacks of the emission control devices.
The deadline
for
implementation
of
those
improvements
was
July
17,
2005.
On
December
1,
2004,
the
Respondent
advised
the
Illinois
Environmental
Protection
Agency
that
SEP
#3
had
been
completed
by
December
1,
2004.
(See
Exhibit
3,
letter
from
Lawson
“Joe”
Wells
on December
10,
2004,
to Ms.
Crystal Myers-
Wilkens.)
7.
With
the
completion
of
the payment
and
all
three
of
the
SEP’s,
the
Order
of
the
Board
of
July
17,
2003,
has been
fulfilled.
WHEREFORE,
the Respondent
prays
that this Notice
be placed
on file with the Illinois Pollution Control Board and the matter
be closed.
Respectfully submitted,
ALLOY ENGINEERING
AND
CASTING
COMPANY
BY:
THOMAS,
MAMER & HAUGHEY, LLP
BY
DA~.
~
3
CERTIFICATE OF SERVICE
DAVID
E.
KRCHAX
hereby certifies
that
he mailed
a
true and
correct copy of the foregoing NOTICE to:
Dorothy M.
Gunn,
Clerk
Illinois Pollution Control Board
100 W.
Randolph,
Suite 402
Chicago,
IL
60601
Thomas Davis
Assistant Attorney General
Chief Environmental Bureau
500
S.
Second St.
Springfield,
IL
62706
Crystal Myers-Wilkens
Illinois Environmental
Protection Agency
Bureau of Air
Division of Legal Counsel
P.O. Box 19276
Springfield,
IL
62794-9276
John McMahon
Wilkie & McMahon
One Main St.,
Suite 214
Champaign,
IL
61820
Robert M.
Olian
Sidley, Austin,
Brown & Wood
Bank One Plaza
10
S.
Dearborn St.
Chicago,
IL
60603
Kevin Ward
Cox & Ward,
P.C.
612 Spring Street
P.O. Box 252
Galena,
IL
61036
4
by
placing
same
in
the
U.S.
Mail,
first
class
postage
fully
prepaid,
on the
27th
day of December,
2004.
David E.
Krchak
THOMAS, MAMER
& HAUGHEY, LLP
P.O. Box 560
Champaign,
IL
61824-0560
(217)
351-1500
5
alloy
engin~erinu
&
casting
company
1700 west washington street•
champaign, IL 61821
tel 2.17 398 3200
•
fax 217 398 3208
November
14, 2003
Illinois Environmental Protection Agency
Bureau ofAir
Division ofLegal Counsel
P.O. Box 19276
Springfield, Illinois
62794-9276
Attention: Ms. Crystal Myers-Willcens
Subject: Ordçr ofthe illinois Pollution ControlBoard
PCB
0 1-155
Dear Ms. Myers-Willcens
Pursuant to Illinois Pollution ControlBoard Order adopted on July 10, 2003
and
received at
Alloy Engineering & Casting Company on
July
17, 2003, the following is respectfully
submitted
to confirm compliance of the order.
A civil penalty of$75,000 was
submitted
to the Agency on October 1, 2003 which
was
due no
laterthan October 8, 2003.
A copy ofcashiers check #248706
is
enclosed for your reference.
As proposed byAlloy Engineering & Casting
Co
and
accepted by the Illinois Pollution Control
Board, Supplemental
Environmental
Project #1
was
to be completed by September
1,
2003.
The
subject
SEP
was
to implement
electronic
photohelic controls to the pulse
cleaning system offive
emission control devices at the Alloy facility in Champaign, Illinois.
As confirmation,ofcompliance to SupplementalEnvironmental Project #1, we offer the
following enclosed documentation for your consideration;
A) Project Labor Cost
Summary,
enclosed
and
labeled enclosure “B”,
costs associatôd with
planning and
installation ofthe electronic
B) Project Material Cost
Summary,
enclosed
costs associated with the electronic photohelic controls
I
I verbally advised Mr.
