DAQ-2024-007877

DAQE-AN157350003-24

{{$d1 }}

Bobby Rakes
Comfort Research, LLC
1719 Elizabeth Avenue NW
Grand Rapids, MI 49504
[e-mail]

Dear Mr. Rakes:

Re: Approval Order: Minor Modification to Approval Order DAQE-AN157350001-17 to Increase
Bead Pentane Content, Increase Boiler Operation Hours, and Reduce Production Limit
Project Number: N157350003

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on April 14,
2021. Comfort Research, LLC must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Christine Bodell, who can be contacted at [phone] or
[e-mail]. Future correspondence on this Approval Order should include the engineer's name as
well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were
received on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:CB:jg

cc: Bear River Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

April 23, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN157350003-24
Minor Modification to Approval Order DAQE-AN157350001-17 to
Increase Bead Pentane Content, Increase Boiler Operation Hours,
and Reduce Production Limit

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Comfort Research, LLC - Polystyrene Filled Products Manufacturing

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality
April 23, 2024

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-AN157350003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Comfort Research, LLC Comfort Research, LLC - Polystyrene Filled
Products Manufacturing

Mailing Address Physical Address
1719 Elizabeth Avenue NW 350 West 1000 North
Grand Rapids, MI 49504 Tremonton, UT 84337

Source Contact UTM Coordinates
Name: Bobby Rakes 402,350 m Easting
Phone: [phone],620,180 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3086 (Plastics Foam Products)

SOURCE INFORMATION
General Description
Comfort Research, LLC (Comfort Research) owns/operates a polystyrene-filled product manufacturing
facility in Tremonton, Box Elder County. These products include bean bag chairs and other furniture
filled with expanded polystyrene (EPS) foam beads. The facility operates three (3) production lines. The
first production line inflates EPS beads using an expander unit. The EPS beads are inflated by blowing
steam across the beads in a steam chamber. The steam is generated using a 6.28 MMBtu/hr boiler. After
initial expansion, the beads move to the fluidized bed section of the expander unit for partial drying and
are then transferred to the first-pass stabilization/holding tent. The beads are allowed to stabilize for
several hours in porous tents. After stabilizing, the beads are transferred back to the expander unit for
final expansion. The beads are then transferred to a porous holding tent for final curing. The second and
third production lines are used for filling bean bag products with EPS beads, sewing, and packaging.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT Particulate matter less than 2.5 microns in size NAA
Box Elder County
Airs Source Size: SM

DAQE-AN157350003-24
Page 4

Applicable Federal Standards
None
Project Description
Comfort Research has requested to following changes:

1. Increase the pentane content in the EPS beads processed on site from 4.5% by weight to 6.0% by
weight (Condition II.B.1.c in Approval Order DAQE-AN157350001-17).

2. Reduce the throughput of raw bead material from 2.5 million pounds per rolling 12-month period to
2.25 million pounds per rolling 12-month period (Condition II.B.1.b (A) in Approval Order
DAQE-AN157350001-17).

3. Increase the hours of operation for the boiler from 2,244 hours per rolling 12-month period to 4,488
hours per rolling 12-month period (Condition II.B.1.b (B) in Approval Order DAQE-AN157350001-17).

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 843 1668.00
Carbon Monoxide 0.58 1.16
Nitrogen Oxides 0.69 1.38
Particulate Matter - Particulate matter less than 10 microns in size 0.04 0.11
Particulate Matter - PM2.5 0.04 0.11
Sulfur Dioxide 0.01 0.01
Volatile Organic Compounds 10.63 67.58

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic Hazardous air pollutant(s) (CAS #GHAPS) 0 2
Hexane (CAS #110543) 30 50
Change (TPY) Total (TPY)
Total HAPs 0.02 0.03

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this Approval Order conform to
those used in the Utah Administrative Code R307 and 40 CFR. Unless noted otherwise,
references cited in these Approval Order conditions refer to those rules. [R307-101]

I.2 The limits set forth in this Approval Order shall not be exceeded without prior approval.
[R307-401]

DAQE-AN157350003-24
Page 5

I.3 Modifications to the equipment or processes approved by this Approval Order that could affect
the emissions covered by this Approval Order must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this Approval Order or in other applicable rules, which are required to
be kept by the owner/operator, shall be made available to the Director or Director's
representative upon request, and the records shall include the two-year period prior to the date
of the request. Unless otherwise specified in this Approval Order or in other applicable state
and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this Approval Order shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with Utah Administrative Code R307-107. General
Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with Utah Administrative Code R307-150 Series. Emission
Inventories. [R307-150]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Comfort Research Plant

II.A.2 Steam Boiler
Rating: 6.28 MMBtu/hr
Fuel: Natural Gas

II.A.3 Expansion Line
Hirsch PX-18000 Expander Unit
Rating: 5,000 lbs/hr

II.A.4 Several Holding Tents

II.A.5 Filling, Sewing, and Packaging Lines
Two (2) production lines for filling, sewing, and packaging bean bag products. Listed for
informational purposes only.

DAQE-AN157350003-24
Page 6

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Hirsch expander unit exhaust point - 10% opacity.

B. Boiler exhaust points - 10% opacity.

C. All other points - 20% opacity.

[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to Title
40 of the Code of Federal Regulations 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall not process more than 2.25 million pounds of raw bead material per
rolling 12-month period. [R307-401-8]

II.B.1.b.1 The owner/operator shall:

A. Determine the raw bead material throughput by purchase records.

B. Record raw bead material throughput on a daily basis.

C. Use the monthly raw bead material throughput data to calculate a new 12-month
total by the 20th day of each month using data from the previous 12 months.

D. Keep the throughput records for all periods the plant is in operation.

[R307-401-8]

II.B.1.c The pentane content in the EPS beads processed on site shall not exceed 6.0% by weight.
[R307-401-8]

II.B.1.c.1 The owner/operator shall maintain the following records for each load of raw bead material
that is received for processing:

A. Date received.

B. Percent by weight of pentane in the raw bead material.

C. Weight of raw bead load.

[R307-401-8]

II.B.2 Boiler Requirements
II.B.2.a The owner/operator shall use only natural gas as fuel in the boiler. [R307-401-8]

II.B.2.b The owner/operator shall not operate the boiler for more than 4,488 hours per rolling 12-month
period. [R307-401-8]

DAQE-AN157350003-24
Page 7

II.B.2.b.1 The owner/operator shall:

A. Determine hours of operation with a supervisor monitoring and maintaining an
operations log.

B. Record hours of operation each day.

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th
day of each month using data from the previous 12 months.

D. Keep hours of operation records for all periods the plant is in operation.

[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN157350001-17 dated June 20, 2017
Is Derived From NOI dated April 14, 2021
Incorporates Additional Information dated February 27, 2024

DAQE-AN157350003-24
Page 8

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
National
Ambient Air
Quality
Standards
National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
Particulate
matter less than
10 microns in
size
Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
Potential to emit Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Tons per year Tons per year
UAC Utah Administrative Code
DAQE-AN157350003-24
Page 9

VOC Volatile organic compounds

DAQE-IN157350003-24

March 15, 2024

Bobby Rakes
Comfort Research, LLC
1719 Elizabeth Avenue NW
Grand Rapids, MI 49504
[e-mail]

Dear Mr. Rakes:

Re: Intent to Approve: Minor Modification to AO DAQE-AN157350001-17 to Increase Bead
Pentane Content, Increase Boiler Operation Hours, and Reduce Production Limit
Project Number: N157350003

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Christine Bodell, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Christine Bodell, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:CB:jg

cc: Bear River Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN157350003-24
Minor Modification to Approval Order DAQE-AN157350001-17 to
Increase Bead Pentane Content, Increase Boiler Operation Hours,
and Reduce Production Limit

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Comfort Research, LLC - Polystyrene Filled Products Manufacturing

Issued On
March 15, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-IN157350003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Comfort Research, LLC Comfort Research, LLC - Polystyrene Filled
Products Manufacturing

Mailing Address Physical Address
1719 Elizabeth Avenue NW 350 West 1000 North
Grand Rapids, MI 49504 Tremonton, UT 84337

Source Contact UTM Coordinates
Name: Bobby Rakes 402,350 m Easting
Phone: [phone],620,180 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 3086 (Plastics Foam Products)

SOURCE INFORMATION
General Description
Comfort Research, LLC (Comfort Research) owns/operates a polystyrene-filled product manufacturing
facility in Tremonton, Box Elder County. These products include bean bag chairs and other furniture filled
with expanded polystyrene (EPS) foam beads. The facility operates three (3) production lines. The first
production line inflates EPS beads using an expander unit. The EPS beads are inflated by blowing steam
across the beads in a steam chamber. The steam is generated using a 6.28 MMBtu/hr boiler. After initial
expansion, the beads move to the fluidized bed section of the expander unit for partial drying and are then
transferred to the first-pass stabilization/holding tent. The beads are allowed to stabilize for several hours in
porous tents. After stabilizing, the beads are transferred back to the expander unit for final expansion. The
beads are then transferred to a porous holding tent for final curing. The second and third production lines are
used for filling bean bag products with EPS beads, sewing, and packaging.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA
Box Elder County
Airs Source Size: SM

DAQE-IN157350003-24
Page 4

Applicable Federal Standards
None
Project Description
Comfort Research has requested the following changes:

1. Increase the pentane content in the EPS beads processed on site from 4.5% by weight to 6.0% by weight
(Condition II.B.1.c in AO DAQE-AN157350001-17).

2. Reduce the throughput of raw bead material from 2.5 million pounds per rolling 12-month period to 2.25
million pounds per rolling 12-month period (Condition II.B.1.b (A) in AO DAQE-AN157350001-17).

3. Increase the hours of operation for the boiler from 2,244 hours per rolling 12-month period to 4,488 hours
per rolling 12-month period (Condition II.B.1.b (B) in AO DAQE-AN157350001-17).

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some rounding
of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 843 1668.00
Carbon Monoxide 0.58 1.16
Nitrogen Oxides 0.69 1.38
Particulate Matter - PM10 0.04 0.11
Particulate Matter - PM2.5 0.04 0.11
Sulfur Dioxide 0.01 0.01
Volatile Organic Compounds 10.63 67.58

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 2
Hexane (CAS #110543) 30 50
Change (TPY) Total (TPY)
Total HAPs 0.02 0.03

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution-producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Box Elder News & Journal on March 20, 2024. During the public
comment period, the proposal and the evaluation of its impact on air quality will be available for the public
to review and provide comments. If anyone so requests a public hearing within 15 days of publication, it will
be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location
of the source. Any comments received during the public comment period and the hearing will be evaluated.
The proposed conditions of the AO may be changed as a result of the comments received.

DAQE-IN157350003-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended conditions
and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended conditions
and that failure to comply with any of the conditions may constitute a violation of the AO.

II.A THE APPROVED EQUIPMENT

II.A.1 Comfort Research Plant

II.A.2 Steam Boiler
Rating: 6.28 MMBtu/hr
Fuel: Natural Gas

II.A.3 Expansion Line
Hirsch PX-18000 Expander Unit
Rating: 5,000 lbs/hr

DAQE-IN157350003-24
Page 6

II.A.4 Several Holding Tents

II.A.5 Filling, Sewing, Packaging Lines
Two (2) production lines for filling, sewing, and packaging bean bag products. Listed for
information purposes only.

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended conditions
and that failure to comply with any of the conditions may constitute a violation of the AO.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Hirsch expander unit exhaust point - 10% opacity.

B. Boiler exhaust points - 10% opacity.

C. All other points - 20% opacity.

[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall not process more than 2.25 million pounds of raw bead material per
rolling 12-month period. [R307-401-8]

II.B.1.b.1 The owner/operator shall:

A. Determine the raw bead material throughput by purchase records.

B. Record raw bead material throughput on a daily basis.

C. Use the monthly raw bead material throughput data to calculate a new 12-month
total by the 20th day of each month using data from the previous 12 months.

D. Keep the throughput records for all periods the plant is in operation.

[R307-401-8]

II.B.1.c The pentane content in the EPS beads processed on site shall not exceed 6.0% by weight.
[R307-401-8]

DAQE-IN157350003-24
Page 7

II.B.1.c.1 The owner/operator shall maintain the following records for each load of raw bead material
that is received for processing:

A. Date received.

B. Percent by weight of pentane in the raw bead material.

C. Weight of raw bead load.

[R307-401-8]

II.B.2 Boiler Requirements
II.B.2.a The owner/operator shall use only natural gas as fuel in the boiler. [R307-401-8]

II.B.2.b The owner/operator shall not operate the boiler for more than 4,488 hours per rolling 12-month
period. [R307-401-8]

II.B.2.b.1 The owner/operator shall:

A. Determine hours of operation with a supervisor monitoring and maintaining an
operations log.

B. Record hours of operation each day.

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th
day of each month using data from the previous 12 months.

D. Keep hours of operation records for all periods the plant is in operation.

[R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN157350001-17 dated June 20, 2017
Is Derived From NOI dated April 14, 2021
Incorporates Additional Information dated February 27, 2024

DAQE-IN157350003-24
Page 8

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

3/18/24, 11:01 AM State of Utah Mail - Legal Notice to be published March 20, 2024
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permthid=thread-a:r-594305673595131868&simpl=msg-a:r378219327003950…1/3
Jeree Greenwood <[e-mail]>
Legal Notice to be published March 20, 2024
2 messages
Jeree Greenwood <[e-mail]>Mon, Mar 18, 2024 at 7:00 AM
To: Box Elder News & Journal <[e-mail]>
Please publish the following notice on March 20, 2024.
If you can, please reply to this email for my records.
Jeree
--
Jeree Greenwood
Office Technician II | Minor NSR Section
M: [phone]
airquality.utah.gov
DAQE-NN157350003-24.pdf
336K
BENJ Legals <[e-mail]>Mon, Mar 18, 2024 at 10:35 AM
To: Jeree Greenwood <[e-mail]>
Jeree,
Your legal notice has been scheduled for March 20.

