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Kentucky Resources Council, PO Box 1070, Frankfort, KY 40602 Phone [502] 875-2428

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PO Box 1070, Frankfort, KY 40602  Phone 502.875.2428, Fax 502.875.2845

KRC Comments on Solvent Replacement At Rubbertown Plant  Posted: October 11, 2011

October 11, 2011

Lauren Anderson, Director
Louisville Metro Air Pollution Control District
850 Barrett Avenue
Louisville, Kentucky 40205

Re: American Synthetic Rubber Company
Construction Permit Phase I
Conversion Project

Dear Director:

These comments are submitted on behalf of the Board and membership of the Kentucky Resources Council. Inc., a nonprofit membership organization incorporated under the laws of the Commonwealth of Kentucky and dedicated to protection of the public and natural resources of the Commonwealth. Council members include individuals who live, work, reside, and own property in west Louisville communities, and whose use and enjoyment of their properties have been adversely affected by pollution from industries located in the Rubbertown area of Metro Louisville.

The Council has these specific comments concerning the requested issuance of a construction permit to covert from use of toluene as an organic solvent associated with production of polybutadiene rubber and styrene butadiene rubber, and use of a mixture of cyclohexane and methylcyclohexane.

While the Council supports the reduction in the potential toxicity of chemicals used in the production of rubber, the District is requested to carefully review available literature regarding cyclohexane and methylcyclohexane in order to assure that the substitution of these compounds for toluene does not result in adverse health or safety effects on workers in the workplace and on the surrounding community due to routine emissions or from accidental releases.

In addition to the specific criteria of the STAR program, there is a general duty obligation both on the part of the District and on the part of permittees, to assure that:

"No person shall permit or cause the emission of air pollutants which exceed the requirements of the District regulations or which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public or which endanger the comfort, repose, health, or safety of any such persons or the public or which cause or have a natural tendency to cause injury or damage to business or property."

APCD Regulation 1.09.

According to OSHA, cyclohexane is a flammable liquid with a flammability rating of 3 (serious fire hazard), that is reactive with oxidizing agents such as perchlorates, peroxides, permanganates, chlorates and nitrates. Though not required to be reported under SARA, exposure to cyclohexane can cause irritation of the yes and mucous membranes, and at higher concentrations, dizziness, nausea and other narcotic effects. Similarly, methylcyclohexane, according to the Material Safety Data Sheet, is a highly flammable solvent and a severe fire hazard when exposed to heat, flame or oxidizers, and whose vapors may travel a considerable distance to a source of ignition. It too is reactive with nitrates, oxidizing acids, chlorine bleaches and may ignite under such circumstances.

Given the close proximity of ASRC to populated residential areas, the delivery, storage, transfer, use, and disposal of spent cyclohexane and methylcyclohexane should receive particular attention. While not regulated as listed “hazardous” chemicals under RCRA nor reportable under Title III of SARA, it is apparent that releases of either or both of these compounds could “cause injury, detriment, nuisance or annoyance” and might, depending on the amount, duration and form of release, “endanger the comfort, repose, health or safety” of persons or cause injury or damage to property. Every precaution should be taken to avoid reactions between these substances and others in the facility, and to prevent releases to the ambient air that could cause irritation to eyes, mucous membranes, and central nervous system impairment or kidney or liver damage.

ASRC should be required, consistent with Regulation 1.09, to demonstrate based on peer-reviewed literature, that the levels of release of each of the two compounds and of the mixture, will remain below those levels in the ambient air that would cause eye irritation, mucous membrane irritation, upper respiratory tract irritation, CNS impairment, and liver and kidney damage, for both acute and chronic exposure. Numeric emission limits should be placed on each compound, and monitoring using appropriate test methods should likewise be imposed.

Thank you in advance for your consideration of these comments.

Cordially,
/s/
Tom FitzGerald
Director

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