Large Point Sources and the STAR Program
Large and moderate industrial and commercial operations are responsible for the largest, single-source emissions of most toxic air pollutants. These emissions come from process stacks, general building ventilation systems, and fugitive sources of outdoor equipment. These stationary, non-mobile operations are likely the cause of the highest risks in the vicinity of the companies. Regulating these operations is the second component of the STAR Program, under Regulation 5.21 Environmental Acceptability for Toxic Air Contaminants, Regulation 5.20, Methodology for Determining Benchmark Ambient Concentration of a Toxic Air Contaminant and Regulation 5.22, Procedures for Determining the Maximum Ambient Concentration of a Toxic Air Contaminant. This aspect of the STAR Program primarily affects 170 companies of Louisville’s 32,000 businesses.
Companies with the largest emissions of the 18 toxic chemicals – such as chloroprene, 1,3-butadiene and arsenic – were required to report information to the Louisville Metro Air Pollution Control District starting April 2006 to determine if they exceed the health risk goal.
By 2011, those companies must lower their toxic emissions of the 18 chemicals to meet the goal or prove to the APCD Board they are using the best available technology to lower emissions as much as possible. The STAR regulations include a public process for companies to seek approval of an extension to meet the new goals.
Major sources (43 companies): Companies that are allowed to release more than 100 tons of chemicals into the air each year (Title V companies). See map of major sources.
Moderate sources (about 130 companies): Companies that emit more than 25 tons of toxic chemicals into the air each year.
The 173 companies that are major or moderate sources of toxic emissions currently provide aggregate data to the APCD on toxic chemicals used annually in their operations. The reports do not provide detailed information on each chemical emitted. See map of moderate sources.
The Five “Points of the Star”
Point 1 – Emissions inventory: Companies will provide detailed information to the APCD and the public about the amount of each of the targeted toxic chemicals they release.
Point 2 – Emissions levels by point of release: Companies will provide detailed information about the emissions levels of toxic chemicals from each stack or release point in their facility. The report will list the amounts of each chemical from each stack or release point.
Point 3 – Emissions level modeling: Companies will use established models to determine whether any of the chemicals they are using exceed the health risk goal. If toxic chemical emissions are at levels below the goal, no additional action is required.
Point 4 – Emissions reduction plan: If toxic chemical emissions exceed the health risk goal, companies must submit a plan to the APCD staff for lowering emissions to meet the goal. Steps could include changing to less toxic chemicals, using lesser amounts of toxic chemicals, improving processes to reduce emissions levels.
Point 5 – Emissions compliance: Companies must meet the health risk goal for each toxic chemical within the specified timeframe or prove to the APCD Board – A) they have made significant progress and deserve more time to meet the goal or B) they have implemented the best technology available to reduce emissions.