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An Allen County tire manufacturer may be allowed to increase its ozone-causing pollution by up to 40 tons per year.
But the decision by Indiana’s environmental regulators to let BFGoodrich in Woodburn use a new additive in its tire-making process is raising red flags for environmentalists. The concerns include:
•There is no requirement in Goodrich’s draft permit for new pollution controls to reduce the new emissions.
•It does not require any monitoring of the pollution to ensure it stays within the 40-ton limit.
•There will be no additional scrutiny before a permit is issued that a permit for more than 40 tons would require.
•The emission calculations are based on numbers supplied by Goodrich, but the analysis is not available for public review.
A 30-day public comment period on the proposed Indiana Department of Environmental Management permit ends Wednesday.
IDEM’s upcoming local decision comes about a year after its controversial decision to allow BP’s Whiting oil refinery to increase the amount of pollution released into Lake Michigan and a year and a half after Allen County returned to ozone attainment status, because its ozone levels had crept back into allowable levels.
Despite the new designation, the American Lung Association rated Allen County’s air quality a “D” this year, up from an “F” in 2007, based on its high levels of ozone.
The pollution Goodrich wants to release reacts with other compounds in the air to cause ozone. Goodrich says the company is committed to environmental responsibility.
While ozone forms a protective layer high in the atmosphere that protects the Earth from ultraviolet radiation, ground-level ozone is a powerful respiratory irritant and can cause shortness of breath, chest pain, and wheezing and coughing. For someone with asthma, high ozone levels could be deadly. Ozone also causes smog.
According to the draft permit, BFGoodrich wants to begin using a silane binder in its tire-making process. Silane binders chemically change the rubber used in tires to make them roll more easily, increasing fuel efficiency. But the silane binder Goodrich wants to use releases ethanol into the air as it reacts with the rubber compounds, the permit says.
Ethanol is in a class of chemicals called volatile organic compounds, which cause ground-level ozone. The plant, which employs about 1,400, already releases 140 tons of VOCs a year before the new process, according to the permit.
“Certainly that raises some serious questions. We’d like to closely scrutinize the permit,” said Bowden Quinn of the Sierra Club’s Hoosier Chapter in Indianapolis. “It does sound fishy.”
Faith Bugel, at the Environmental Law and Policy Center in Chicago, called some of IDEM’s decisions “dubious.”
By keeping the release of ethanol to less than 40 tons per year, the permit is considered a “minor” source of new pollution, but it is a “synthetic minor,” Bugel said, because Goodrich will stay within the limits – known as the Prevention of Significant Deterioration threshold – by limiting the amount of raw materials used, not by actually controlling the pollution.
Plant Manager Paul Cagle said in a written statement the company is deliberately staying below the 40-ton threshold by limiting how much silane binder it uses.
“The permit application in question does not trigger Prevention of Significant Deterioration permitting requirements because the plant has chosen to take voluntary limits on the use of silane in its process. These limits reduce the potential emissions from the silane binder below the threshold amounts defined by the PSD regulations,” Cagle wrote. “The PSD issue has also been analyzed and validated by Indiana Department of Environmental Management during the application review period.”
But the amounts themselves are in question, too: The amount of silane binder Goodrich can use under the proposed permit is limited to 467,836 pounds a year, based on the silane releasing 0.171 pounds of ethanol for every pound of silane used.
But the 0.171 figure – known as an emission factor – was not calculated by IDEM; it was provided by Goodrich, and the detailed calculations Goodrich used to arrive at the number were provided by Goodrich to IDEM on the condition they be kept confidential, the permit says.
That means there’s no way for the public to decide whether the number is valid, Bugel said. If the silane actually releases 0.172 pound of ethanol for every pound of silane used, for example – just 1 one-thousandth of a pound more – the plant will emit 500 pounds of ethanol more than allowed.
“You can’t do any public review,” Bugel said. “I’d say there’s a problem with public notice and comment, and I’m not sure why emissions factors would be confidential.”
Goodrich said in its permit the number was arrived at by testing at a similar facility but did not name the facility and refused to tell The Journal Gazette which facility the testing occurred in.
A similar tire plant, the Goodyear Tire and Rubber facility in Freeport, Ill., used an emission factor of 0.194 for its silane binder permit in 2003, according to its permit. Unlike Goodrich’s draft permit, Goodyear’s permit does not specify which silane binder will be used; but at that emission level, Goodrich would be 5 tons over the limit.
Going over the limit would do more than just violate Goodrich’s permit, it would make Goodrich subject to more scrutiny before the permit was granted, and more requirements afterward.
With a “major” increase in pollution, Goodrich would likely have to do an analysis to find the lowest achievable emission rate and use pollution controls to meet that rate, then would have to actively monitor ethanol levels coming out its stacks to ensure they stay within limits, Bugel said.
Goodrich’s Cagle said the company needs to keep its calculations secret.
“The decision to keep the VOC emission calculations confidential is due to the highly competitive nature of the tire manufacturing industry,” Cagle said in the statement. “The actual emission factors and calculations for silane involve specific plant production volumes and unique manufacturing recipes that provide BFGoodrich Tires a competitive advantage. For this reason, the information is considered confidential.”
Bugel said it’s questionable to use an emission factor at all.
“Emissions factors are really frowned upon,” she said. “You should really only use them where you can’t get actual emissions.”
But IDEM Public Information Officer Rob Elstro contends it’s better to use an estimate than actual numbers, suggesting monitoring devices can sometimes be inaccurate.
He also pointed out that applicants are required to give correct information.
“When the facility gives us the emission factor, they have to certify that it is accurate,” Elstro said. “Our permit writers do review the information they submit to us.”
The permit says the number is based on testing done at a similar facility, but Elstro could not say which facility that was. He also didn’t know whether IDEM follows the guidance that emission factors should only be used when there is no alternative.
IDEM also admits the permit contains an error. As published on IDEM’s Web site, the draft permit allowed Goodrich to use 467,850 pounds of silane a year. But when The Journal Gazette pointed out that amount – assuming the emission factor is correct – would put the ethanol releases over the 40-ton limit, the agency said it would correct the amount to 467,836 pounds.
Elstro said the error does not mean IDEM’s numbers can’t be trusted, but proves the public comment period works.
“That’s why we put these permits out for public notice,” he said.
The silane binder Goodrich wants to use is also not the only alternative. General Electric’s NXT Low-V silane can lower ethanol emissions by 70 percent, and its NXT-Z silane is essentially ethanol-free.
Elstro didn’t know whether IDEM discussed the possibility of Goodrich using a different silane binder in its process to lower ethanol emissions.
He said IDEM’s decision not to require testing was made carefully.
“That’s a pretty conservative assumption the agency is using,” Elstro said. “They make a determination whether the information submitted was sufficient or whether testing is required, and in this case they chose not to require testing.”
The Sierra Club’s Quinn said it appears to be another example of IDEM putting industry ahead of the environment.
“IDEM has shown itself to be very business-friendly in its permitting process,” Quinn said. “That’s why we’re appealing their decision on the BP Whiting refinery – their permits are not as rigorous as they should be.”
Goodrich says the new process is actually a very green decision because it will improve fuel efficiency and therefore help the environment.
“BFGoodrich Tires has a strong environmental commitment,” Cagle said. “We are confident that this responsible use of silane to improve tire fuel economy is an example of that dedication.”
dstockman@jg.net
