Director
In response to the question raised last month by Ms. Embry regarding American Synthetic Rubber Company (ASRC) and the control efficiency of the proposed thermal oxidizer, Mr. Goldsmith said that he spoke with EPA Region 4 personnel who stated that a 99.5% control efficiency, which is what ASRC has proposed as a minimum, sounded reasonable. Many of the Lowest Achievable Emissions Rate (LAER) determinations have required much less controls, even down to as little as 95%. Hazardous waste incinerators could be required to achieve 99.99%, but this is not that application.
Ms. Embry asked whether there were any examples of this technology being used anywhere in the country that are achieving higher rates and what those rates are. Mr. Williams responded that the District’s understanding is that 99.99% can be and is being achieved. However, from the research and feedback the District has had, they don’t know if they want to set that as a regulatory requirement. The company’s estimate, presented to the Board, was based on the 99.5% control efficiency. The company has represented that it anticipates the possibility of getting a higher destruction efficiency. At this point, the District is comfortable with maintaining the regulatory requirement of 99.5% control efficiency, knowing that this is the minimum that the thermal oxidizer will achieve. The feedback from EPA was that this was an achievable, realistic, and reasonable goal. A representative of the John Zink Company, a manufacturer of thermal oxidizers, indicated at last month’s Board meeting that 2,000 of the John Zink thermal oxidizers, and perhaps as many as another 1,000 thermal oxidizers from competitors, have been installed in this country, and many of them did achieve a 99.99% rate.
Ms. Smith noted that during discussions at last month’s meeting a company representative mentioned that there is always a cost to environmental controls. A higher rate could be achieved, but the energy cost to the company would go up considerably. Ms. Smith asked whether there had been any discussions with Louisville Gas and Electric (LG&E) about providing natural gas at a more economical rate. Mr. Williams responded that he was not aware of any planned discussions. Ms. Smith said she is looking at a community-wide problem-solving effort. Ms. Embry added that the Board would like to feel confident that ASRC is going to achieve the lowest control efficiency rate that the technology is capable of. Mr. Williams responded that the District will explore the LG&E issue.
Ron Musgnug, ASRC, said that it will cost more money to operate the thermal oxidizer at higher flows as well as at higher temperatures. There are three factors that are important to the control efficiency of a thermal oxidizer: residence time, temperature, and total gas flow. He said that ASRC is trying to capture the maximum airflow from the plant, anywhere between 2,000 and 600 cubic feet per minute. They intend to size the thermal oxidizer so that it would be able to take the low flows as well as the high flows and still remain as efficient as possible. The added cost issue came up when he said that if the 1,3-butadiene gas stream is at a low flow rate, the volume of combustible gas would need to be increased by adding natural gas. This was only a comment to explain the operating efficiency of the device. ASRC will be working to bring it to a 99.99% efficiency. He said that it does not make sense to be required to meet a 99.99% control efficiency. Their objective is to set up the temperatures, set up the flows, and set up the residence time so they can achieve as high a control efficiency above 99.5% as possible. Their environmental stewardship is the assurance that they will operate at the optimum efficiency to produce the cleanest air possible. He did not think it would be productive for the Board to pursue lower gas rates from LG&E.
Mr. Williams added that once ASRC begins operation of a thermal oxidizer and performs the required stack tests to determine control efficiency, the District could negotiate with ASRC to revise the permit condition to require a higher control efficiency. At that point, there would be actual performance data upon which to base a more stringent requirement. Mr. Musgnug responded that it would be acceptable to renegotiate a different control efficiency requirement after the tests results are available.
On the next subject, Mr. Williams said that the State of Kentucky has concluded that there was both a 1-hour and 8-hour ozone standard exceedance on August 2 at the Shepherdsville/Bullitt County monitor. The maximum 8-hour concentration was 102 parts per billion and the maximum 1-hour concentration was 127 parts per billion. The following day the District’s Bates Elementary monitor recorded an 8-hour ozone exceedance of 93 parts per billion. It is likely that the final 2004 ozone season report will show two 8-hour exceedances and one 1-hour exceedance.
Mr. Williams noted that this morning’s Courier-Journal had reported on a study that came out yesterday on the observed correlation between increased ozone levels and increased mortality. This was a 95-city study led by Johns Hopkins and Harvard Universities. The Board members will be provided with a copy of the study. The study found that, on average, there was an average increase of 0.52% in mortality for every 10 parts per billion increase in ozone levels. The effect was seen generally with a one-week lag time following the increased ozone event. These were for levels that are even below the federal 8-hour standard of 80 parts per billion. The study did not show that the effect related to any particular sub-population, such as the elderly or people with respiratory disease. Louisville was included in the 95-city study. The researchers attempted to rank the communities by size of effect. Louisville was ranked 14th worst out of the 95 cities. The researchers cautioned that not too much weight should be put on that ranking because the actual differences between cities was quite small and sometimes within a margin of error. The study bears on the issues that are being examined by the Air Quality Task Force as it goes forward to make recommendations to this Board about what this community should do to achieve attainment with the 8-hour ozone standard. Mr. Williams said that he believes that the EPA has acknowledged that this is a significant and important study and its results would be considered as the EPA deliberates what strategies to pursue to achieve public health protection from ozone.
Mr. Williams said that the monitored PM2.5 levels continue to trend downward in general this year, similar to the monitored ozone levels, although the monitored October PM2.5 average was a bit elevated over the monitored averages for the previous three years. The monitored June, July, and August PM2.5 averages were the lowest averages for those months.
Lawn Care for Cleaner Air Awards
The list of this month’s Lawn Care for Cleaner Air Award recipients was submitted for filing. A copy is attached to the original minutes.
Air Quality Data
The air quality monitoring reports were submitted for filing. A copy of each report is attached to the original minutes.
Enforcement Status
The APCD Enforcement Status
11/11/2004 
report was submitted for
filing. A copy is attached to the original minutes.
Startup, Shutdown, Malfunction, and Emergency Report
The Malfunctions,
Emergencies, Startups and Shutdowns received 10/11/2004 through 11/10/2004
report was submitted for filing. A copy is attached to the original minutes.