ILLINOIS POLLUTION CONTROL BOARD
June 4,
1992
IN THE MATTER OF:
)
)
GENERAL
MOTORS CORPORATION
)
R90-23
SITE-SPECIFIC EXCEPTION TO
)
(Rulemaking)
35 ILL.
ADM. CODE 216.381
)
FOR FERROUS FOUNDRIES IN
)
VERMILION COUNTY.
)
Proposed Rule.
First Notice.
OPINION
AND
ORDER OF THE BOARD
(by B.
Forcade):
This matter comes before the Board on the October 10,
1990,
proposal of General Motors Corporation
(GM)
for site-specific
relief from Section 216.381
(35 Ill. Adm. Code 216.381)
and GM’s
amended petition filed on December 21,
1990.
Section 216.381
limits the emission of gases containing carbon monoxide from
cupolas to a concentration of carbon monoxide of 200 ppm.
The
petition seeks exception to this limit for foundries located in
Vermilion County and imposes a limit of 2,000 ppm for carbon
monoxide emissions from cupolas in Vermilion County.
In a March 14,
1991,
order,
the Board determined that an
Economic Impact Statement was not required.
Hearings were held
on August 27,
1991 in Chicago, Illinois and on
August
29,
1991 in
Danville, Illinois.
The Illinois Environmental Protection Agency
(Agency) and the Department of Energy and Natural Resources
(DENR) participated in the hearings.
Several members of the
public also attended the hearings.
GM filed a memorandum in
support of the petition on October 30,
1991,
along with the
engineering studies and stack test reports requested at the
hearing.
Public comments were received from DENR and the Agency.
In
P.C.
#1, DENR provided the Board with a list of foundries in
Illinois.
The Agency,
in P.C. #2,
supported the proposed rule.
BACKGROUND
~M operates an iron foundry in Danville, Vermilion County,
Illinois, manufacturing iron castings for the automotive
industry.
These include brake drums,
bearing caps,
differential
carriers, water pumps and brake rotors.
The foundry is located
approximately 1.5 miles from downtown Danville,
in an area that
is predominately agricultural, with some residential sections.
134—157
2
(Tr.A’ at 12.)
Vermilion County has been designated by U.S. EPA
as either an attainment area or “unclassified” for carbon
monoxide. See 40.CFR 81.314
(1990).
(Tr.B at 15.)
General Motors contributed more than $80.7 million to the
Danville—area economy in 1990.
(Tr.A at 15.)
In 1990,
the
average number of employees on GM’S payroll at Danville was 1323.
(Tr.A at 15.)
The foundry produces more than 800 tons per day of
iron castings.
(Tr.A at 23.)
Divisions of GM account for 90
of
the sales while the rest is sold to other automotive
manufacturers such as Ford and Chrysler.
(Tr.A at 26.)
The
castings are also exported to France,
Canada and Mexico.
(Tr.A at
26.)
GM presently is using two cupolas
(Cupola
#2 and #3)
in its
foundry operation.
(Tr.A at 58.)
Cupola #2 typically melts
approximately 30 to 54 tons per hour; cupola #3 melts from 66 to
72 tons per hour.
(Tr.A at 59.)
A cupola is a vertical shaft
furnace which is fed or “charged” with layers of metallics, coke
and limestone (as flux).
(Tr.A at 61.)
The shaft
is 120 feet
tall and up to 132 inches in diameter.
(Tr.A at 61.)
Cupola
melting is used by GM to melt scrap metal.
More than 200,000
tons of scrap metal are remelted and made into castings at the
Danville facility each year.
(Tr.A at 60.)
Typical cupola exhaust gasses can contain 13 to 27 percent
carbon monoxide.
(Tr.A at 108.)
This is the equivalent of
130,000 to 270,000 ppm.
(Tr.A at 108.)
In a cupola, high carbon
monoxide levels and specific carbon dioxide ratios are important
to the metallurgical properties of the iron.
