Air Pollution Control District Notice of Public Hearing

November 4, 2020

The Louisville Metro Air Pollution Control Board will be holding a hearing on a Source-Specific VOC “Bubble” Agreed Board Order with LL Flex, LLC at its November 18, 2020, Board Meeting.

The proposed Agreed Board Order –

  • Updates a source-specific method of complying with alternative volatile organic compound limits using reasonably available control technology (RACT) as allowed by APCD Regulation 2.12.  This source-specific limit is referred to as a “bubble.”
  • U.S. EPA approved a “bubble” for this source into the Kentucky State Implementation Plan (SIP) on May 16, 1990 and approved a revision on January 13, 1998.  Approving the “bubble” into the SIP makes the source-specific limits federally enforceable by U.S. EPA.
  • Emissions limits in the proposed Agreed Board Order are not being increased.  They remain the same as in the previous source-specific SIP revisions, and no increase in emissions will result.
  • ​​The Agreed Board Order specifically:
    • Updates the name of the source’s owner – now “LL Flex LLC”;
    • ​Replaces the previous SIP revisions that relied on old construction permits that have since been revised and incorporated into the Title V Operating Permit (O-0015-17-V (R1)) for the company;
    • Notes that the company has removed Rotogravure Printing/Coating Machine Number 16 from the facility and added a control device for Machine Number 14.
    • Replaces the method that the company uses to track emissions by substituting technical material specifications, which includes all information needed to determine compliance and complies with APCD Regulation 6.29, instead of more complex emissions tracking.
    • Specifies that the company will be required to maintain records that include all information needed to determine compliance, including technical material specifications.
    • Does not allow any increase in emissions.
    • If approved, will be submitted to U.S EPA for inclusion in the SIP as a federally enforceable emission limit.

More information is available on APCD’s Proposed Actions at You may request a hard copy of the Agreed Board Order by calling (502) 574-6000, between 8:00 a.m. and 5:00 p.m. Monday through Friday. Please specify that you are calling about the Source-Specific VOC Bubble Agreed Board Order with LL Flex, LLC, provide your name and mailing address, and a copy will be mailed to you.

Oral statements will be accepted at a public hearing via teleconference (due to the COVID-19 outbreak) at 10:00 a.m., November 18, 2020. Instructions on attending the hearing will be posted at before the meeting and emailed to subscribers of APCD Public Notices at  For more information, please contact Matt King at (502) 574-6714 or email [email protected].