LOUISVILLE, Ky.—American Synthetic Rubber Corp., a division of Michelin North America Inc., is facing public criticism over its request to modify some of its Strategic Toxic Air Reduction Program goals at its Louisville facility.
However, ASRC and Michelin say that the criticism is based on a misunderstanding of both the meaning of the request and the actual, massive emissions reductions ASRC is making at the facility.
"We are not requesting a waiver, or an exception, or permission to pollute more," a Michelin spokesman said.
In May, ASRC proposed changes to the original STAR modification request it made to the Louisville Metro Air Pollution Control District in December 2015 for its plant in the section of Louisville known as Rubbertown.
Instead of requesting to modify environmental acceptability goals for emissions of all toxic air contaminants, ASRC now requests only a modification applicable to emissions from an individual toxic air contaminant from an individual process on non-industrial property for emissions of 1,3-butadiene, stated a May 16 letter to the district from Guillaume Coiraton, ASRC chief operating officer.
"ASRC has achieved significant reductions in fugitive emissions over the past two years," Coiraton wrote. "ASRC is confident that these reductions will be maintained and improved upon."
ASRC originally requested a fugitive emissions level for butadiene of 6,708 pounds per year, but reduced that in May to 4,964 pounds per year, according to an update and timeline the district issued June 23.
The district held a public hearing on ASRC's revised modification request July 19 and accepted written statements until July 24, it said.
Those statements and testimony presented at the hearing will be released shortly for public viewing, a spokeswoman for the district said.
The district will prepare a formal Response to Comment document, and make a final decision on ASRC's petition at the end of the public comment period, it said.
In an Aug. 11 editorial, the Louisville Courier-Journal opposed the ASRC petition.
"Relaxing the emission requirements would increase cancer risks and cause other health issues for residents, employees at the plant and employees at other Rubbertown plants," the editorial said.
However, the Michelin spokesman said the Courier-Journal editorial and other press reports are mistaken about ASRC's activities and intentions.
Total emissions from the Rubbertown plant have fallen more than 90 percent since 2003, the spokesman said—a claim the Courier-Journal acknowledged.
Butadiene emissions at the ASRC plant declined especially quickly after 2005, when the company installed a flare thermal oxidizer to control those emissions, the Michelin spokesman said.
The STAR regulations are very complex, but essentially they allow manufacturing facilities some variation from emissions goals when they use Best Available Control Technologies, which ASRC always does, according to the spokesman.
ASRC already is meeting all the required STAR emissions goals within the plant, the spokesman said. The first request for modifications was required by law because the plant exceeded its emissions goals for 2013, 2014 and 2015, he said. The revised request was required because emissions at the plant fell further than expected for 2016, he said.
Fugitive emissions of butadiene at the plant declined 47 percent between 2013 and 2016, the spokesman said.
The request for modifications involves a fenced-off outdoor area of the plant site where very few employees ever go, where non-employees cannot legally go, and which already presents a very low risk to either workers or the public, he said.
Instead of the 500 ppm required by law, ASRC defines a toxic leak as being 250 ppm, the spokesman said. The company also regularly replaces all rupture disks in butadiene operations; has increased monitoring of butadiene components; and seals leaking components immediately rather than delaying repairs as federal regulations allow, he said.
The editorial listed organizations opposed to the proposed modification, including the American Lung Association, the Kentucky Resources Council and Rubbertown Emergency Action (REACT).
"The STAR program was not intended as a validation of the use of the public's air for toxic waste disposal from industrial facilities," REACT and the KRC said at an April 19 hearing about the original request for modifications.
Officials from the KRC could not be reached for comment.