Thanks,

Erin Young Aho
3/18/24, 11:01 AM State of Utah Mail - Legal Notice to be published March 20, 2024
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permthid=thread-a:r-594305673595131868&simpl=msg-a:r378219327003950…2/3
Legal Notices, Box Elder News Journal

The deadline for legal notices is MONDAY BY NOON prior to Wednesday publication. If there is a Monday holiday, the deadline is
FRIDAY BY NOON.

From: Jeree Greenwood <[e-mail]>
Date: Monday, March 18, 2024 at 6:03 AM
To: BENJ Legals <[e-mail]>
Subject: Legal Notice to be published March 20, 2024
Please publish the following notice on March 20, 2024. If you can, please reply to this email for my records. Jeree -- Jeree Greenwood Office Technician II | Minor NSR Section
sophospsmartbannerend
Please publish the following notice on March 20, 2024.
If you can, please reply to this email for my records.

Jeree

--
Image removed by sender. Division Name
Jeree Greenwood
Office Technician II | Minor NSR Section
M: [phone]
airquality.utah.gov
Image removed by sender.Image removed by sender.

3/18/24, 11:01 AM State of Utah Mail - Legal Notice to be published March 20, 2024
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permthid=thread-a:r-594305673595131868&simpl=msg-a:r378219327003950…3/3
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DAQE-NN157350003-24

March 15, 2024

Box Elder News & Journal
Legal Advertising Dept
PO BOX 370
Brigham City, UT 84302-0370

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Box Elder News &
Journal on March 20, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Bear River Association of Governments
cc: Box Elder County

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN157350003-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Comfort Research, LLC
Location: Comfort Research, LLC - Polystyrene Filled Products Manufacturing – 350 West
1000 North, Tremonton, UT
Project Description: Comfort Research, LLC (Comfort Research) owns/operates a polystyrene-filled
product manufacturing facility in Tremonton, Box Elder County. These products
include bean bag chairs and other furniture filled with expanded polystyrene
(EPS) foam beads. The facility operates three (3) production lines. The first
production line inflates EPS beads using an expander unit. The EPS beads are
inflated by blowing steam across the beads in a steam chamber. The steam is
generated using a 6.28 MMBtu/hr boiler. After initial expansion, the beads move
to the fluidized bed section of the expander unit for partial drying and are then
transferred to the first-pass stabilization/holding tent. The beads are allowed to
stabilize for several hours in porous tents. After stabilizing, the beads are
transferred back to the expander unit for final expansion. The beads are then
transferred to a porous holding tent for final curing. The second and third
production lines are used for filling bean bag products with EPS beads, sewing,
and packaging.

Comfort Research has requested the following changes:

1. Increase the pentane content in the EPS beads processed on site from 4.5% by
weight to 6.0% by weight (Condition II.B.1.c in AO DAQE-AN157350001-17).

2. Reduce the throughput of raw bead material from 2.5 million pounds per
rolling 12-month period to 2.25 million pounds per rolling 12-month period
(Condition II.B.1.b (A) in AO DAQE-AN157350001-17).

3. Increase the hours of operation for the boiler from 2,244 hours per rolling 12-
month period to 4,488 hours per rolling 12-month period (Condition II.B.1.b (B)
in AO DAQE-AN157350001-17).

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before April 19, 2024, will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with
R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: March 20, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN157350003
March 7, 2024

Bobby Rakes
Comfort Research, LLC.
1719 Elizabeth Avenue NW
Grand Rapids, MI 49504
[e-mail]

Dear Bobby Rakes,

Re: Engineer Review:
Minor Modification to AO DAQE-AN157350001-17 to Increase Bead Pentane Content, Increase
Boiler Operation Hours, and Reduce Production Limit
Project Number: N157350003

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. Comfort Research,
LLC. should complete this review within 10 business days of receipt.

Comfort Research, LLC. should contact Christine Bodell at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
Christine Bodell at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment
period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by
the DAQ Director.

If Comfort Research, LLC. does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Comfort Research, LLC. has concerns that cannot be resolved
and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.

Approval Signature ___________________________________________11 March 2024____________
(Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Lieutenant Governor

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N157350003
Owner Name Comfort Research, LLC.
Mailing Address 1719 Elizabeth Avenue NW
Grand Rapids, MI, 49504

Source Name Comfort Research, LLC. - Polystyrene Filled Products
Manufacturing
Source Location 350 West 1000 North
Tremonton, UT 84337

UTM Projection 402,350 m Easting, 4,620,180 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3086 (Plastics Foam Products)

Source Contact Bobby Rakes
Phone Number [phone]
Email [e-mail]

Billing Contact Bobby Rakes
Phone Number [phone]
Email [e-mail]

Project Engineer Christine Bodell, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted April 14, 2021
Date of Accepted Application March 1, 2024

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 2
SOURCE DESCRIPTION

General Description
Comfort Research, LLC (Comfort Research) owns/operates a polystyrene-filled products
manufacturing facility in Tremonton, Box Elder County. These products include bean bag chairs
and other furniture filled with expanded polystyrene (EPS) foam beads. The facility operates
three production lines. The first production line inflates EPS beads using an expander unit. The
EPS beads are inflated by blowing steam across the beads in a steam chamber. The steam is
generated using a 6.28 MMBtu/hr boiler. After initial expansion, the beads move to the fluidized
bed section of the expander unit for partial drying, and are then transferred to the first pass
stabilization/holding tent. The beads are allowed to stabilize for several hours in porous tents.
After stabilizing, the beads are transferred back to the expander unit for final expansion. The
beads are then transferred to a porous holding tent for final curing. The second and third
production lines are used for filling bean bag products with EPS beads, sewing and packaging.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA
Box Elder County
Airs Source Size: SM

Applicable Federal Standards
None

Project Proposal
Minor Modification to AO DAQE-AN157350001-17 to Increase Bead Pentane Content and
Reduce Production Limit

Project Description
Comfort Research, LLC (Comfort Research) has requested to following changes:

1. Increase the pentane content in the EPS beads processed on site from 4.5% by weight to 6.0%
by weight (Condition II.B.1.c in AO DAQE-AN157350001-17)

2. Reduce the throughput of raw bead material from 2.5 million pounds per rolling 12-month
period to 2.25 million pounds per rolling 12-month period (Condition II.B.1.b (A) in AO DAQE-
AN157350001-17)

3. Increase the hours of operation for the boiler from 2,244 hours per rolling 12-month period to
4,488 hours per rolling 12-month period (Condition II.B.1.b (B) in AO DAQE-AN157350001-
17).

EMISSION IMPACT ANALYSIS
All criteria pollutants and HAPs emission increases are below their respective modeling thresholds in R307-
410-4 and R307-410-5. Therefore, modeling is not required at this time. [Last updated February 28, 2024]

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 3
SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 843 1668.00
Carbon Monoxide 0.58 1.16
Nitrogen Oxides 0.69 1.38
Particulate Matter - PM10 0.04 0.11
Particulate Matter - PM2.5 0.04 0.11
Sulfur Dioxide 0.01 0.01
Volatile Organic Compounds 10.63 67.58

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 2
Hexane (CAS #110543) 30 50
Change (TPY) Total (TPY)
Total HAPs 0.02 0.03

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Increase in Hours of Operation for Natural Gas-Fired Boilers
The source will be increasing hours of operation of the natural-gas fired boiler from 2,244 hours
annually to 4,488 hours annually. This will result in an increase of 0.69 tpy of NOx, 0.58 tpy of
CO, and small amounts of PM10, PM2.5, VOCs, SO2, and HAPs (<0.1 tpy, each).

The burner on the boiler currently meets an equivalent NOx emission rate of approximately 80
parts per million by volume (ppm). Comfort Research conducted a cost analysis to replace the
current burner to a low-NOx burner (60 ppm) and ultra-Low-NOx burner (30 ppm). The cost
analysis indicated that the cost effectiveness of replacing the current boiler with a low-NOx or
ultra-low-NOx burner would exceed $100,000/ton of NOx reduced. This is considered cost-
prohibitive. Due to the small increase of emissions from the boiler, additional add-on control
technologies would also be cost-prohibitive. Therefore, BACT to control emissions from the boiler
is best operating practices and to limit opacity to 10%. [Last updated February 28, 2024]

2. BACT review regarding Increase in Pentane Content
The source has requested to increase the pentane content in the EPS beads from 4.5% by weight to
6.0% by weight. This results in an increase in 10.64 tpy of VOCs emissions, of which 3.66 tpy will
be non-fugitive and 6.98 tpy will be fugitive.

Available control technologies include carbon adsorption, thermal incineration (TO), and
regenerative thermal oxidizers (RTO). All three control options were evaluated as part of this
BACT analysis.

Carbon adsorption controls VOC by adsorbing VOCs onto the surface of granulated activated
carbon. There are two types of carbon adsorption system, regenerable (e.g. fixed bed) systems and
non-regenerable (e.g. carbon canisters). Carbon adsorption systems are typically designed to
achieve a 95% control efficiency; however, this efficiency is reduced for streams with low VOC
concentrations. Gas streams with high temperatures may also reduce the efficiency of carbon
adsorption systems and could create an ignition hazard. Carbon adsorption is not considered a
technically feasible control for the Comfort Research plant due to the high temperature and
humidity of the gas stream and relatively low VOC concentrations.

Thermal incinerators are used to control VOC emissions in a wide variety of industrial
applications. This technology is particularly effective for gas streams with high VOC
concentrations and minor fluctuations in flow. The costs for the supplemental fuel required to
operate these units can be high. These units will typically achieve destruction efficiencies of 98%
to 99.99%. However, the efficiency of thermal incineration for pentane destruction has not been
proven to be effective. For purposes of this BACT analysis, a 95% efficiency was assumed.
Comfort Research estimated that the cost effectiveness of a thermal incineration unit would be
approximately $10,100 per ton of VOC removed. Given the high costs of this control and the
uncertainties with its control efficiency, this option is not considered economically or technically
feasible.

Regenerative Thermal Oxidizers (RTOs) are listed under the RBLC as BACT for EPS emission
controls. RTOs are used for the treatment to exhaust air. A bed of material is used to absorb VOCs
from the exhaust stack. They are suited for low VOC concentrations with high waste stream flow
rates. The media used in the bed varies depending on the type or collection of VOCs to be
oxidized. Comfort Research estimated that the cost effectiveness of an RTO unit would be
approximately $12,000 per ton of VOC removed. The DAQ considers this cost prohibitive,

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 5

Therefore, BACT to control VOC emissions from the EPS process is limiting the pentane content
of the beads to 6.0% by weight, best operating practices, and limiting visible emissions to 10%
opacity. The throughput of raw bead material will be limited to 2.25 million pounds per rolling 12-
month period [Last updated March 4, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-
401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 6
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Comfort Research Plant

II.A.2 Steam Boiler
Rating: 6.28 MMBtu/hr
Fuel: Natural Gas

II.A.3 Expansion Line
Hirsch PX-18000 Expander Unit
Rating: 5,000 lbs/hr

II.A.4 Several Holding Tents

II.A.5 Filling, Sewing, Packaging Lines
Two production lines for filling, sewing, and packaging bean bag products. Listed for
information purposes only.

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1
NEW
Site-Wide Requirements
II.B.1.a
NEW
The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Hirsch expander unit exhaust point - 10% opacity

B. Boiler exhaust points - 10% opacity

C. All other points - 20% opacity

[R307-401-8]

II.B.1.a.1
NEW
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 7
II.B.1.b
NEW
The owner/operator shall not process more than 2.25 million pounds of raw bead material per
rolling 12-month period. [R307-401-8]

II.B.1.b.1
NEW
The owner/operator shall:

A. Determine the raw bead material throughput by purchase records

B. Record raw bead material throughput on a daily basis.

C. Use the monthly raw bead material throughput data to calculate a new 12-month total
by the 20th day of each month using data from the previous 12 months.

D. Keep the throughput records for all periods the plant is in operation.

[R307-401-8]

II.B.1.c
NEW
The pentane content in the EPS beads processed on site shall not exceed 6.0% by weight.
[R307-401-8]

II.B.1.c.1
NEW
The owner/operator shall maintain the following records for each load of raw bead material
that is received for processing:

A. Date received

B. Percent by weight of pentane in the raw bead material

C. Weight of raw bead load

[R307-401-8]

II.B.2
NEW
Boiler Requirements
II.B.2.a
NEW
The owner/operator shall use only natural gas as fuel in the boiler. [R307-401-8]

II.B.2.b
NEW
The owner/operator shall not operate the boiler for more than 4,488 hours per rolling 12-
month period. [R307-401-8]

II.B.2.b.1
NEW
The owner/operator shall:

A. Determine hours of operation with a supervisor monitoring and maintaining an
operations log

B. Record hours of operation each day

C. Use the hours of operation to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months

D. Keep hours of operation records for all periods the plant is in operation

[R307-401-8]

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 8

PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes AO DAQE-AN157350001-17 dated June 20, 2017
Is Derived From NOI dated April 14, 2021
Incorporates Additional Information dated February 27, 2024

REVIEWER COMMENTS

1. Comment regarding Source Emission Estimates and DAQ Acceptance:
Emissions were estimated for EPS bead processing and the steam boiler.

