A public hearing of the Air Pollution Control Board of Jefferson County was called to order March 21, 2001, at 9:02 a.m. in the Board Room of the Air Pollution Control District, 850 Barret Avenue, Louisville, Kentucky, by the Chairman, Dr. Robert Powell.

The Chairman read the opening announcement, rules, and purpose of the hearing which was to review Board Orders with BFGoodrich Company and Louisville Gas and Electric Company.

Mr. Gaylord said that BFGoodrich (BFG) had a mutual agreement with Oxy Vinyls (Oxy) for the control of emissions during periods when the control device is not functional. On June 1, 2000, BFG had to by-pass its control device and send its vinyl chloride waste stream to Oxy for destruction in their control. On June 12, 2000, Oxy inquired of BFG if they were still sending the waste to them for destruction because there was no flow or line pressure indication on Oxy’s system computer. BFG immediately shut down the by-pass to Oxy, shut down operations, and investigated the apparent problem. It was discovered that the transfer pipe had corroded and failed. The failure allowed for the emissions of an estimated 2,573 pounds of vinyl chloride. BFG, in order to settle this violation, proposed to complete a Supplemental Environmental Project (SEP). The SEP is projected to removed over 900 pounds of VOCs, which includes approximately 600 pounds of Hazardous Air Pollutants (HAPs), from the atmosphere annually. BFG is to pay the District an assessed penalty of $7,500 by April 18, 2001. On February 28, 2001, BFG transferred all of its interest in its Performance Materials Division to PMD Group, Inc. Since that date, PMD has operated the Bells Lane facility and will be responsible for implementing the requirements of this Board Order other than the payment of the penalty and legal notice costs.

The District intends to recommend that the Board approve the Order with BFGoodrich Company.

Statements:

None.

Mr. Gaylord said that this Board Order addresses reactive particle emissions that caused spotting of metal surfaces on property in the Valley Village area and originated from Mill Creek Station. Studies subsequently performed by LG&E’s contractor, Radian Corporation, determined that the reactive particle emissions in question were associated with the accumulation of iron sulfate and sulfuric acid residues on ductwork and stack surfaces due to carryover past mist eliminators and other factors and the subsequent release of such residues during temperature or flue gas velocity fluctuations under certain circumstances. The District intends to recommend that the Board approve the Board Order with Louisville Gas and Electric Company.

Statements:

Mr. Mike Kirkland, Plant Manager, Mill Creek Station, briefed the Board on changes relating to the reactive particle emissions at the Station. LG&E proposes to convert the generating units at the Station to wet stack operation by eliminating reheat and redesigning stack breachings, lining the stacks with a high-grade stainless steel alloy, upgrading mist eliminators and wash systems, and eliminating the capability of bypassing scrubbers during scrubber malfunction events. Converting to wet stack operation and eliminating reheat will eliminate temperature fluctuations and decrease flue gas velocities. Eliminating reheat and upgrading mist eliminators will minimize carryover conditions.

Mr. Vibbert asked if the reactive particle emissions were toxic. A report by the District’s contractor, IIT Research Institute, established that the emissions were not toxic. The compliance plan is due to be completed by February 28, 2003.

The hearing adjourned at 9:20 a.m.

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Robert W. Powell, MD
Chairman

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Jonathan L. Trout
Secretary-Treasurer