LOUISVILLE, Ky., Sept. 15, 2017 — American Synthetic Rubber Company’s request for modification of its emission goals under Louisville’s Strategic Toxic Air Reduction program was substantially approved by the Air Pollution Control District today.
“ASRC respects the District’s decision, which adheres to the legal requirements under the STAR program and maintains appropriate safeguards for the community. The District’s decision also recognizes that the facility fully complies with all plant-wide goals for total emissions under STAR regulations,” said Guillaume Coiraton, plant manager for ASRC. “ASRC considers the health of its employees and residents in the community as its highest priority, and we will continue our efforts to reduce actual emissions every day.”
The STAR program provides two legal pathways for compliance:
- Meet the program’s unmodified emission goals for both individual processes and for total plant-wide emissions, or …
- Meet the unmodified plant-wide emissions goal and implement the best-available control technologies with modified goals for individual processes.
ASRC’s request pursued the second approach, and applies best-available control technologies to certain individual processes related to 1,3-butadiene. The District granted ASRC’s request for modification concerning so-called “fugitive” emissions of butadiene, the trace amounts that can escape from the plant’s valves and connections. By implementing the best-available control technologies, ASRC already has reduced this category of emissions by 47 percent from 2013 to 2016.
“ASRC has implemented drastic improvements to reduce its total plant-wide emissions by more than 90 percent since 2003, and then further reduced its fugitive emissions by nearly half in the last three years,” Coiraton said. “This track record demonstrates that ASRC should be seen as a model manufacturer that is fully responsible for its emissions. We are proud of the plant’s achievements.”
The District’s decision affirms that ASRC has properly implemented the best-available control technologies for minimizing fugitive emissions of butadiene. ASRC’s ongoing approach includes the following:
- Replacing certain connections with new technology
- Aggressive leak detection and repair for butadiene components, in specific cases up to 16 times more stringently than federal law requires
- Tightening the standard definition of a “leak” that requires repair, from the federal threshold at 500 ppm to 250 ppm
- Using engineered components to seal leaks immediately, instead of allowing a waiting period as permitted by federal law
The District denied ASRC’s request for butadiene emissions from the plant’s flare stack because the plant has operated in recent years well below the modified level of its request. ASRC made this request to provide flexibility in its industrial operations while still meeting the unmodified goal for total plant-wide emissions.
“The actions implemented by ASRC and approved by the District rank among the most aggressive in the nation to control this category of emissions. We will continue to operate the plant to achieve the lowest possible emissions over time,” Coiraton said.
“Unfortunately, the facts regarding this request for modification have been misunderstood throughout the STAR review process. ASRC has demonstrated clearly that the plant is following both the letter and the spirit of the STAR program goals, which has resulted in lower actual emissions over time,” Coiraton said. “As we have demonstrated through regular participation with the Rubbertown Community Advisory Council, ASRC is committed to continue its outreach with residents and dialogue with government officials to inform them about the plant’s actual record for emissions control.”
The complete decision from the District is available here.
About American Synthetic Rubber Company
ASRC produces synthetic rubber, which delivers essential performance advantages when combined with natural rubber and other components in the production of tires for all types of vehicles. Built in 1942, Michelin began investing in American Synthetic Rubber Company (ASRC) in the 1980s and fully acquired the site in the 1990s. This year, ASRC celebrates 75 years of operation in the Louisville, Ky., area. The plant’s mission is to produce synthetic elastomers to supply Michelin’s tire production factories, and industrialize new elastomers, resulting from research, which will help create the tires of tomorrow. ASRC produces more than 360 million pounds of synthetic rubber per year, or approximately 1 million pounds per day. Approximately 370 employees work at the site.
Eric S. Bruner