Emissions from EPS bead processing are generated as pentane, a VOC, contained in the EPS beads.
The pentane is released during the expansion and stabilization process. Emissions are based on an
annual bead throughput of 2,250,000 lbs/yr, a bead pentane content of 6.0%, and 4,488 hours of
operation, annually.

The VOC distribution was calculated using Table 5-1 of the EPA's Control of VOC Emissions from
Polystyrene Foam Manufacturing, 68-02-4378, August 1990. Per the EPA document, approximately
15% of pentane is retained in the final product, 47% is released as fugitive emissions, and 38% is
released as non-fugitive emissions. Comfort Research conservatively assumed that all the pentane in
the product is released as a VOC.

Emissions from the boiler were estimated using the emission factors in AP-42, Chapter 1.4 (Natural
Gas Combustion) for HAPs and criteria pollutants, a boiler rating of 6.28 MMBtu/hr, and 4,488
hours of operation per year.
[Last updated February 28, 2024]

2. Comment regarding Federal Standard Applicability:
40 CFR 60 (NSPS) Subpart Dc (Standards of Performance for Small Industrial-Commercial-
Institutional Steam Generating Units) applies to each new steam generating unit that has a maximum
design heat input capacity greater than or equal to 10 MMBtu/hr and less than 100 MMBtu/hr. The
applicability date for NSPS Subpart Dc is June 9, 1989. Steam generating unit means a device that
combusts any fuel and produces steam or heats water or heats any heat transfer medium. Comfort
Research operates one (1) natural gas-fired, 6.28 MMBtu/hr boiler. This boiler is below the 10
MMBtu/hr applicability threshold for this Subpart. Therefore, NSPS Subpart Dc does not apply to
this facility.

40 CFR 63 (MACT) Subpart JJJJJJ (National Emission Standards for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers Area Sources) applies to industrial, commercial, or
institutional boilers located at an area source of HAP emissions. Natural gas-fired boilers are only
subject to this subpart if they have the capability to burn solid fuels during periods of gas
curtailment. The boiler at Comfort Research only operates using natural gas; therefore, MACT
Subpart JJJJJJ does not apply to this unit.
[Last updated February 28, 2024]

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 9
3. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following:

1. Any major source;
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants; or
4. Any Title IV affected source.

This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR
60 (NSPS), 40 CFR 61 (NESHAP) or 40 CFR 63 (MACT) regulations. Therefore, this facility is not
a Title V source.
[Last updated February 28, 2024]

Engineer Review N157350003: Comfort Research, LLC. - Polystyrene Filled Products Manufacturing
March 7, 2024
Page 10
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Equipment Details
Rating 6 MMBtu/hour
Operational Hours 4,488 hours/year
Firing Normal
Criteria Pollutant
Concentration
(ppm)
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 80 0.61 1.37
CO 84 0.52 1.16
PM10 7.6 0.05 0.11
PM2.5 7.6 0.05 0.11
SO2 0.6 0.00 0.01
VOC 5.5 0.03 0.08
Lead 0.0005 0.00 0.00
HAP 0.01 0.0261 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 120,000 739 1,658
Methane (mass basis)25 2.3 0.01 0.03N2O (mass basis)298 2.2 0.01 0.03
CO2e 1,668
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
2-Methylnaphthalene 2.40E-05 1.48E-07 3.32E-07
3-Methylchloranthrene 1.80E-06 1.11E-08 2.49E-08
7,12-Dimethylbenz(a)anthracene 1.60E-05 9.85E-08 2.21E-07
Acenaphthene 1.80E-06 1.11E-08 2.49E-08
Acenaphthylene 1.80E-06 1.11E-08 2.49E-08
Anthracene 2.40E-06 1.48E-08 3.32E-08
Benz(a)anthracene 1.80E-06 1.11E-08 2.49E-08
Benzene 2.10E-03 1.29E-05 2.90E-05
Benzo(a)pyrene 1.20E-06 7.39E-09 1.66E-08
Benzo(b)fluoranthene 1.80E-06 1.11E-08 2.49E-08
Benzo(g,h,i)perylene 1.20E-06 7.39E-09 1.66E-08
Benzo(k)fluoranthene 1.80E-06 1.11E-08 2.49E-08
Chrysene 1.80E-06 1.11E-08 2.49E-08
Dibenzo(a,h)anthracene 1.20E-06 7.39E-09 1.66E-08
Dichlorobenzene 1.20E-03 7.39E-06 1.66E-05
Fluoranthene 3.00E-06 1.85E-08 4.14E-08
Fluorene 2.80E-06 1.72E-08 3.87E-08
Formaldehyde 7.50E-02 4.62E-04 1.04E-03
Hexane 1.80E+00 1.11E-02 2.49E-02
Indeno(1,2,3-cd)pyrene 1.80E-06 1.11E-08 2.49E-08
Naphthalene 6.10E-04 3.76E-06 8.43E-06
Phenanathrene 1.70E-05 1.05E-07 2.35E-07
Pyrene 5.00E-06 3.08E-08 6.91E-08
Toluene 3.40E-03 2.09E-05 4.70E-05
Arsenic 2.00E-04 1.23E-06 2.76E-06
Beryllium 1.20E-05 7.39E-08 1.66E-07
Cadmium 1.10E-03 6.77E-06 1.52E-05
Chromium 1.40E-03 8.62E-06 1.93E-05
Cobalt 8.40E-05 5.17E-07 1.16E-06
Manganese 3.80E-04 2.34E-06 5.25E-06
Mercury 2.60E-04 1.60E-06 3.59E-06
Nickel 2.10E-03 1.29E-05 2.90E-05
Selenium 2.40E-05 1.48E-07 3.32E-07
AP-42 Table 1.4-3
AP-42 Table 1.4-4
Natural Gas-Fired Boilers & Heaters
Manufacturer Data
or AP-42 Table 1.4-1
AP-42 Table 1.4-2
AP-42 Table 1.4-2
&
Table A-1 to
Subpart A of Part 98
Emission Factor
(lb/10^6 scf)
Page 1 of Version 1.0 November 29, 2018
Page 2 of Version 1.0 November 29, 2018
Requested
Raw beads 2,250,000 lb/yr
VOC content 0.06
pentane VOC emissions 135,000 lb/yr
pentane VOC emissions 67.50 tpy
VOC Non-Fug 25.65 tpy
VOC Fugitive 31.73 tpy
Total 57.38
2017 AO Boiler
tpy tpy
NOx 0.69 1.37
SO2 0 0.01
PM10 0.07 0.11
PM25 0.07 0.11
CO 0.58 1.16
VOC 56.95 0.08
CO2e 825 1,668
HAPs 0.010 0.0261
HAPS (lb/hr)20 52
Permitted
Raw beads 2,500,000 lb/yr
VOC content 0.045
VOC emissions 112,500 lb/yr
VOC emissions 56.25 tpy
Production Line New PTE
tpy tpy Increase
1.37 0.68
0.01 0.01
0.11 0.04
0.11 0.04
1.16 0.58
67.50 67.58 10.63
1667.77 842.77
0.00
0.00
0.03 0.02
0
0
52 32
Christine Bodell <[e-mail]>
DIVISION OF AIR QUALITY - Comfort Research 2021 NOI
6 messages
Christine Bodell <[e-mail]>Thu, Feb 22, 2024 at 3:13 PM
To: [e-mail], Jeff Twaddle <[e-mail]>
Good Afternoon,
I am a permitting engineer with the Utah Division of Quality (DAQ). The Comfort Research 2021 NOI (attached) was assigned to me this week.
If possible, can you please email me everything that was sent to Sarah Foran? She is no longer at the DAQ.
I appreciate your patience with this process. I will do what I can to get this NOI processed as soon as possible.
Thank you,
Christine
--
Christine Bodell
Environmental Engineer
Email | [e-mail]
Phone| [phone]
Emails to and from this email address may be considered public records and
thus subject to Utah GRAMA requirements
FINAL_Comfort Research NOI 2021.pdf
2436K
Anielle Duritza <[e-mail]>
To: "[e-mail]" <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>, Steve Marquardt <[e-mail]>, Bobby Rakes <[e-mail]>, Mariah Martinez <[e-mail]>, "ahumpherys@u
Hi Christine,

Please see attached email communication with Sarah. In our meeting with Sarah in November, we discussed that Comfort Research would update the RTO cost analysis and resubmit to UDAQ. Comfort Resear
an RTO quote. We believe that the BACT submitted in the April 2021 NOI application shows that RTO control is not cost effective. Please review the original BACT analysis and let us know if you agree that the R
should continue pursuing an RTO quote and resubmit the cost analysis.

We also met this week with Alan Humphreys, Susan Weisenberg, and Chad Gilgen regarding the response letter to the Compliance Advisory Letter (attached) and the internal UDAQ transition and review of the
Compliance Advisory (DAQC-1141-23) issued on October 20, 2023 follows a Warning Letter (DAQC-163-20) issued on February 26, 2020 and a Compliance Advisory (DAQC-207-21) issued on February 19, 202
pentane content of the EPS beads.

Thank you kindly,
Anielle

Anielle Duritza
Consultant, Engineering
She/Her/Hers

250 East 200 South, Floor 16, Salt
Lake City, UT 84111 erm.com
832-924-5304

From: Jeff Twaddle <[e-mail]>
Sent: Thursday, February 22, 2024 3:30 PM
To: Steve Marquardt <[e-mail]>; Anielle Duritza <[e-mail]>
Subject: Fwd: DIVISION OF AIR QUALITY - Comfort Research 2021 NOI

Fyi

Get Outlook for iOS
From: Christine Bodell <[e-mail]>
Sent: Thursday, February 22, 2024 4:13:48 PM
To: [e-mail] <[e-mail]>; Jeff Twaddle <[e-mail]>
Subject: DIVISION OF AIR QUALITY - Comfort Research 2021 NOI

You don't often get email from [e-mail]. Learn why this is important
EXTERNAL MESSAGE
[Quoted text hidden]
This e-mail and any attachments may contain proprietary, confidential and/or privileged information. No confidentiality or privilege is waived or lost by any transmission errors. This communication is intended solely for the intended recipient, and if you are not the intended rec
and do not copy, distribute, disclose, or otherwise act upon any part of this email communication or its attachments. To find out how the ERM Group manages personal data please review our Privacy Policy
---------- Forwarded message ----------
From: Sarah Foran <[e-mail]>
To: Anielle Duritza <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>, Mariah Martinez <[e-mail]>, Steve Marquardt <[e-mail]>, Bobby Rakes <[e-mail]>
Bcc:
Date: Mon, 27 Nov 2023 22:33:28 +0000
Subject: Re: Status of 2021 NOI Application
EXTERNAL MESSAGE
HI Anielle,
10am Thursday works for me.
Thanks,
Sarah Foran, PE
Environmental Engineer | Major NSR
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
On Mon, Nov 27, 2023 at 3:02 PM Anielle Duritza <[e-mail]> wrote:
Hi Sarah,

Comfort Research has asked ERM to reengage and respond to the missing information request for the 2021 NOI pertaining to the RTO as BACT. We would like to meet with you and UDAQ to discuss a few qu

We are available this Wednesday (11/29) between 1 PM – 3 PM MT, and Thursday (11/30) between 10 AM – 12 PM MT or after 3 PM MT. Please let me know a time that works best for your schedule, and I wi
have another preferred meeting platform, please forward an invite to the people CC’d on this e-mail and myself.

Thank you kindly,

Anielle Duritza
Consultant, Engineering
She/Her/Hers

250 East 200 South, Floor 16, Salt Lake City, UT
84111 erm.com
832-924-5304

From: Sarah Foran <[e-mail]>
Sent: Thursday, October 19, 2023 2:23 PM
To: Bobby Rakes <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>; Anielle Duritza <[e-mail]>; Mariah Martinez <[e-mail]>; Steve Marquardt <[e-mail]>
Subject: Re: Status of 2021 NOI Application

EXTERNAL MESSAGE

Perfect, thanks.

For summary, UDAQ is waiting on Comfort Research's decision/new evaluation. for a thermal oxidizer control. I have included what I think are the relevant emails below and attached the NOI I have:

Sarah Foran <[e-mail]>
to bobby.rakes, Ann
Good Afternoon,

I spoke with management and they do feel that the current cost per ton is cost-effective in relation to installing a thermal incinerator on the process.

We understand that the costs have potentially changed since the NOIs submission, so if you would like to update your cost quotes, just let me know.

Thanks,
Sarah Foran, PE
Environmental Engineer | Major NSR
M: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

Here is the original email from when I received the project (the calculator questions have since been answered).

On Thu, May 25, 2023 at 8:42 AM Sarah Foran <[e-mail]> wrote:
Good Morning,

I am reaching out to let you know that your request for a modification to your AO was just transferred to me.

I see that the request is for an increase in VOCs due to material changes and adding on-site boilers.

Based on my quick review I noticed that the BACT costs were evaluated in cost per lb rather than cost per ton, this section will need to be updated.

I will let you know as I do a more thorough review if there are any other questions or comments. I do have a large queue of projects but I will expedite yours as much as possible. However, I will need the B
application fully.

Please feel free to reach out with questions or concerns.