Darwin
Fields atthe IEPA Champaign Field Operations Office the week ~
of
August
25,2003 that SEP#1
had been completed prior to’the September
1,
2003 deadline.
alloy engineering
& casting company
__________
1700 west washington street ~champaign,
IL 61821
:
tel 217 398 3200
•
fax 2173983208
C).Photographs ofeach set ofphotohelic controls at the five respective pulse
type
emission control devices are on the attached CD diskette
and
labeled as.
Southwest emission control device
-
Photo’s 4,
5, 6, &
7
South emission control device
-
Photo’s 8, 9,
10, 11, & 12.
Torit emission control device
-
‘Photo’s
13,
14,
&
15
North CSI
emission control device
-
Photo’s
16,
18, & 20
•
.
‘
South CSI
emissioncontrol device
-
Photo’s
17,
19,
& 22
Be advised that Alloy Engineering & Casting Co is currently moving forward to implement
Supplemental Environmental Projects #2
& #3
as per the Illinois Pollution Control Boards order.
‘j’h~
board
order stated
that
the “Agency” be notified ofSEP completion.
Aside
from sending a
‘copy Of
this
notification to Mr. Jobn.Justice, I have not copied other departments
within
the
agency.
In the event
other departments require notification, please advise ofwho needs
:
notification
and
I will do so accordingly.
Also,
during a site visit and audit conducted by BOA-FOS
Mr.Darwin
Fields onNovember
13,
2003, Mr Fields was
shown
the photohelic control installation at one of the emission control
devices as
further confirmation.
Should you have questions pertaining to the above please do not hesitate to contact me at 217-
355-4190 or via email at joe.wells~aecco.com.
CC:
Mr. John B.
Justice
Illinois Environmental Protection
Ag~ii’~~4~
Bureau ofAir
.
Field Operations Section
2009 Mall Street
Collinsville, Illinois
62234
Mr. Mark Chandler
—
President,
Alloy
Mr. Robert Stanford
—
Controller, Alloy
Facilities, Maintenan,ce, & Safety
Enclosures’
EnvfronmentallLettersllPCB
SEP #1
confirmation 031100
a.
.
allay enginHering & casting
company
•
1700 west washington street’
champaign, IL 61821
•
.
tel2l73983200
•
fax2173983208
May 14. 2004
Illinois Environmental Protection Agency.
Bureau ofAir
Division ofLegal Counsel
•
P.O. Box 19276
Springfield, Illinois. 62794-9276
Attention: Ms.
CrystalMyers-Wilkens
Subject: Order ofthe Illinois Pollution ControlBoard
PCB 0 1-155
Dear Ms.
Myers-Wilkens
Pursuant to Illinois Pollution Control Board Order adopted on July
10, 2003
and received at
Alloy Engineering &
Casting Company on July
17, 2003, the following
is respectfully submitted
to confirm further cOmpliance ofthe order.
As per the IPCB order, a civil penalty has been submitted and Supplemental Environmental
Project #1
was completed per the order. Please reference Alloy Engineering & Casting Co’s
previous submittal dated November 14,
2003, which detailedthe specifics ofthe compliance.
As proposed by Alloy Engineering &
Casting Co and accepted by the Illinois Pollution Control
Board, Supplemental Environmental Project #2 has been completed. The subject SEP was to
repair or replace air emission control ducting withintwo years ofthe IPCB order.
I verbally advised Mr. Darwin Fields at the IEPA Champaign Field Operations Office on
May 7, 2004 that
SEP #2 has been completed, which is well in advance ofthe July
17, 2005
deadline.
Mr.Darwin Fields, IEPA
—
BOA
—
FOS,
is
scheduled to conduct a plant
audit and
review at the Alloy facility on Friday May 21, 2004
at which time I will confirm
implementation.
As confirmation ofcompliance to Suppieni~ntal~
-~
y~o~mentaI
Project #2,
following enclosed documentation for yourconsid~ratiô~.~
A) Project Labor Cost Summary, enclosed and labeled enclosure
costs associated with the repair or replacement of air emission
B) Projeát Material Cost Summary, enclosed and labeled enclosure “B’
costs associated with the repair or replacement of air emission
e
allay engineerinu
& casting company
•
1700 west washington street’
champaign,
IL 61821
te12173983200
•
C) Photographs depicting the installation ofrepresentative emission control devices
are on the attached CD diskette and labeled as enclosure “C”;
-
Photo’s
00,1, 002,
003, 017, 018, 019, 020, 021,.& 022 depicts the new emission
control ducting, drops, & damper control gates forthe Centrifugal Casting
Processes.