(Tr.A at 109.)
These levels can be minimized by proper selection of fuels,
charge material and by major facility changes but cannot be
eliminated.
(Tr.A at 109.)
In July of 1988, emissions tests of the cupolas showed
carbon monoxide emissions from both cupolas were in excess of 200
ppm.
Carbon monoxide was present at a concentration of 8,317 ppm
for Cupola #3 and 4,563 ppm for Cupola #2.
(Exh.
C—18,
Tr.B at
81.)
Subsequent tests showed carbon monoxide concentrations as
high as 16,053 ppm for Cupola #3.
(Exh.
C—18,
Tr.B at 81.)
As a
result of these tests, GM initiated an aggressive plan to modify
the system beyond the state-of-the art contemplated by the
regulations.
In November 1988, GM filed a petition for variance
(PCB 88-193)
in order to continue the operation of the foundry
while it implemented corrective action to reduce the
concentration of carbon monoxide in its emissions.
(Tr.B at 23.)
1
Tr.A refers
to the transcript
of
the August
27,
1991,
hearing.
Tr.B refers to the transcript of the August
29,
1991,
hearing.
134—158
3
As part of the variance petition, GM submitted a compliance
plan describing various activities to bring the emissions within
compliance.
(Tr.B at 23.)
In June of
1989, GM filed an amended
petition to provide a more recent,
and thorough, compliance plan.
GM has completed the compliance plan submitted with the original
and amended petitions.
(Tr.B at 24.)
While these modifications
have significantly reduced emissions,
compliance has not been
achieved.
Emissions have dropped from a high of approximately
18,000 ppm to below 2,000 ppm.
(Tr.B at 40.)
A consultant to GM suggested two additional modifications
that could be made to the cupola operation to reduce emissions.
The first suggestion was to pull more air through the system and
the second was to replace both cupolas and the fume control
systems.
The estimated cost of these modifications were $8.2
million and $52 million.
(Tr.B at 42.)
The consultant could not
guarantee that these modifications would result in compliance
with the 200 ppm carbon monoxide standard.
(Tr.B at 40.)
GM does not consider these alternatives economically
feasible and believes that a rule change is the best alternative
to achieve compliance.
ENVIRONMENTAL
IMPACT
A
computer modeling study demonstrated that carbon monoxide
emissions at the rate of 2,000 ppm would not cause an adverse
environmental impact in the area.
(Exh.
D—1, Tr.B at 116 -167.)
Vermilion County is either an attainment area or unclassified for
carbon monoxide.
The present emissions from the Danville
facility are less than 2,000 ppm.
The purpose of the site
specific rulemaking is to allow the same level of carbon monoxide
emissions that exists today.
(Am.
Pet. at 5.)
AFFECTED SOURCES
GM does not believe that there are any similar sites in the
state and is certain the there are no similar sites located in
Vermilion County.
In public comment #1, DENR provided a list of
foundries in Illinois classified as Gray and Ductile Iron
Foundry, the same classification as the GM foundry in Danville.
DENR provided this list to the Board for the purpose of informing
the Board of similar facilities in the state which may seek
similar regulatory relief.
There are 50 foundries in Illinois
with this classification.
However,
a similar classification does
not necessarily mean that these facilities are operating under
similar conditions as GM or are unable to comply with the 200 ppm
standard.
134— 159
4
The site-specific rule as proposed by GM would exempt all
foundries in Vermilion County from the 200 ppm standard for
carbon monoxide emissions and permit emissions of 2,000 ppm.
The list of foundries provided in P.C. #1 lists one other foundry
in Vermilion County, with the same classification as GM. The S.
T. Gallagher
& Son Inc. foundry is located in Hoopeston,
Illinois
in Vermilion County.
No additional information was provided
concerning this foundry or the emission of carbon monoxide from
the facility.
Therefore,
the proposed rule will be modified so
that the site—specific relief is limited to GM’s facility in
Danville.