Thank you,

On Thu, Oct 19, 2023 at 1:38 PM Bobby Rakes <[e-mail]> wrote:
Sarah,

ERM is authorized to act on our behalf and has full authority to review any coorespondence.

Thanks!

BOBBY “SAND DAWG” RAKES
MASTER SERGEANT, USAF (RET.)
DIRECTOR OF OPERATIONS
616.475.5000 X401

COMFORT RESEARCH
CREATORS OF BIG JOE

From: Steve Marquardt <[e-mail]>
Sent: Thursday, October 19, 2023 2:49 PM
To: Bobby Rakes <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>; Anielle Duritza <[e-mail]>; Sarah Foran <[e-mail]>; Mariah Martinez <[e-mail]>
Subject: RE: Status of 2021 NOI Application

Bobby,

Could you please send a response to Sarah at the State of Utah letting her know that ERM is still/again authorized to review the old correspondence?

She can be reached at [e-mail]

Thank you,

Steve Marquardt
Managing Consultant

901 Woodland Str, Suite 104, Nashville,
TN 37206 erm.com
[phone]

From: Anielle Duritza <[e-mail]>
Sent: Thursday, October 19, 2023 1:23 PM
To: Sarah Foran <[e-mail]>
Cc: Steve Marquardt <[e-mail]>; Jeff Twaddle <[e-mail]>
Subject: RE: Status of 2021 NOI Application

Hi Sarah,

No worries at all - ERM prepared the application, and our company name appears both on the application and the cover letter attached to the application. Let me know if you have any additional questions.

Continued thanks,

Anielle Duritza
Consultant, Engineering
She/Her/Hers

250 East 200 South, Floor 16, Salt Lake
City, UT 84111 erm.com
832-924-5304

From: Sarah Foran <[e-mail]>
Sent: Thursday, October 19, 2023 12:04 PM
To: Anielle Duritza <[e-mail]>
Cc: Steve Marquardt <[e-mail]>; Jeff Twaddle <[e-mail]>
Subject: Re: Status of 2021 NOI Application

EXTERNAL MESSAGE

Normally this wouldn't be a problem at all, but since the project has changed hands within the company, I just need the company representative to "authorize" ERM to be included again.

(sorry for the inconvenience)
Sarah Foran, PE
Environmental Engineer | Major NSR
M: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

On Thu, Oct 19, 2023 at 11:46 AM Anielle Duritza <[e-mail]> wrote:
Hi Sarah,

Thank you for this information.

Do you mind forwarding me a copy of the information that was requested to complete the application, and any additional letters or emails sent to Comfort Research about the application?

Thank you kindly,

Anielle Duritza
Consultant, Engineering
She/Her/Hers

250 East 200 South, Floor 16, Salt Lake
City, UT 84111 erm.com
832-924-5304

From: Sarah Foran <[e-mail]>
Sent: Wednesday, October 4, 2023 6:59 PM
To: Anielle Duritza <[e-mail]>
Subject: Re: Status of 2021 NOI Application

EXTERNAL MESSAGE

Hi Anielle,

I have been working with Ann Mason at Comfort Research. The project is currently paused while I wait for additional information.

Thanks,
Sarah Foran, PE
Environmental Engineer | Major NSR
M: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

On Tue, Oct 3, 2023 at 3:08 PM Anielle Duritza <[e-mail]> wrote:
Hi Sarah,

I recently reached out to UDAQ, and received your contact information. Comfort Research, LLC (Site ID: 15735) submitted a NOI on April 14, 2021. Would you know the status of the application? When
mentioned that it was under internal review, but I was wondering if you had any further information.

Thank you,

Anielle Duritza
Consultant, Engineering
She/Her/Hers

250 East 200 South, Floor 16, Salt Lake City, UT
84111 erm.com
832-924-5304

This message contains information which may be confidential, proprietary, privileged, or otherwise protected by law from disclosure or use by a third party. If you have received this message in error, please contact us immediately at [phone] and take the
computer system. Thank you.
Please visit ERM's web site: http://www.erm.com. To find out how ERM manages personal data, please review our Privacy Policy

This e-mail and any attachments may contain proprietary, confidential and/or privileged information. No confidentiality or privilege is waived or lost by any transmission errors. This communication is intended solely for the intended recipient, and if you are not the in
your system and do not copy, distribute, disclose, or otherwise act upon any part of this email communication or its attachments. To find out how the ERM Group manages personal data please review our Privacy Policy

This e-mail and any attachments may contain proprietary, confidential and/or privileged information. No confidentiality or privilege is waived or lost by any transmission errors. This communication is intended solely for the intended recipient, and if you are not the intend
system and do not copy, distribute, disclose, or otherwise act upon any part of this email communication or its attachments. To find out how the ERM Group manages personal data please review our Privacy Policy
This e-mail and any attachments may contain proprietary, confidential and/or privileged information. No confidentiality or privilege is waived or lost by any transmission errors. This communication is intended solely for the intended recipient, and if you are not the intended
system and do not copy, distribute, disclose, or otherwise act upon any part of this email communication or its attachments. To find out how the ERM Group manages personal data please review our Privacy Policy
---------- Forwarded message ----------
From: Bobby Rakes <[e-mail]>
To: "[e-mail]" <[e-mail]>, Susan Weisenberg <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>, Anielle Duritza <[e-mail]>
Bcc:
Date: Mon, 12 Feb 2024 18:08:32 +0000
Subject: //COMFORT RESEARCH// Response to October 20, 2023 Compliance Advisory Letter
Some people who received this message don't often get email from [e-mail]. Learn why this is important
EXTERNAL MESSAGE
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

3 attachments
Re: Status of 2021 NOI Application.eml
152K
SIGNED--Comfort Research LLC (15735)_Response to CA Letter_02 07 2024.docx
70K
//COMFORT RESEARCH// Response to October 20, 2023 Compliance Advisory Letter.eml
118K
Christine Bodell <[e-mail]>Mon, Feb 26, 2024 at 10:54 AM
To: Anielle Duritza <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>, Steve Marquardt <[e-mail]>, Bobby Rakes <[e-mail]>, Mariah Martinez <[e-mail]>
Hello Aniella,
Thank you for responding to my email. I have had time to review the NOI in its entirely and have the following comments:
Item 1. Page 9 of the NOI (Table 4-1 Summary of Emissions):
I get a total VOC potential to emit of 67.58 tpy (EPS Bead Processing (67.5 tpy) + Boiler VOC (0.08 tpy) = 67.58 tpy). Page 9 of the NOI is accounting for an extra ton of VOC, but I cannot find where it is
coming from. Why is the VOC stack amount set to 27.03 tpy instead of 25.65 tpy?
Item 2. TO BACT Analysis:
Based on the BACT Calculations, it looks like the total capital costs is approximately $325,000. Assuming a 10 year life span on the equipment, this would equal an annualized capital cost of $32,500. It also
looks like the annual operation and maintenance costs are equal to roughly $245,000.
The total cost of the TO would be $32,500 + $245,000 = $277,500, without considering capital recovery.
Of the 65.7 tpy of VOCs contained in the process, 47% are released as fugitive emissions, 38% is released as non-fugitive emissions, and 15% is retained in the product, per EPA guidance (Control of VOC
Emissions from Polystrene Foam Manufacturing, EPA-450/3-90-020, September 1990, EPA Contract 68-02-4378).
Therefore, of the 67.5 tpy of VOC emissions total, 25.65 tpy are non-fugitive (38%).
TO's typically reduce VOCs by up to 98%. Therefore, the annual tons of VOCs reduced by the TO is 0.98* 25.65 tpy = 25 tpy (rounded)
$/ton of VOC reduced = $277,500/25 tons of VOCs reduced= $11,100/ton VOC reduced.
Considering that the source is located in an attainment area for ozone, I would consider this value to be cost prohibitive and therefore agree with the BACT determination. Comfort Research is still welcome
to resubmit an updated cost analysis if it elects to do so. However, there is no need for Comfort Research to continue pursuing an RTO quote at this time. Please let me know if you would like me
to proceed with the application process.
Thank you,
Christine
[Quoted text hidden]
Anielle Duritza <[e-mail]>Tue, Feb 27, 2024 at 3:16 PM
To: Christine Bodell <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>, Steve Marquardt <[e-mail]>, Bobby Rakes <[e-mail]>, Mariah Martinez <[e-mail]>
Hi Christine,

I have responded in blue below.

Thank you kindly,
Anielle

Anielle Duritza
Consultant, Engineering
She/Her/Hers

250 East 200 South, Floor 16, Salt
Lake City, UT 84111 erm.com
832-924-5304
You don't often get email from [e-mail]. Learn why this is important

From: Christine Bodell <[e-mail]>
Sent: Monday, February 26, 2024 10:54 AM
To: Anielle Duritza <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>; Steve Marquardt <[e-mail]>; Bobby Rakes <[e-mail]>; Mariah Martinez <[e-mail]>
Subject: Re: DIVISION OF AIR QUALITY - Comfort Research 2021 NOI

EXTERNAL MESSAGE

Hello Aniella,

Thank you for responding to my email. I have had time to review the NOI in its entirely and have the following comments:

Item 1. Page 9 of the NOI (Table 4-1 Summary of Emissions):
I get a total VOC potential to emit of 67.58 tpy (EPS Bead Processing (67.5 tpy) + Boiler VOC (0.08 tpy) = 67.58 tpy). Page 9 of the NOI is accounting for an extra ton of VOC, but I cannot find where it is
coming from. Why is the VOC stack amount set to 27.03 tpy instead of 25.65 tpy?

The emissions summary table on PDF page 9 and 28 of the NOI application are incorrect as you suspected. In the emissions summary table, the stack VOC emissions had accidentally added the NOX
emissions from the boiler (1.38 tons per year) instead of the VOC emissions from the boiler (0.08 tpy). This results in a change of 1.3 tpy (1.38 tpy – 0.08 tpy = 1.3 tpy), which is reflected in the difference
between 27.03 tpy and 25.73 tpy VOC (27.03 tpy – 25.73 tpy = 1.3 tpy). I also updated the changes to PM10 and PM2.5 in the emissions summary table, which had accidentally double counted the filterable
particulate emissions. The corrected emissions are highlighted in the table below. If you would prefer, we can also provide revised PDF pages 9 and 28 to correspond with the emissions summary table
below.
Table 4‑1 Summary of Emissions
Pollutant
Previous Potential Emissions Proposed Potential Emissions
Increased
Potential
Emissions
(Tons/Yr)(Tons/Yr)(Tons/Yr)
NOx 0.69 1.38 0.69
SO2 0.00 0.01 <0.005
PM10 0.06 0.11 0.05
PM2.5 0.06 0.11 0.05
Condensable PM 0.04 0.08 0.04
CO 0.58 1.16 0.58
VOC Stack 22.07 25.73 3.66
VOC Fugitive 34.88 41.85 6.98
Total VOC (stack +fugitive)56.94 67.58 10.64
Major HAPs Lbs/yr
Lead 0.007 0.014 0.07
Hexane 24.87 49.74 24.87
Total HAPs (incl. Hexane)26.09 52.18 26.09

Item 2. TO BACT Analysis:
Based on the BACT Calculations, it looks like the total capital costs is approximately $325,000. Assuming a 10 year life span on the equipment, this would equal an annualized capital cost of $32,500. It also
looks like the annual operation and maintenance costs are equal to roughly $245,000.

The total cost of the TO would be $32,500 + $245,000 = $277,500, without considering capital recovery.

Of the 65.7 tpy of VOCs contained in the process, 47% are released as fugitive emissions, 38% is released as non-fugitive emissions, and 15% is retained in the product, per EPA guidance (Control of VOC
Emissions from Polystrene Foam Manufacturing, EPA-450/3-90-020, September 1990, EPA Contract 68-02-4378).

Therefore, of the 67.5 tpy of VOC emissions total, 25.65 tpy are non-fugitive (38%).
TO's typically reduce VOCs by up to 98%. Therefore, the annual tons of VOCs reduced by the TO is 0.98* 25.65 tpy = 25 tpy (rounded)

$/ton of VOC reduced = $277,500/25 tons of VOCs reduced= $11,100/ton VOC reduced.

Considering that the source is located in an attainment area for ozone, I would consider this value to be cost prohibitive and therefore agree with the BACT determination. Comfort Research is still welcome
to resubmit an updated cost analysis if it elects to do so. However, there is no need for Comfort Research to continue pursuing an RTO quote at this time. Please let me know if you would like me
to proceed with the application process.

Comfort Research agrees with your assessment that the value is not cost effective, and as such, will pause on pursuing an RTO quote at this time. Comfort Research would like UDAQ to proceed with the
application process. Please let me know if you have any further questions.

Thank you,
Christine

[Quoted text hidden]
[Quoted text hidden]
Christine Bodell <[e-mail]>Wed, Feb 28, 2024 at 8:08 AM
To: Anielle Duritza <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>, Steve Marquardt <[e-mail]>, Bobby Rakes <[e-mail]>, Mariah Martinez <[e-mail]>
Hello Anielle,
The new values you provided match my estimates. There is no need for you to provide a revised PDF of NOI pages 9 and 28.
Is the appropriate contact still Mike Kitchen?
Best,
Christine
[Quoted text hidden]
Steve Marquardt <[e-mail]>Wed, Feb 28, 2024 at 8:33 AM
To: Christine Bodell <[e-mail]>, Anielle Duritza <[e-mail]>
Cc: Jeff Twaddle <[e-mail]>, Bobby Rakes <[e-mail]>, Mariah Martinez <[e-mail]>
Hello Christine,

Anielle is out of the office this morning, or I would normally have her respond.

