Gilman Brothers (GB), a company manufacturing laminated foam boards at its facility by extruding polystyrene resin and a volatile organic compound (VOC) blowing agent (BA), wanted to double its permitted production capacity. The facility, which was a minor source of VOC emissions, did not have any emissions control. Doubling the capacity would make the facility a major source and the Connecticut Department of Environmental Protection (CTDEEP) has never allowed a major source of VOC emissions to operate without any emissions control. The addition of any control device would impact the production cost. As the foam board is a low margin commodity product and as none of the competitors of GB have control devices, any increase in production cost would negatively impact the viability of GB’s business. GZA was contracted to assist GB in obtaining a permit that allows the production increase without the addition of any control device.
GZA met with CTDEEP to discuss the permitting strategy. CTDEEP indicated that the BACT analysis would determine emission control applicability. GZA performed extensive research to identify polystyrene foam manufacturing emission control practices and justifiable process data for quantification of emission reductions. GZA’s research also included identification of other control options, such as non-traditional control devices, process changes, non-VOC BA usages, etc. GZA demonstrated that very few foam manufacturing facilities and none of the comparable facilities have emissions control. With the client’s assistance, GZA collected realistic economic data for the BACT analysis. GZA prepared and submitted the air permit application package incorporating the BACT analysis. GZA also promptly responded to additional data requests from the CTDEEP.
CTDEEP approved the permit that allowed the client to operate at the increased capacity without any emission control.