ILLINOIS POLLUTION CONTROL BOARD
February 19, 1987
GENERAL MOTORS CORPORATION
)
(ELECTRO—MOTIVE DIVISION)
)
Petitioner,
V.
)
PCB 86—195
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
Respondent.
SUPPLEMENTAL STATEMENT (by J.D. Dumelle and J. Theodore Meyer):
The issue of the use of 40 gallons of paint in a year or 65
gallons or even 80 gallons (at full production) represents a de
minimus situation to us.
The paint at issue has 6.01 lbs. of VOC per gallon. The
rule requires 4.3. Thus, the difference between these two
figures is the excess emitted over the rule if the somewhat
controversial solids content correction is neglected. The excess
emissions for the 40 gallons estimated to be used in 1987 is thus
40 (6.01
—
4.3)
=
68.4 lbs. Using 250 working days, the excess
emissions compute to 4.4 ounces of VOC per day of plant
operation! That is de minimus and the Board should •so find.
If Electromotive can sell enough locomotives to get back to
full production capacity it might reasonably add about 5,000 jobs
to its present 5,055. At full production, 80 gallons per year of
the paint in question would be required. The excess emissions
would then double to 8.8 ounces per day or about a half pound a
day. That is so small as to be minimal in environmental impact
and de minimus in the leg-al sense.
3
cob D. Dumelle, P.E.
3.
~~odore Meyer
hairman
Boarä’ Member
76.61
—2—
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
Board, hereby certify that the above supplemental Statement was
filed on the
______________
day of-1~-~t~~ 1987.
Dorothy M.. Gunn, Clerk
Illinois Pollution Control Board
76-62