The appropriate contact is now Bobby Rakes.

BOBBY “SAND DAWG” RAKES
Master sergeant, usaf (ret.)
DIRECTOR OF OPERATIONS
616.475.5000 X401

Please contact Anielle if you have any questions. Thank you,

Steve Marquardt
Managing Consultant

901 Woodland Str, Suite 104,
Nashville, TN 37206 erm.com
[phone]

[Quoted text hidden]
EXTERNAL MESSAGE

[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
EXTERNAL MESSAGE

[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
EXTERNAL MESSAGE

[Quoted text hidden]

--

Christine Bodell
Environmental Engineer
Email | [e-mail]
Phone| [phone]
Emails to and from this email address may be considered public records and
thus subject to Utah GRAMA requirements

This e-mail and any attachments may contain proprietary, confidential and/or privileged information. No confidentiality or privilege is waived or lost by any transmission errors. This communication is intended solely for the intended recipient, and if you are not the
intended recipient, please notify the sender immediately, delete it from your system and do not copy, distribute, disclose, or otherwise act upon any part of this email communication or its attachments. To find out how the ERM Group manages personal data
please review our Privacy Policy

This e-mail and any attachments may contain proprietary, confidential and/or privileged information. No confidentiality or privilege is waived or lost by any transmission errors. This communication is intended solely for the intended recipient, and if you are not the
intended recipient, please notify the sender immediately, delete it from your system and do not copy, distribute, disclose, or otherwise act upon any part of this email communication or its attachments. To find out how the ERM Group manages personal data please
review our Privacy Policy
[Quoted text hidden]
The business of sustainability

Notice of Intent for Permit Modification
Comfort Research

14 April 2021
Project No.: 0592594

www.erm.com Version: 1.0 Project No.: 0592594 Client: Comfort Research 14 April 2021
Signature Page

14 April 2021

Notice of Intent for Permit Modification

Comfort Research

Jeff Twaddle, P.E.
Partner

Suzy Smith, P.E.
Senior Consultant

ERM-West, Inc.
136 East South Temple
Suite 2150
Salt Lake City, UT 84111

T: [phone]
F: [phone]

© Copyright 2021 by ERM Worldwide Group Ltd and / or its affiliates (“ERM”).
All rights reserved. No part of this work may be reproduced or transmitted in any form,
or by any means, without the prior written permission of ERM.

www.erm.com Version: 1.0 Project No.: 0592594 Client: Comfort Research 14 April 2021 Page i
NOTICE OF INTENT FOR PERMIT MODIFICATION
Comfort Research
CONTENTS
CONTENTS
1. INTRODUCTION ................................................................................................................................ 1
2. FACILITY DESCRIPTION .................................................................................................................. 2
3. PROCESS INFORMATION ................................................................................................................ 3
3.1 OPERATION SCHEDULES .................................................................................................................. 3
4. EMISSION RELATED INFORMATION .............................................................................................. 4
4.1 Offset Applicability ................................................................................................................................ 5
5. REGULATORY REVIEW ................................................................................................................... 6
5.1 Federal.................................................................................................................................................. 6
5.2 State ..................................................................................................................................................... 6
5.3 Non-Attainment New Source Review .................................................................................................... 7
5.4 Modeling/Emission Impact Analysis ...................................................................................................... 7
5.5 Best Available Control Technology (BACT) Analysis ............................................................................ 7
5.5.1 BACT Query ........................................................................................................................ 7
5.5.2 Evaluation of Hirsch Expander ............................................................................................. 9
5.5.3 Ranking of EPS Control Technologies ............................................................................... 10
5.6 Small Steam Boiler RACT/BACT LEAR .............................................................................................. 10
5.6.1 Ranking of Boiler Control Technologies ............................................................................. 16
5.7 Cost Analyses ..................................................................................................................................... 17

APPENDIX A SITE MAP
APPENDIX B PROCESS FLOW DIAGRAMS
APPENDIX C FACILITY EMISSIONS
APPENDIX D UDAQ FORMS
APPENDIX E BACT CALCULATIONS
APPENDIX F SPECIFICATION SHEETS/SAFETY DATA SHEETS

List of Tables
Table 4-1 Summary of Emissions ................................................................................................................. 4
Table 5-1 BACT Cost Comparisons ............................................................................................................ 17

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CONTENTS
Acronyms and Abbreviations
AO Approval Order
BACT Best Available Control Technology
CFR Code of Federal Regulations
CO Carbon monoxide
EPS Expendable polystyrene
GHG Greenhouse gas
HAP Hazardous Air Pollutant
lbs/hr Pounds per hour
MMBtu/hr Million British Thermal Units per hour
MMSCF Million standard cubic feet
NAA Non-Attainment Area
NOI Notice of Intent
NOx Oxides of nitrogen
NSR New Source Review
PFD Process Flow Diagram
PM10 Particulate Matter, less than 10 microns
PM2.5 Particulate Matter, less than 2.5 microns
ppm Parts per million
PTE Potential-to-Emit
RBLC RACT/BACT/LEAR Clearinghouse
RTO Regenerative Thermal Oxidizer
Sf Square feet
SIC Standard Industrial Code
SIP State Implementation Plan
SO2 Sulfur dioxides
Tpy Tons per year
UDAQ Utah Division of Air Quality
USEPA United State Environmental Protection Agency
UTM Universal Transverse Mercator
VOCs Volatile organic compounds

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INTRODUCTION
1. INTRODUCTION
Comfort Research, LLC (Comfort Research) occupies a portion of the building located at 350 W 1000
North, Tremonton, Utah. Comfort Research is considered a Minor Source with the largest criteria pollutant
being volatile organic compounds (VOCs). This Box Elder County facility is located in the Particulate
Matter less than 2.5 microns (PM2.5), Non-Attainment Area (NAA).
Comfort Research manufactures various polystyrene filled products. These products include bean bag
chairs and other furniture filled with expanded polystyrene (EPS) foam beads. For additional information
on the final products, please see www.comfortresearch.com.
Comfort Research is submitting this Notice of Intent (NOI) for approval to modify the current Approval
Order (AO) AN157350001-17. The pentane content of the beads used will increase to approximately 6%
by weight, versus 4.5% as allowed by the current permit. In addition, Comfort Research proposes to
increase the operating hours and decrease the annual throughput of the beads. This NOI is prepared
using Potential-to-Emit (PTE) emissions based on Comfort Research’s predicted maximum production.
The criteria pollutant emission estimations presented herein show the proposed changes are not
considered a Major Modification, nor are emission offsets required. The following information is provided
as part of this NOI in accordance with the requirements of Utah Division of Air Quality (UDAQ) Air Quality
Regulations R307 401-5.

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FACILITY DESCRIPTION
2. FACILITY DESCRIPTION
Comfort Research occupies 94,500 square feet (sf) of a 675,000 sf facility. The owners of the building
operate their own boiler for building heat, which is not part of Comfort Research’s permit. Comfort
Research uses the manufacturing floor, warehouse storage, and loading docks.
For public notice purposes, the following description has been prepared for issue.
“Comfort Research Tremonton facility manufactures assorted brands of bean bag products for major US
retailers from this facility. Imported and domestically produced covers are filled with expanded polystyrene
beans. These beans will be a result of expanding polystyrene foam using imbedded pentane within the
beans as the expanding agent. The facility may operate 2 shifts a day, 5.5 days a week.”
Located in Box Elder County at 350 W 1000 North, Tremonton, Utah, the Universal Transverse Mercator
(UTM) coordinates are UTME 402470 and UTMN 4620169, UTM Zone 12, UTM Datum: NAD27. The site
map of the facility is found in Appendix A. The Box Elder County airshed is classified as Serious Non-
Attainment for PM2.5.

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PROCESS INFORMATION
3. PROCESS INFORMATION
Comfort Research operates three production lines: EPS Line, Bean Bag Line, and Bean Packaging Line.
The Bead Line provides the equipment to process the raw material, expandable polystyrene (EPS) beads
that will feed the other two processing lines. EPS undergoes two expansion processes prior to filling the
shells. The Hirsch PX-18000 (Hirsch) is the expander unit that inflates the EPS beads to their final size.
Inflation of the bead is accomplished by blowing steam from a 6.28 MMBtu/hr steam boiler, across the
beads in a steam chamber. The heating of the pentane within the bead causes the pentane to expand,
increasing the volume of the bead. The Hirsch operates with a stack exit velocity of 26.5 feet per second
or a rate of 4,200 dry standard cubic feet per minute.
In the expansion unit, the beads are exposed to steam, then moved to the fluidized bed section of the
Hirsch unit for partial drying, and transferred to their dedicated holding tents. This operation is considered
a batch process since only one mode can be accommodated at any given time inside the Hirsch. The
Hirsch is rated at 5,000 pounds per hour (lbs/hr) of raw material input, but the other constraints of the
processing, such as second passes, bagging, and sewing, cannot handle that rate or volume. The other
two lines are for filling the shells, sewing, and packaging. See Appendix B for the Process Flow Diagram
(PDF) of the Hirsch process. Note that the Bean Bag Line, and the Bean Packaging Line have no or
negligible emissions. The EPS, bean bag, and packaging line Process Flow Diagrams are shown in
Appendix B, as well.
3.1 OPERATION SCHEDULES
The facility operations operate at a maximum of two (2) 8-hour shifts per day, 5.5 days per week, 51
weeks per year (4,488 hours/year). Actual operations schedules are dependent on market demands.
Comfort Research has reviewed production from their other facilities that have identical processes
apparatuses (i.e., PX-18000) and use the same EPS beads. Comfort Research is requesting an
operational limit be applied to this facility to ensure they are below the Major Source thresholds for VOCs.
Since the concentration of the beads remains fairly constant, Comfort Research is requesting a tonnage
limit based on the operational schedule identified as opposed to a time-based operational limit. Comfort
Research requests an operational limit maximum of 2.25 million pounds per year (1,125 [tons per year])
of raw material bead input, with an anticipated annual average usage of 500 lbs/hr or less. A rolling 12-
month average of raw material (EPS) input will be kept for monitoring and recordkeeping purposes.
In regard to annual demands, the fourth quarter tends to be the highest given the holiday season.
Comfort Research’s other facilities have shown the following:
 1st Quarter = 20-22 percent
 2nd Quarter = 22-24 percent
 3rd Quarter = 18-20 percent
 4th Quarter = 32-34 percent

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EMISSION RELATED INFORMATION
4. EMISSION RELATED INFORMATION
Criteria, hazardous air pollutants (HAP), and greenhouse gas (GHG) emissions for the proposed facility
are found in Appendix C. The United States Environmental Protection Agency (USEPA) 450/3-90-020
Control of VOC Emissions from Polystyrene Foam Manufacturing document provides values for off-
gassing of pentane during the manufacturing and storage process. Note that based on the EPA
document, 15% of the pentane is retained in the final product. However, for purposes of this application,
Comfort Research has elected to consider the retained percentage as fugitive emissions. Appendix C
shows the pentane, from expansion and off-gassing, is segregated into stack emissions and fugitive
emissions based on this document.
The emissions are based on the proposed operational limit of 1,125 tpy of EPS beads and the boiler
operating 4,488 hours per year. The estimated PTE emissions without controls are as follows:
Table 4-1 Summary of Emissions

Previous
Potential
Emissions
Proposed
Potential
Emissions
Increased
Potential
Emissions
Pollutant (Tons/Yr) (Tons/Yr) (Tons/Yr)
NOx 0.69 1.38 0.69
SO2 0.00 0.01 <0.005
PM10 0.06 0.13 0.06
PM2.5 0.06 0.13 0.06
Condensable PM 0.04 0.08 0.04
CO 0.58 1.16 0.58
VOC Stack 22.07 27.03 4.97
VOC Fugtive 34.88 41.85 6.98
Total VOC (stack +fugitive) 56.94 68.88 11.94
Major HAPs Lbs/yr
Lead 0.007 0.014 0.07
Hexane 24.87 49.74 24.87
Total HAPs (incl. Hexane) 26.09 52.18 26.09

Greenhouse Gases (GHG)
Previous
Potential
Emissions
(Tons/Yr)
Proposed
Potential
Emissions
(Tons/Yr)
Increased
Potential
Emissions
(Tons/Yr)
CO2 824.01 1648.02 824.01
CH4 0.015 0.03 0.15
N2O 0.0015 0.003 0.0015
Total CO2e= 1650

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EMISSION RELATED INFORMATION
Fugitive emissions of VOCs are from the first and second holding of the processed beads in porous tents.
Additional fugitives are emitted during storage of the beads. Emissions per emission unit are found on the
individual UDAQ forms found in Appendix D. The forms in Appendix D include Form 2, 4, and 5.
4.1 Offset Applicability
The Comfort Research facility is located in Box Elder County, which is NAA for PM2.5. However, the
requirement for Minor Source Offsets of PM10 and Ozone precursors does not apply as the source
should not impact Davis or Salt Lake Counties. Regardless, the requested increase over the current AO
is less than 25 tons per year, so VOC offsets are not required. Similarly, increases in NOx, SO2, and
PM10 combined are less than 25 tons per year.

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REGULATORY REVIEW
5. REGULATORY REVIEW
5.1 Federal
As this facility is located in Box Elder County, the Serious Non-Attainment requirements are applicable.
By definition, this is a “Synthetic Minor” Source with all criteria pollutants being under the Major Source
thresholds by agreement to limit production with operational constraints.