Reference AECCo purchase order J0443 on enclosure “B”.
-
Photo’s
004 & 005 depicts the additional ducting and damper control gates for
‘the CGC shakeout systent
Reference AECCo purchase order # J0443
on enclosure “B”
-
Photo #006 depicts the replacement elbow and damper control gates at the CGC.
Vibramill lump reduction machine.
Reference AECCo purchase order #A121I
on enclosure “B”
Photo’s. 007 & 008 depicts the skirting and dust capture enclosure at the CGC
Vibramill lump reduction machine.
Reference AECCo purchase order #J0443
on enclosure “B”
-
PhOto’s 009, 011, 012, 013, 014, 015, 016 depicts the emission
control ducting,
drops, hoods & damper controlgates installed in the CGC finishing department.
Reference AECCo purchase orders A1891 & A2927 on enclosure “B”.
-
In’ addition, theNorth CSI emission control device wastested and balanced
to ensure optimum operating capability.
Reference AECCo’s
purchase
orders A1243 & A1891 on enclosure “B“.
-
Photo 010 depicts the repaired elbow and damper control gate, which is
connectedto the CGC shot blasting
process, Reference AECCo’s
orders A227l
on enclosure “B”.
D) Copies ofAECCo’s purchase orders to a local mechanical contractor’
specializes in industrial ventilation & e~nj~sion
control have also
mcluded,
and labeled
attach~’~ik de~tthe
scope ofthe
Be advised that Alloy Engineering &
Casting
Co has issued the
implement
Supplemental Environmental Project #3 as per the Illinois Poi
order.
It is also
our
expectation to have SEP ~3 completed prior to the
again in advance ofthe ordered deadline.
e
alloy engineering.& casting company
__________
1700 west washington
street” champaign,
IL 61821
tel 217 398 3200
•
fax 217 3983208
The
board
order
statedthat the “Agency” be notified of SEP completion.
Aside from sending a
cOpy of
this
notificationto Mr. JohnJustice, I have not copied other departments withinthe
agency.
In the event other d~partments
require notification, please advise ofwhom needs
notification and I wifi do so accordingly.
Be assured that
although we have completed this particular SEP, we will continue to maintain
our emission control systems as
part
ofour‘continuous improvement programs and preventative
maintenance systems.
.
I would greatly appreciate acknowledgement ofthis submittal and your accepatance of
compliance.
.
.
Should you have questions pertaining to the above please do not hesitateto contact me at 217-
355-4190 or via email at joe.wells(~aecco.com.
Re~~~)~
La~n “Joe” Wells
~aager
~aci1ities, Maintenance, & E.M.S
Enclosures
CC:
Mr. John B. Justice
Illinois Environmental Protection Agency
Bureau ofAir
.
Field Operations Section
.
2009 Mall Street
Collinsville,
Illinois
62234
Mr. Robert Stanford
—
General
Ma~’~dL~,~
Alloy Engineering
& Casting”Cb:
Environmental/Letters/IPCB SEP
#2
confirmation
&Iuy
engineering
& casting
company
•
1700 west washington
street” champaign,
IL 61821
te12173983200
•
fax2173983208
December 10, 2004’
Illinois Environmental Protection Agency
Bureau ofAir
Division of
Legal
Counsel
P.O. Box
19276
Springfield, Illinois
62794-9276
-
• Attention: Ms. Crystal Myers-Wilkens
Subject: Order ofthe IllinoisPollution Control Board
PCB ‘01-1
55
Dear Ms. Myers-Wilkens
Pursuant to IllinoisPollution Control Board Order adopted on July 10, 2003, and received at
•
AlloyEngineering & Casting Company on July 17, 2003, the following is respectflully submitted
•
to confirm f1~ll
compliance ofthe order.
As perthe IPCB order, acivil penalty was
submitted and Supplemental Environmental Projects
#1
&
1i~2were c
mpleted perthe order. Please reference Alloy Engineering &
Casting ‘Co’s
previous subniittals dated November 14, 2003
& May 14, .2004, which detailed the specifics of
the compliance.
