Business Objective

An eyeglass manufacturing facility was in the midst of permitting an expansion to their lens coating operations. Their existing consultant had been unable to secure local district approval of their permit application, as the emissions of air toxics from specific equipment were not understood and had not been properly described to district engineering staff. To complicate matters, the existing consultant recommended a VOC control strategy that had not been properly tested for the specific coating application, and the control vendor was unable to provide accurate destruction test data. The client's legal counsel turned to ALG for guidance to correct the engineering analysis and to secure permit approvals as soon as possible.

Technical Approach

ALG technical staff has substantial experience in the quantification of air toxic emissions from similar operations used in aerospace manufacturing, and in the control of VOC emissions for a broad spectrum of operations. Working directly with the original equipment manufacturer, we developed equipment-specific emission factors for target air toxic compounds. These factors were then applied to agency-approved health risks analyses that allowed ALG to demonstrate that emissions of air toxics would be within agency guidelines. Concurrently, our staff conducted a VOC BACT analysis and confirmed that the proposed VOC controls would not achieve required efficiencies. We quickly obtained vendor quotes for reliable control systems, and re-submitted applications for VOC controls with District staff. In doing so, we regained the confidence of the district's engineering staff, which allowed our client to obtain all necessary pre-construction approvals.

Results

ALG technical expertise, solid relationships with local district engineering staff, and practical experience in emission controls allowed our client to secure approvals for their planned expansion. They have continued to expand production capacity to meet customer demand, which would not have been possible with prior control and equipment configurations.