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

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