TECHNICAL FEASIBILITY
AND
ECONOMIC REASONABLENESS
In the Board’s 1972, opinion adopting the carbon monoxide
emission standards, the Board noted that the 200 ppm standard
could be met with the use of inexpensive afterburners.
(Tr. B at
71,
Exh. C-14.)
See In the Matter of:
Emission Standards
(April
13,
1972),
R71—23,
4 PCB 298.
The costs of such afterburners for
a typical—size cupola, 54-inch inside diameter, amounted to
$2,400 in 1968.
(Tr.B at 71,
Exh.
C—l5.)
The GM plant in
Danville has had the type of technology contemplated by the
regulation in place for more than 20 years.
(Tr.B at 79.)
Even
with subsequent modifications, this technology fails to achieve
compliance.
GM has employed technologies beyond those
contemplated by the original 1972 regulation,
without achieving
compliance.
The emission controls at the Danville plant remove
between 99.1 and 99.6 percent of the CO in the exhaust gases.
(Tr.B at 119.)
Other available technologies would require
extensive structural modifications which are too costly for the
plant in light of other environmental considerations.
Modern
Equipment,
a consultant to GM,
indicated that no foundry was
achieving carbon monoxide emission levels consistently below the
200 ppm standard.
(Tr.B at 24.)
The technology presently installed at the GM plant in
Danville has reduced the emission of carbon monoxide to less than
2,000 ppm.
With the present technology, GM will be in compliance
with the proposed rule.
CONCLUSION
The Board agrees that site-specific relief is appropriate,
based on the record of this proceeding.
GM has attempted to
achieve compliance by modifying its system and studying
technologies to reduce the carbon monoxide emissions.
While,
GM’s efforts have substantially reduced the carbon monoxide
emissions,
it is not in compliance with the regulation.
Additional modifications to the cupolas are prohibited by cost
and will not guarantee compliance.
The proposed rule will not
134— 160
5
allow an increase in carbon monoxide emissions from its present
level.
Studies done by GM show that carbon monoxide emissions of
2,000 ppm will not have an adverse impact on the environment in
Vermilion County.
The rule the Board today proposes for first
notice is the rule proposed by GM in its petition, modified to
limit the site-specific relief to GM’s foundry in Vermilion
County.
ORDER
The Board hereby directs that first notice of the following
proposed amendments be submitted to the Joint Committee on
Administrative Rules.
SUBPART 0:
PRIMARY
AND
FABRICATED METAL PRODUCTS
Section 216.381
Cupolas
No person shall cause or allow the emission of gases
containing carbon monoxide into the atmosphere from any
cupola with a manufacturer’s rated melt rate in excess
of
5 tons per hour, unless such gases are burned in a
direct flame afterburner so that the resulting
concentration of carbon monoxide in such gases is less
than or equal to 200 ppm corrected to 50 percent excess
air or such gas streams are controlled by other
equivalent pollution control equipment approved by the
Agency according to the provisions of 35 Ill.
Adm. Code
201.
Section 216.382
Exception, General Motor’s Ferrous
Foundry in Vermilion County
The standard for carbon monoxide of Section 216.381
does not apply to the existincT ferrous foundry located
adjacent to Interstate
74 at G Street
in Vermilion
County, owned by General Motors Corporation on the
effective date of this requlation.
The emission of
carbon monoxide from this foundry shall not exceed
2,000 ppm corrected to 50 percent excess air.
(Source:
Amended at
____
Ill. Reg.
,
effective
__________________________________________________________________________
)
IT IS SO ORDERED.
134—16 1
6
I, Dorothy M. Gunn,
Clerk of the Illinois Pollution Control
Board, hereby certif
that the ab
opinion and order was
adopted on the
______
day of
________________,
1992, by a vote
of
7—c’
.
Dorothy M.
Gpfin, Clerk
Illinois Pol~utionControl Board
134— 162