Not Applicable – Subpart JJJJJ – National Emission Standards for Hazardous Air Pollutants for Area
Sources: Industrial, Commercial, and Institutional Boilers – does not apply to gas fired steam boilers.
5.2 State
Minor Sources in Utah are subject to the rules and Air Quality Regulations R307. These include Minor
Source New Source Review (NSR) and the associated Minor Source Best Available Control Technology
(BACT).
2014 PM2.5 SIP
R307-101-2 Minor Source
R307-107 Breakdowns
R307-150 Series – Inventories, Testing, and Monitoring
R307-401 Future Modifications
R307-401-4 General Requirements; Startup, Shutdowns, and Maintenance
R307-401-5 Notice of Intent
R307-401-6 Review Period, Completeness Determination
R307-401-7 Public Notice
R307-401-8 Approval Orders; Recordkeeping shall be kept for a minimum of 2 years; Visible emissions
shall not exceed values
R307-401-8 Non-HAP VOCs; 12-Month Rolling Average; Records of Consumption
R307-401-12 Reduction in Air Pollutants
R307-401-18 Review 18 months
R307-401-19 Approval Order (inclusive)
R307-401-8 Determination of mass emission rates, stack testing method
R307-401-8 Stack testing once every 5 years
R307-401-8 Owner/operator shall use only natural gas as fuel
The facility is subject to the rules and controls of the 2014 PM2.5 SIP plan based on the location and the
emission of VOCs as a precursor to PM2.5.

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5.3 Non-Attainment New Source Review
Comfort Research is located in Tremonton, Utah, which is located within Box Elder County. Box Elder is a
NAA area for PM2.5. As the source is not a non-attainment major source, no offsets are required.
Because this is deemed a Minor Source and the emissions for pollutants are below the threshold values,
PM10 and/or ozone offsets are not required under R307-403-5 and/or R307-403-6.
5.4 Modeling/Emission Impact Analysis
UDAQ Air Quality Regulations R307-410-4 provide emission thresholds above which dispersion modeling
of criteria pollutants is required if the source is located within an attainment area. Because this facility is
located in a NAA zone, air dispersion modeling is usually not required.
5.5 Best Available Control Technology (BACT) Analysis
There are two emission units that require BACT analyses: the Hirsch expander unit and the 6.28
MMBtu/hr steam boiler. The following section explains why best operating practices (or no control)
selected should be considered BACT.
BACT means an emission limitation and controls that include design, equipment, work practice, operation
standard, or combination thereof, based on a maximum degree of reduction of each pollutant subject to
regulation under the Utah Air Conservation Act emitted from any emitting unit. BACT is reviewed by
UDAQ on a case-by-case basis taking into account energy, environmental and economic impacts, and
other cost. The results of the analyses determine if it is feasible and achievable. Based on the proposed
BACT, the most effective engineering techniques and control equipment are used to minimize emission of
air contaminants into the outside environment from its process. The following four criteria should be used
when analyzing strategies to achieve BACT.
1. Energy
2. Environmental impacts
3. Economic impacts
4. Other considerations
5.5.1 BACT Query
EPA’s RACT/BACT/LEAR Clearinghouse (RBLC) was queried for EPS production, pentane and for
facilities that operate under similar SIC codes. One result was obtained from the RBLC for EPS
production and the control of VOCs. Regenerative Thermal Oxidizer (RTO) is considered BACT with
0.002 pounds of VOCs per ton of EPS or 98 percent control.

RBLC ID: IN-0238 03/03/2015
Corporate/Company: CARPENTER COMPANY
Facility Name: CARPENTER COMPANY
Facility Description: A POLYURETHANE AND POLYSTYRENE FOAM PRODUCTION SOURCE
PROCESS NAME: EXPANDED POLYSTYRENE (EPS) FOAM MANUFACTURING LINE

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REGULATORY REVIEW
Process Type: 99.014 (Polystyrene Foam Products Manufacturing)
Primary Fuel: NATURAL GAS
Throughput: 12.25 MMBTU/H
Process Notes:

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC
Test Method: Unspecified
Pollutant Group(s): Volatile Organic Compounds (VOC)
Emission Limit 1: 0.0020 LB/T 3-HOUR ROLLING AVERAGE
Emission Limit 2: 0.0030 LB/T
Standard Emission:
Did factors, other than air pollution technology considerations influence the BACT decisions:
Unknown
Case-by-Case Basis: N/A
Control Method: (A) REGENERATIVE THERMAL OXIDIZER (RTO)
Est. % Efficiency: 98.000
Cost Effectiveness: 0 $/ton
Incremental Cost
Effectiveness:
0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance
Notes:
THIRD LIMIT: 0.016 POUNDS PER TON STATE BACT
No other BACT was listed in the RBLC, but VOCs are often controlled using several technologies besides RTO.

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5.5.2 Evaluation of Hirsch Expander
Three control technologies were considered for controlling pentane emissions from this operation: carbon
adsorption, thermal incineration, and regenerative thermal oxidation (RTO).
Carbon Adsorption is often used for the control of certain types of volatiles. VOCs are trapped on the
surface of granulated activated carbon physically or by chemical reactions with carbon. Capital cost of
both fixed bed and disposable carbon canisters tend to be higher than RTO due to shipping cost,
bed/canister replacement, and disposal. Carbon adsorption systems depend on process variables such
as adsorption time, volumetric flow rate, pressure drop, carbon capacity, and inlet and outlet contaminant
concentrations. The control of VOC emissions typically reduces the concentrations from between 400 to
2,000 parts per million (ppm) to under 50 ppm. At the lower end of this range, VOCs may be difficult or
uneconomical to control.
The lower explosive limit (LEL) of pentane is 1.4%, or 14,000 ppm. However, insurance providers typically
limit the concentration of explosive gases to 25% of the LEL, or approximately 3,500 ppm for pentane.
The estimated concentration based on 25.65 tons/yr of pentane from the 1st and 2nd stage bead
expansion (represents 38% of pentane captured from expander, 62% is fugitive), an expander exhaust
flow rate of 4,200 dscfm, and assuming 4,488 hours of operation per year would be 242 ppm.
Moisture will be approximately 12 percent, which will also impede the effectiveness of carbon adsorption.
The other consideration on carbon adsorption is that this is an exothermic reaction. Heat will build up
within the carbon beds and the possibility of bed fires is a safety concern.
However, the main argument against the use of activated carbon is the high cost of shipping the new and
spent carbon, making its use prohibitive. Given the high cost, the generation of additional waste, unknown
effectiveness with pentane only, high moisture, and safety concerns, this technology does not appear
applicable to control pentane emissions.
Thermal Incineration is often used to control VOC emissions from gas emission sources. A conventional
thermal incinerator was sized based on the concentration of pentane emissions and flow rate from the
Hirsch. The effectiveness of destroying pentane-only emissions is unknown at this time, but an estimate
of 98 percent effectiveness appears plausible. The heat value of the exhaust from the expander is rather
low, and based on cost estimation design results, the auxiliary fuel requirement for a conventional TO will
be at least 47.4 cfm of natural gas. The additional emissions from this natural gas combustion would add
NOx, and particulate matter which may be more harmful than the uncontrolled VOC. However the cost to
operate the conventional TO would exceed $10,735 per ton of VOC controlled and is therefore cost
prohibitive. An RTO was also evaluated and was also found to be cost prohibitive.
Other Considerations: While the EPS is stable under standard conditions, the steam expansion process
provides for a more unstable state. Having an incinerator on site and the associated flame/combustion
may create safety concerns as far as fire and explosions. The applicability of using a thermal incinerator
has not been proved to be effective on pentane. More engineering and beta testing is needed to
determine if this is a viable technology to control pentane emissions. Either structural improvements will
be required to mount this control unit on the existing roof or extensive duct work will be required with
additional blowers if it is installed next to the building.
Regenerative Thermal Oxidizers (RTOs) are listed under the RBLC as BACT for EPS emission controls.
RTOs are used for the treatment to exhaust air. A bed of material is used to absorb VOCs from the
exhaust stack. They are suited for low VOC concentrations with high waste stream flow rates. The media
used in the bed varies depending on the type or collection of VOCs to be oxidized. Estimates were made
using this technology for the Hirsch operations, although not all the parameters were available to
determine specifics in the operating system.

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Other Considerations: The section occupied by Comfort Research in this 675,000 sf building is located
near the center. Mounting a RTO will require either a large crane or a helicopter drop. Emissions from
construction were not calculated in this evaluation. If the RTO is roof-mounted, extensive structural
improvements will be required. If this unit is mounted next to the building, extensive duct work and
additional blowers and ongoing flow balancing will be needed for efficient and effective operation.
See Appendix E for the benefit cost analysis of using this technology.
5.5.3 Ranking of EPS Control Technologies
RTO is the only documented technology that has been used to control pentane emissions. Several
commercial packages are available for flow rates and emission concentrations proposed for this facility.
Associated costs include the complexity of mounting this unit on the roof of the existing building, structural
additions needed to support a roof-mounted unit, and change out logistics for the ceramic beds. The RTO
will require electrical and natural gas power; additional labor to operate, maintain, and monitor the
system; and safety controls to prevent fire and or explosions.
Thermal incineration could be a viable option, but additional engineering, design, testing, and evaluation
will be required before effective control of emissions is achieved. While this unit does not require
electricity, monitoring equipment may require electrical power on the roof. This control technology has
more open flame than RTO units, which may increase the risk of fire or explosion.
Carbon adsorption also has applicability issues; this technology is not listed in the RBLC database and
reduces emissions with less efficiency than RTO or thermal incineration controls, as well as cost and the
generation of additional pollutants and operational costs.
RTO and thermal incineration cost analyses were performed and are documented in Appendix E. Both
control technologies will increase criteria and GHG pollutant emissions. Significant amounts of natural
gas will be wasted if these technologies are required and an economic burden on this new facility will be
created. In addition, fire and explosion potential will increase with the energy used in these control
systems. As documented in Health and Safety Executive (HSE) Health and Safety Executive bulletin, Fire
and explosion risks from pentane in expandable polystyrene (EPS), September 1998 (see
http://www.hse.gov.uk/pubns/ppis1.pdf), the risks are significant if additional heat sources are present.
Comfort Research concludes that best management practices (BMPs) should be considered BACT.
Storage of pre- and post-expanded EPS should be conducted in a cool area with the industry
recommended low ventilation. The steam boiler should be run efficiently with natural gas as a fuel source.
Limits on raw material storage volumes, throughput, hours of production, and packaged storage time
should be considered BACT.
5.6 Small Steam Boiler RACT/BACT LEAR
Several listings were found for small steam boilers that have performed BACT. The unit being evaluated
is smaller and produces less than any cited in the RBLC database. From the RBLC listings, the
combustion of clean fuels, proper burner design, and energy efficiency appears to be considered BACT
for small boilers.

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PROCESS NAME: Steam boiler #1
Process Type: 11.390 (Other Gaseous Fuel & Gaseous Fuel Mixtures)
Primary Fuel: Refinery fuel gas
Throughput: 22.00 MMBTU/H
Process Notes:

POLLUTANT NAME: Carbon Dioxide Equivalent (CO2e)

CAS Number: CO2e
Test Method: Unspecified
Pollutant Group(s): Greenhouse Gasses (GHG)
Emission Limit 1: 12587.0000 TONS/YEAR 12-MONTH ROLLING SUM BASIS

Did factors, other than air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable
Requirements:

Control Method: (P) Combustion of clean fuels and energy efficiency
Est. % Efficiency:

Cost Effectiveness: 0 $/ton
Incremental Cost
Effectiveness:
0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance
Notes:

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PROCESS NAME: Steam boiler #2
Process Type: 11.390 (Other Gaseous Fuel & Gaseous Fuel Mixtures)
Primary Fuel: Refinery fuel gas
Throughput: 22.00 MMBTU/H
Process Notes:

POLLUTANT NAME: Carbon Dioxide Equivalent (CO2e)

CAS Number: CO2e
Test Method: Unspecified
Pollutant Group(s): Greenhouse Gasses (GHG)
Emission Limit 1: 12587.0000 TONS/YEAR 12-MONTH ROLLING SUM BASIS
Emission Limit 2:
Standard Emission:
Did factors, other than air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable
Requirements:

Control Method: (P) Combustion of clean fuels and energy efficiency
Est. % Efficiency:

Cost Effectiveness: 0 $/ton
Incremental Cost
Effectiveness:
0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance
Notes:

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PROCESS NAME: Steam Boiler
Process Type: 13.310 (Natural Gas [includes propane and liquefied petroleum gas])
Primary Fuel: Natural Gas
Throughput: 65.00 MMBtu/H
Process Notes: Natural Gas-fired steam boiler to vacuum tank degasser

POLLUTANT NAME: Carbon Monoxide

CAS Number: 630-08-0
Test Method: EPA/OAR Method 10
Pollutant Group(s): In Organic Compounds
Emission Limit 1: 0.0400 LB/MMBTU
Emission Limit 2: 11.4000 T/YR
Standard Emission:
Did factors, other than air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable
Requirements:
OPERATING PERMIT
Control Method: (P) Proper burner design and good combustion practices
Est. % Efficiency:

Cost Effectiveness: 0 $/ton
Incremental Cost
Effectiveness:
0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance
Notes:
Method 10 or 10B if required
POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC

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Test Method: Unspecified
Pollutant Group(s): Volatile Organic Compounds (VOC)
Emission Limit 1: 0.3500 LB/H
Emission Limit 2: 1.5200 T/YR
Standard Emission:
Did factors, other than air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable
Requirements:
OPERATING PERMIT
Control Method: (P) Proper burner design and good combustion practices
Est. % Efficiency:

Cost Effectiveness: 0 $/ton
Incremental Cost
Effectiveness:
0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance
Notes:
Short-term limit based on AP-42 Table 1.4-2, emission factor of 5.5 LB/MMSCF.
No testing is required

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: EPA/OAR Method 7
Pollutant Group(s): InOrganic Compounds , Oxides of Nitrogen (NOx), Particulate Matter (PM)
Emission Limit 1: 0.0700 LB/MMBTU
Emission Limit 2:
Standard Emission:
Did factors, other than air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: N/A

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Other Applicable
Requirements:
OPERATING PERMIT
Control Method: (N)
Est. % Efficiency:

Cost Effectiveness: 0 $/ton
Incremental Cost
Effectiveness:
0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance
Notes:
Method 7 or 7E. No ton per year limit in permit.
POLLUTANT NAME: Particulate matter, total < 10 µ (TPM10)

CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): Particulate Matter (PM)
Emission Limit 1: 0.4800 LB/H
Emission Limit 2: 2.1000 T/YR
Standard Emission:
Did factors, other than air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: N/A
Other Applicable
Requirements:
OPERATING PERMIT
Control Method: (N)
Est. % Efficiency:

Cost Effectiveness: 0 $/ton
Incremental Cost
Effectiveness:
0 $/ton
Compliance Verified: Unknown

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Pollutant/Compliance
Notes:
Short-term limit based on AP-42 Table 1.4-2 using emission factor of 7.6
LB/MMSCF. No testing required.

