DAQ-2024-004874

1719 Elizabeth Ave NW, Grand Rapids MI 49504
comfortresearch.com
February 12, 2024
ATTN: Chad Gilgen, Manager Minor Source Compliance Section
Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Submitted electronically to: Chad Gilgen, ([e-mail]);
Susan Weisenberg ([e-mail])
RE: Response to October 20, 2023 Compliance Advisory Letter
Comfort Research, LLC
Tremonton, Utah
Site ID 15735 (B1)
Dear Mr. Gilgen,
Comfort Research, LLC (Comfort Research) owns and operates a polystyrene filled products
manufacturing facility in Tremonton, Utah. The beads at this facility are produced by expanding
the imbedded pentane in raw expandable polystyrene (EPS) beads for use downstream in the
production of bean bag chairs and other furniture filled with EPS foam beads. Comfort Research
currently operates under Approval Order (AO) Number DAQE-AN157350001-17, issued June 20,
2017.
Comfort Research received a Compliance Advisory letter from UDAQ on November 29, 2023
(DAQC-1141-23) following a UDAW inspection on September 15, 2023. Note that although the
letter is dated October 20, 2023, Comfort Research only received the letter on November 29,
2023, as turnover at the company caused the letter to be forwarded to someone who no longer
works at the Comfort Research facility. The Compliance Advisory letter indicates that Comfort
Research was in violation of Utah Administrative Code (UAC) R307-401-5, and Conditions 1.2 and
II.B.1.c. of AO DAQE-AN157350001-17.
As a result of the inspection, DAQ alleges the following violations:
Comfort Research failed to submit a Notice of Intent to increase the pentane content in the
EPS beads processed on site before ordering and using beads with a higher pentane
content than allowed by the AO.
Comfort Research exceeded the allowable pentane limit for the EPS beads processed on
site. The AO allows a maximum pentane content of 4.5% by weight, and records reviewed
during the inspection shows an average pentane content of 5.56% by weight.
Note that this Compliance Advisory follows a Warning Letter (DAQC-163-20) issued on February
26, 2020 and a Compliance Advisory (DAQC-207-21) issued on February 19, 2021 for similar
REVIEWED
Initials: CG Date: 2-13-24
Compliance Status: Compliance
Advisory Response
File # 15735 (B1)

violations. In response to the February 2021 Compliance Advisory, Comfort Research submitted a
Notice of Intent (NOI). The NOI submitted April 2021 included the following updates:
 Increase the allowable pentane content to 6% by weight;
 Reduce allowable bead production to 2.25 million pounds per 12-months;
 Increase the hours of operation of the boiler to 4,488 hours per year; and
 Administrative changes to permit contact.
A call was held with the permit writer, Sarah Foran, on November 30, 2023 to learn more about
why the April 2021 NOI was not fully processed. Comfort Research is currently in the process of
resolving these additional information requests from UDAQ for the submitted NOI regarding the
Best Achievable Control Technology (BACT) determination for control of VOC. Specifically, DAQ
questioned the infeasibility of the use of a thermal oxidizer based on cost effectiveness. Note that
Comfort Research initially did not receive the information requests, as they had been sent to a
contact that no longer worked at the facility, which resulted in a permitting delay. Had the NOI
been fully processed, Comfort Research believes the subsequent alleged violations would not have
resulted.
An examination of AO conditions II.B.1.b (2.5 million pounds of raw bead material throughput per
rolling 12-month period), and II.B.1.c. (maximum pentane content limit not to exceed 4.5% by
weight) shows the effective annual allowable VOC emission rate from the use of the EPS beads to
be 56.25 tons per year. However, an examination of the EPS bead usage and pentane content
records (863,600 pounds per year and a weighted average pentane content of 5.45% by weight1)
produces a result of 23.51 tons per year which is less than the effective VOC emission limit of the
current permit.
Because Comfort Research submitted an NOI application to correct the pentane content and is
working to resolve the outstanding issues to allow for issuance of an updated AO, and because the
annual amount of VOC actually generated was less than the 56.25 tons allowed by the current
permit, it is Comfort Research’s position that any exceedance of the allowable bead pentane
content limit did not result in damage to the environment. Therefore, Comfort Research asks that
no further enforcement action be taken regarding this matter.
Any questions related to the operations of the plant and this response to the Compliance Advisory
Letter should be directed to my attention via email at [e-mail].

Thank you,

Bobby Rakes, Director of Operations
Comfort Research

Cc: Jeff Twaddle, ERM

1 Annual EPS bead usage and pentane content for period of January 1, 2023 through December 31, 2023.
2/26/24, 9:34 AM State of Utah Mail - //COMFORT RESEARCH// Response to October 20, 2023 Compliance Advisory Letter
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-f:1790717529829004592&simpl=msg-f:1790717529829004592 1/1
Chad Gilgen <[e-mail]>
//COMFORT RESEARCH// Response to October 20, 2023 Compliance Advisory Letter
Bobby Rakes <[e-mail]>Mon, Feb 12, 2024 at 11:08 AM
To: "[e-mail]" <[e-mail]>, Susan Weisenberg <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>, Anielle Duritza <[e-mail]>
Please see aached response leer to the 2023 Compliance Advisory Leer
BOBBY “SAND DAWG” RAKES
Master sergeant, usaf (ret.)
DIRECTOR OF OPERATIONS
616.475.5000 X401

COMFORT ReseARCH
CREATORS OF BIG JOE

SIGNED--Comfort Research LLC (15735)_Response to CA Letter_02 07 2024.docx
70K
2/26/24, 9:34 AM State of Utah Mail - //COMFORT RESEARCH// Response to October 20, 2023 Compliance Advisory Letter
https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permmsgid=msg-a:r1474829142968277326&simpl=msg-a:r147482914296827…1/1
Chad Gilgen <[e-mail]>
//COMFORT RESEARCH// Response to October 20, 2023 Compliance Advisory Letter
Chad Gilgen <[e-mail]>Tue, Feb 13, 2024 at 12:37 PM
To: Bobby Rakes <[e-mail]>
Cc: Susan Weisenberg <[e-mail]>, Jeff Twaddle <[e-mail]>, Anielle Duritza
<[e-mail]>
Hello Bobby,
Thanks for submitting a response to the October 20, 2023, Compliance Advisory. The DAQ has reviewed the letter and
we (me and Susan) would like to schedule a time with you to further discuss your response. Please let me know your
availability during the following dates/times and I will send you a Google Meet invite:
Wednesday, February 14: 9am - 3pm
Friday, February 16: 9am - 1pm
Tuesday, February 20: 9am - 3pm
All times are MST.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
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