‘
As proposed by AlloyEngineering
&
Casting
Co
and accepted bythe IllinoisPollution Control
Board,
Supplemental Environmental Project #3 has been completed.
The subject SEP was to
install
broken bag detectors in exhaust stacks ofemission control devices
within
two years ofthe
IPCB order.’
I verbally advised Mr. DarwinFields at the. IEPA ChampaignField Operations Office on
December
1, ~0O4that SEP #3 has been’completed, which is well in advance ofthe July
1
•
2005 deadline.
As confirmation ofcompliance to Supplemental EnvironmentalProject #3, we
following enclosed dOcumentation for ypur con~
A)
Project Labor Cost’ Summary, enclosed and lab~êl~’d~
costs associated with the broken bag detector project.
B) Project Material Cost
Summary,
enclosed andlabeled
costs associated with the broken bag detector project.
C) SEP project cost summaryfor compliance to
IPCB
orderPCB 01-1
and labeled enclosure “C”, details the total expenditures
for
a
e
aJloy engineering
& casting
company
1700 west washington
street
.
champaign, IL
61821
tel 217 398 3200
‘
fax 217 398 3208
which
exceeds the stipulated settlement
‘Penalty Offset”
by
$16,154.76.
D) Photographs depictinginstallation
ofthe respective broken bag
detectors and control
modules are enclosed which havebeen labeled as per thefollowing;
•
-
Photo’s
Ai,
A2,
A3, & A4
Northwest Micropul Modulaire Emission Control
Device
servicing
the
Electric
Arc Furnaces
-
Photo’s
AS,
A6,
A7, & A8
Southwest WheelabratorFrye Emission ControlDevice servicing the
Static Finishing & Centrifugal Casting
PhotoA9,Al0,& All
South Micropul Pulse-Air Emission Control Device servicing the Statiô
Foundry,
Static Shotbiast, & StaticMaterial handling
-
Photo’sAl2&A13
Torit Emission Control Device servicing the Static Green Sand Reclamation
-
Photo’s A14,
A15, &
A20
Northeast Griffen Emission ControlDevice servicing the CGC Induction Melt
•
Furnaces
--
Photo A16, A17, A22, & A23
,
North CSI Emission Control Device servicing the CGC Finishing,
Shot
•
blasting; & Material Handling
-
Photo
A18, A24,
& A25
•
South
CSI Emission Control Device servicing the CGC Cooling
Material Handling
-
Photo
Bi, B2, B4, & B5
~
‘.4
j~f~
Emission ControlDevice
s~rvIcin
g~tbe
CGC Sand
•
.
•
•
‘
I would be pleased to
accommodate a visit from Mr. Fields at his
confirmation
ofproject
installation
is necessary.
The board order.stated that the “Agency” be notified ofSEP
completion.
copy ofthis notificationto Mr.
John Justice, I have not copied other dei
‘agency.
In the event other departments require notification, please advise
notification and I will do so accordingly.
alloy engineering
& casting
company
__________
1700 west washington street’
champaign,
IL 61821
tel 2173983200.’
fax 217 398 3208
•
Be assured
that
although
we have finalized compliance of
IPCB
order
#01-155,
we
are
•
committed
to
maintaining
our emission control
systems
and
our
environmental management
systems
as
part
ofour continuous improvepient
programs and
preventative maintenance systems.
.1 would greatly appreciate acknowledgement ofthis submittal
and
your acceptance of
compliance.
Should you
have questions pertaining to the above please do not hesitate to contact
me
at 217-
355-4190
or via
email atjoe.wells@aecco.com.
*~
Manager
•
Facilities, Maintenance, &
E.M.S
Enclosures
CC:
Mr. John B.
Justice
Illinois Environmental
Protection Agency
Bureau ofAir
Field Operations Section
2009
Mall Street
Collinsville, Illinois
62234
,
Mr. Robert,Stanford
General Manager /
CFO
•
Alloy Engineering & Casting Company
~
‘,~
Enviromflefltal/LettetSIIPCB
SEP #3
confirmation