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE
Test Method: EPA/OAR Method 9
Pollutant Group(s):

Emission Limit 1: 20.0000 % OPACITY AS A 6-MINUTE AV
Emission Limit 2:
Standard Emission:
Did factors, other than air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: N/A
Other Applicable
Requirements:
OPERATING PERMIT
Control Method: (N)
Est. % Efficiency:

Cost Effectiveness: 0 $/ton
Incremental Cost
Effectiveness:
0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance
Notes:
Method 9 if required.

5.6.1 Ranking of Boiler Control Technologies
The BACT analysis of the steam boiler was performed using Low-NOx and Ultra Low-NOx burners in
place of older existing burners with emission rates assumed to be predicted by the AP-42 natural gas
combustion factors. A cost analysis was performed using the provided concentrations that could be
obtained after conversion and the cost quoted by Cleaver Brooks. As shown in Appendix E, the cost to
control is prohibitive based on the dollars per ton removed. The Appendix E calculations documents these
costs for lowering the NOx emission rate to 60 ppm and 30 ppm.

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NOTICE OF INTENT FOR PERMIT MODIFICATION
Comfort Research
REGULATORY REVIEW
5.7 Cost Analyses
The cost calculation for BACT is performed to evaluate the cost of the equipment per removed ton of
pollutant. The evaluation used standard USEPA Office of Air Quality Planning and Standards CO$T-AIR
Control Cost Spreadsheet, Estimating Costs of Air Pollution Control; RS Means Cost Data: 2015, vendor
information and pricing provided by Questar and Rocky Mountain Power. See the BACT Appendix for the
entire costing spreadsheets. UDAQ guidance document and equations were used to determine the cost
of implementing BACT both for the Hirsch and the steam boiler. As documented for the cost analysis, the
following equation and definitions were used to determine the cost to implement and operate these
control technologies.
A = (B + C)/D
A = Annualized cost expressed in dollars per ton of pollutant removed
B = Annualized equipment cost in $/yr = PV{i / [1 - (1 + i) -n]}
Where:
PV = Present day value of the equipment or the cost of the equipment today
i = Interest rate at which the company can borrow money. Ten percent should be entered into the
equation as 0.10; 5 percent as 0.05
n = Number of years of the life of the equipment
C = Annual operating cost is the sum of the cost for spare parts, power, labor, maintenance, etc., less the
value for the amount of reclaimed product or by product recovered and used or sold
D = The amount of emission reduction due to the installation and operation of the pollution control
equipment in tons/year

Table 5-1 BACT Cost Comparisons

Unit Control A
($/Lbs)
D
(ton
removed)
6.28 MMBtu Steam
Boiler
Low NOx
(60 ppm)
$104.6K 0.25
6.28 MMBtu Steam
Boiler
Ultra-Low NOx
(30 ppm)
$35.3 0.82
Hirsch PX 18000 Thermal Oxidizer
(RTO)
$ 10.2K 26.17
Hirsch PX 18000 Thermal
Incinerator
$11.8K 25.14

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APPENDIX A SITE MAP

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APPENDIX B PROCESS FLOW DIAGRAMS

Facility:  Comfort Research  
Production Line:Bead Line (Line 1)
Production Line:Bean Bags Line (Line 2)
Production Line:Bean Line (Line 3)
Rice Delivered
to Expander
First Pass
Expansion to
First Pass
Tents to
Second Pass
Expansion to
Inspection
Point
Second Pass
Tents to Filling
Make Bean
Bag
Inspection
Point
Package Bean
Bag
Finished
Goods
Foam to Line
Label Hang
Tag
Assemble
Chair Packaging Finished
Goods
Inspection
Document
Inspection
Document
Second Pass
Tents to
Third Pass
Expansion to

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APPENDIX C FACILITY EMISSIONS

Comfort Research
Emission Summary Tremonton Site
Emissions Emissions
Pollutant (Lbs/hr)(Tons/yr)
NOx 0.62 1.38
SO2 0.00 0.01
PM10 0.06 0.13
PM2.5 0.06 0.13
Condensable PM 0.04 0.08
CO 0.52 1.16
VOC Stack 41.66 27.03
VOC Fugtive 66.96 41.85
Total VOC (stack +fugitive)108.62 68.88
Major HAPs Lbs/yr
Lead 0.00 0.01
Hexane 0.01 49.74
Total HAPs (incl. Hexane)0.01 52.18
Greenhouse Gases (GHG)
Emissions
(tons/yr)
CO2e
Emission
Potential
(tons/yr)
CO2 1,648.02 1,648.02
CH4 0.03 7.76E-01
N2O 0.003 9.26E-01
Total =1650
04 12 21 Comfort Calculations 2021 NOI_swm.xlsx Summary Page 1 of 1
Comfort Research
Tremonton Site
Emission Source: EPS Bead Processing
Raw Material Input Rate
Operating Schedule:16 hrs/day 5.5 days/week 51 weeks/yr 4488 hr/yr
Mass
(beads)Units Duration
Bead
Throughput Units
Maximum Hourly Usage:1800 lb/hr @
Average Usage:500 lb/hr @ 4488 2,244,000 lb/yr
Proposed Annual Limit:Proposed Annual Limit =2,250,000 lbs/yr
Pentane Content (EPS RAPAC )
Maximum (Lbs/hr)
VOC Content2 =6.0%
VOC Emissions:(Lbs/hr) MAX 108.00 Lbs/hr @ 1800 lbs/hr
VOC Emissions:(Lbs/yr)MAX 135,000 Lbs/yr @2.25M Lbs/yr
VOC Emissions:(tpy)MAX 67.50 tpy
VOC Emission Distribution1
Distribution Total Captured Total Fugitive3
/ Rate 24%(Captured)19%(Fugitives)14%(Captured)15%(Fugitives)13%(fugitives)38%62%
Max (Lbs/hr)25.92 20.52 15.12 16.20 14.04 41.04 66.96
Max (tpy)16.20 12.83 9.45 10.13 8.78 25.65 41.85
1. Table 5-1 - Pentane Loss Analysis for EPS Bead Products, Control of VOC Emissions from Polystrene Foam Manufacturing, EPA-450/3-90-020, September 1990, EPA Contract 68-02-4378
2. VOC Content listed on SDS (REPAC SDS)
Hirsch PX-18000 Expander Raw Material Input Rate:
3. For purposes of this application, Comfort Research has chosen to included the 15% of Pentane retained in the product at shipping in the Total Fugitive lost.
% Loss Expander 1st Holding Time Loss During 2nd Expansion % Loss 24 hours % Loss 24-48 hours
04 12 21 Comfort Calculations 2021 NOI_swm.xlsx Hirsch Emissions Page 1 of 1
Comfort Research
Comfort Research
Emission Source:Natural Gas Steam Boiler CB200-150
Operating Parameters 150 psi
Maximum Heat Input
Capacity *6.28 MMBtu/hr
Operating Hours 4,488 hr/yr
Natural Gas 1020 MMbtu/ 106scf
Maximum N.G. Usage 6157 scf/hr
* Nameplate rating
Natural Gas Natural Gas
Pollutant lb/106scf lb/MMbtu
NOx 100 0.0980
SO2 0.6 0.0006
PM10T 7.6 0.0075
PM2.5T 7.6 0.0075
CO 84 0.0824
VOC 5.5 0.0054
Lead 0.0005 0.0000
Hexane 1.8 0.0018
Total HAPs (incl. Hexane)1.888 0.0019
Greenhouse Gases (GHG)
Natural Gas
(kg/MMBtu)
Natural Gas
lb/MMBtu
Global Warming
Potential (GWP)
CO2 53.06 116.94 1
CH4 1.0E-03 2.20E-03 25
N2O 1.0E-04 2.20E-04 298
Emission Factors for Natural Gas1,2
04 12 21 Comfort Calculations 2021 NOI_swm.xlsx Boiler Emissions Page 1 of 2
Comfort Research
Comfort Research
Emission Source:Natural Gas Steam Boiler CB200-150
Pollutant
Emission
Factor
(lb/MMbtu)
Max. Annual
Operating Rate
(MMBtu/yr)
Potential Hourly
Emissions
(lb/hr)
Potential Annual
Emissions
(ton/yr)
NOx 0.0980 28,185 0.62 1.38
SO2 0.0006 28,185 0.00 0.01
PM10F 0.0019 28,185 0.01 0.03
PM2.5F 0.0019 28,185 0.01 0.03
PM10T 0.0075 28,185 0.05 0.11
PM2.5T 0.0075 28,185 0.05 0.11
CO 0.0824 28,185 0.52 1.16
VOC 0.0054 28,185 0.03 0.08
Lead 0.0000 28,185 3.08E-06 6.91E-06
Hexane 0.0018 28,185 0.01 0.02
Total HAPs 0.0019 28,185 0.01 0.03
CO2 116.94 28,185 734.41 1,648.02
CH4 2.20E-03 28,185 0.01 0.031
N2O 2.20E-04 28,185 0.001 0.003
CO2e3 -28,185 735 1,649.72
Low NOx (lbs/hr)
Low NOX
(tpy)
Ultra Low Nox
(Lbs/hr)
Ultra Low NOx
(tpy)
0.50 1.127 0.251 0.564
Reduction =0.25 0.82
Notes:
GWPs per 40 CFR 98, Table A-1 [CO2 = 1, CH4 = 25, N2O = 298].
3. CO2 Equivalent (CO2e) lb/hr, ton/yr = CO2 + [GWPCH4 * CH4)] + [GWPN2O * N2O].
Maximum Potential Emissions
1. Natural Gas emission factors per AP-42 Table 1.4-1, 1.4-2, and 1.4-3 for criteria pollutants and total HAPs. GHG
emission factors per 40 CFR Part 98, Tables C-1 and C-2.
2. PM10T and PM2.5T emission factors include filterable and condensable particulate matter (e.g., Total PM10, PM2.5).
04 12 21 Comfort Calculations 2021 NOI_swm.xlsx Boiler Emissions Page 2 of 2
Form 5 Equivalent
Pollutants
Permitted
Emissions
PTE 1
(tpy)
Proposed
Future
Potentials
Emissions
(tpy)
Proposed
Change PTE
(tpy)
NOx 0.691 1.380 0.689
SO2 0.0041 0.0083 0.0041
PM10 0.066 0.131 0.066
PM2.5 0.066 0.131 0.066
Condensable
PM 0.039 0.079 0.039
CO 0.580 1.161 0.580
VOC Stack 22.066 27.032 4.966
VOC Fugtive 34.875 41.850 6.975
VOC Total 56.941 68.882 11.941
HAPs lb/yr lb/yr lb/yr
Lead 0.007 0.014 0.007
Hexane 24.87 49.74 24.87
Total HAPs
(incl. Hexane)26.09 52.18 26.09
GHGs tons/yr tons/yr tons/yr
CO2 e 824.86 1649.72 824.86
Criteria Pollutants
1.Permitted Emissions (PTE) as contained in 2017
application and as reflected in State of Utah, Approval
Order Number DAQE-AN157350001-17, June 20, 2017.
Comfort Research
04 12 21 Comfort Calculations 2021 NOI_swm.xlsx Form 5 Page 1 of 1
Offset Applicability
Pollutants New Emissions (tpy)
Major Modification
Thresholds (tpy)
PM2.5 SIP Offset
Thresholds1 (tpy)
NOx 0.57 40 40
SO2 0.00 40 40
PM10 0.05 15
PM2.5 0.05 10
Condensab
le PM 0.03
CO 0.47 100
Total VOC 11.82 40 40
HAPs
Lead 0.00 0.60
Hexane 0.01
Total HAPs (incl. Hexane)
GHGs
CO2 e 675 75000
Criteria Pollutants
1 UDAQ Guidance for PM2.5 Emission Reduction Credit (ERC) Banking and Offsetting Requirements
Comfort Research
04 12 21 Comfort Calculations 2021 NOI_swm.xlsx Form 5 Page 1 of 1
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APPENDIX D UDAQ FORMS
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________

Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2. Name of process to be modified/added:
_______________________________

End product of this process:

_______________________________

3. Permit Change Type: New Increase*

Equipment

Process

Condition Change ____________________

Other ______________________________

Other ______________________________

Other ______________________________

4. Does new emission unit affect existing
permitted process limits?

Yes No
5. Condition(s) Changing:

6. Description of Permit/Process Change**

7. New or modified materials and quantities used in process. **
Material Quantity Annually

8. New or modified process emitting units **

Emitting Unit(s)

Capacity(s)

Manufacture Date(s)

*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.

Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed

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APPENDIX E BACT CALCULATIONS

Comfort Research
Table E-1 BACT TI-1 EPS - TO Control Evaluation
TOTAL ANNUAL COST SPREADSHEET PROGRAM--THERMAL INCINERATORS
COST BASE DATE: 2021
Unit TCI 60 100.0 2nd Quarter 2017 [3]
INPUT PARAMETERS
-- Gas flowrate (scfm): 4200 Exhaust
-- Reference temperature (oF): 95 Ambient
-- Inlet gas temperature (oF): 100 Process
-- Inlet gas density (lb/scf): 0.0715 Calculated
-- Primary heat recovery (fraction): 0.70 Default for TO
-- Waste gas heat content (BTU/scf): 0.52 Based on (lb/hr): 11.43
-- Waste gas heat content (BTU/lb): 7.29 Calculated
-- Gas heat capacity (BTU/lb-oF): 0.255 Default
-- Combustion temperature (oF): 1500 Assumed
-- Preheat temperature (oF): 1080 Calculated
-- Fuel heat of combustion (BTU/lb): 21502 Methane
-- Fuel density (lb/ft3): 0.0408 Methane
DESIGN PARAMETERS
-- Auxiliary Fuel Requirement (lb/min): 1.934 Calculated
(scfm): 47.4 Calculated
-- Total Gas Flowrate (scfm): 4247 Calculated
CAPITAL COSTS
Equipment Costs ($):
-- Incinerator:
@ 0 % heat recovery: 0
@ 35 % heat recovery: 0
@ 50 % heat recovery: 0
@ 70 % heat recovery: 172,292
-- Other (auxiliary equipment, etc.): 0
Total Equipment Cost--base: 172,292
' ' ' --escalated: 215,502
Purchased Equipment Cost ($): 232,742
Total Capital Investment ($): 296,927 Added $6K monitoring equipment
========= ========= ===================== ============ ==================
ANNUAL COST INPUTS
Operating factor (hr/yr):4488 TO hr/yr
Operating labor rate ($/hr): 42.00 Operator wage
Maintenance labor rate ($/hr): 60.00 Maintenance wage
Operating labor factor (hr/sh): 0.5 Default
Maintenance labor factor (hr/sh): 0.75 Default
Electricity price ($/kwh): 0.12 RMP
Natural gas price ($/mscf): 9.12 Questar
Annual interest rate (fraction): 0.08 Default
Control system life (years): 12 Default
Capital recovery factor: 0.1327 Default
Taxes, insurance, admin. factor: 0.06 Default
Pressure drop (in. w.c.): 19.0 Default
04 15 21 App_FNL_BACT costs(rev2).xls TO
Page 1 of 2
Comfort Research
Table E-1 BACT TI-1 EPS - TO Control Evaluation
ANNUAL COSTS
Item Cost ($/yr) Wt. Factor W.F.(cond.)
----------------------------------------------------------------------------------------------------------------------
Operating labor 11,781 0.041 ----
Supervisory labor 1,767 0.006 ----
Maintenance labor 25,245 0.089 ----
Maintenance materials 25,245 0.089 ----
Natural gas 116,436 0.409 ----
Electricity 8,476 0.030 ----
Overhead 38,423 0.135 0.360
Taxes, insurance, administrative 17,816 0.063 ----
Capital recovery 39,401 0.138 0.201
----------------------------------------------------------------------------------------------------------------------
Total Annual Cost 284,589 1.000 1.000
[1] Original equipment costs reflect this date.
[2] Original equipment cost, purchased equipment cost
[3] Source: Chemical Engineering Magazine, February 2014.
Chemical Engineering Plant Cost Index (CEPCI)
04 15 21 App_FNL_BACT costs(rev2).xls TO
Page 2 of 2
Comfort Research
CAPITAL COST (Pollution Control Equipment) Unit Cost Basis Total ($)
Purchased Equipment:
Basic Equipment & Auxiliaries A= (1) $150,583
Instrumentation & Controls 0.10A (2) $15,058
Sales Taxes 0.05A (2) $7,529
Freight 0.05A (2) $7,529
Total Purchased Equipment Cost B = $180,700
Direct Installation Costs:
Foundations & Supports 0.08B (2) $14,456
Handling & Erection 0.14B (2) $25,298
Electrical 0.04B (2) $7,228
Piping 0.02B (2) $3,614
Insulation for Ductwork 0.01B (2) $1,807
Painting 0.01B (2) $1,807
Total Direct Installation Costs $54,210
Indirect Installation Costs:
Engineering 0.10B (2) $18,070
Construction & Field Expenses 0.05B (2) $9,035
Contractor Fees 0.10B (2) $18,070
TI Training 0.02B (3) $3,614
Start-up 0.05B (2) $9,035
Performance Test 0.11B (2) $19,877
Emissions Monitoring Equipment 0.01B (3) $6,600
Contingencies 0.03B (2) $5,421
Total Indirect Installation Costs $89,722
TOTAL CAPITAL COSTS: C = $324,632
ANNUAL OPERATION & MAINTENANCE
Operating Labor (1) $11,781
Supervisory Labor (15% of operating labor) (1) $1,767
Maintenance Labor (1) $25,245
Maintenance Materials (100% of maintenance labor) (1) $25,245
Natural Gas (1) $116,436
Electricity (1) $8,476
Overhead (1) $38,423
Taxes, Insurance, Administrative Costs (1) $17,816
TOTAL OPERATION AND MAINTENANCE COSTS $245,189
Capital Recovery System: 0.1327 Assumes 7% compound interest rate and system useful life of 12 years.
Capital Recovery System: $39,401
Amortized Annual Costs = Annual O & M Costs + System Capital Recovery
Amortized Annual Costs = $284,589
References:
(1) Factor based on USEPA Office of Air Quality Planning and Standards Cost Spreadsheets, posted on the Internet 7/99
(2) Factor based on USEPA Office of Air Quality Planning and Standards Control Cost Manual (EPA 453/B-96-001).
(3) Added an estimate of $6,000 for emissions monitoring equipment to indirect installation costs.
Note: USEPA OAQPS Cost Spreadsheets calculate Total Capital Investment for Thermal Incinerators.
Table E-1 BACT TI-1 EPS - TO Control Evaluation
04 15 21 App_FNL_BACT costs(rev2).xls TO $$Page 1 of 1
Comfort Research
CAPITAL COST (Pollution Control Equipment) Unit Cost Basis Total ($)
TOTAL CAPITAL COSTS:C = $324,632
ANNUAL OPERATION & MAINTENANCE
Operating Labor (1) $11,781
Supervisory Labor (15% of operating labor) (1) $1,767
Regulatory Reporting (2) $12,175
Maintenance Labor (1) $25,245
Maintenance Materials (100% of maintenance labor) (1) $25,245
Natural gas (1) $116,436
Electricity (1) $8,476
Overhead (1) $38,423
Taxes, Insurance, Administrative Costs (1) $17,816
TOTAL OPERATION AND MAINTENANCE COSTS $257,364
Capital Recovery System: 0.1327 Assumes 7% compound interest rate and system useful life of 12 years.
Total Capital Recovery System: $39,401
Amortized Annual Costs = Annual O & M Costs + System Capital Recovery
$296,764
67.5 tpy emissions of VOCs
Additional Tons VOC removed = 25.14 Based on 38% capture efficiency and 95% control
Cost Per Ton Removed = $11,806
References:
(1) Factor based on USEPA Office of Air Quality Planning and Standards CO$T-AIR Control Cost Spreadsheets, posted on the Clean Air Technology Center webpage 7/99.
(2) based on engineering judgment
Table E-1 BACT TI-1 EPS - TO Control Evaluation
04 15 21 App_FNL_BACT costs(rev2).xls TO 2 Page 1 of 1
Comfort Research
CAPITAL COST (Pollution Control Equipment) Unit Cost Basis Total ($)
TOTAL CAPITAL COSTS:C = $324,632
ANNUAL OPERATION & MAINTENANCE
Operating Labor (1) $11,781
Supervisory Labor (15% of operating labor) (1) $1,767
Regulatory Reporting (2) $12,175
Maintenance Labor (1) $25,245
Maintenance Materials (100% of maintenance labor) (1) $25,245
Natural gas (1) $116,436
Electricity (1) $8,476
Overhead (1) $38,423
Taxes, Insurance, Administrative Costs (1) $17,816
TOTAL OPERATION AND MAINTENANCE COSTS $257,364
Capital Recovery System: 0.1327 Assumes 7% compound interest rate and system useful life of 12 years.
Total Capital Recovery System: $39,401
Amortized Annual Costs = Annual O & M Costs + System Capital Recovery
$296,764
67.5 tpy emissions of VOCs
Additional Tons VOC removed = 25.14 Based on 38% capture efficiency and 95% control
Cost Per Ton Removed = $11,806
References:
(1) Factor based on USEPA Office of Air Quality Planning and Standards CO$T-AIR Control Cost Spreadsheets, posted on the Clean Air Technology Center webpage 7/99.
(2) based on engineering judgment
Table E-1 BACT TI-1 EPS - TO Control Evaluation
04 15 21 App_FNL_BACT costs(rev2).xls TO 2 Page 1 of 1
Comfort Research
CAPITAL COST (Pollution Control Equipment) Unit Cost Basis Total ($)
TOTAL CAPITAL COSTS:C = $324,632
ANNUAL OPERATION & MAINTENANCE
Operating Labor (1) $11,781
Supervisory Labor (15% of operating labor) (1) $1,767
Regulatory Reporting (2) $12,175
Maintenance Labor (1) $25,245
Maintenance Materials (100% of maintenance labor) (1) $25,245
Natural gas (1) $116,436
Electricity (1) $8,476
Overhead (1) $38,423
Taxes, Insurance, Administrative Costs (1) $17,816
TOTAL OPERATION AND MAINTENANCE COSTS $257,364
Capital Recovery System: 0.1327 Assumes 7% compound interest rate and system useful life of 12 years.
Total Capital Recovery System: $39,401
Amortized Annual Costs = Annual O & M Costs + System Capital Recovery
$296,764
67.5 tpy emissions of VOCs
Additional Tons VOC removed = 25.14 Based on 38% capture efficiency and 95% control
Cost Per Ton Removed = $11,806
References:
(1) Factor based on USEPA Office of Air Quality Planning and Standards CO$T-AIR Control Cost Spreadsheets, posted on the Clean Air Technology Center webpage 7/99.
(2) based on engineering judgment
Table E-1 BACT TI-1 EPS - TO Control Evaluation
04 15 21 App_FNL_BACT costs(rev2).xls TO 2 Page 1 of 1
Comfort Research
CAPITAL COST (Pollution Control Equipment) Unit Cost Basis Total ($)
TOTAL CAPITAL COSTS:C = $773,164
ANNUAL OPERATION & MAINTENANCE
Operating Labor (1) $11,781
Supervisory Labor (15% of operating labor) (1) $2,356
Maintenance Labor (1) $25,245
Maintenance Materials (100% of maintenance labor) (1) $25,245
Natural gas (1) $15,060
Electricity (1) $8,834
Regulatory Reporting (2) $12,175
Overhead (1) $38,776
Taxes, Insurance, Administrative Costs (1) $43,224
TOTAL OPERATION AND MAINTENANCE COSTS $182,697
Capital Recovery System: 0.1168 Assumes 7% compound interest rate and system useful life of 15 years.
Total Capital Recovery System: $84,163.83
Amortized Annual Costs = Annual O & M Costs + System Capital Recovery
Amortized Annual Costs = $266,860.87
67.5 tpy of emissions
Additional Tons VOC removed = 26.17 Based on 38% capture efficiency and 98% control
Cost Per Ton Removed = $10,196
References:
(1) Factor based on USEPA Office of Air Quality Planning and Standards CO$T-AIR Control Cost Spreadsheets, on the Clean Air Technology Center webpage 7/99.
Table E-2 RTO EPS Control Evaluation
04 15 21 App_FNL_BACT costs(rev2).xls RTO 2 (2) Page 1 of 1
Comfort Research
Table E-3 Boiler BACT Estimates

Low NOx Ultra Low Nox
A =104,614$              35,513$           
B =10,204$                10,651$           
C =15,950$                18,470$           
D =0.25 ton removed 0.82 ton removed
Direct Cost -Low
Nox
Ultra low NOx
Direct Cost
Capital Cost
Equipment*32,000$ 35,000$
Conversion Labor 30,000$ 30,000$
Facility Labor 3,780$ 3,780$
Shipping 2,700$ 2,700$
Total = 68,480$ 71,480$
Annual Cost
Replacement Parts 200$ 200$
O&M 9,450$ 9,450$
Increase Fuel 6,300$ 8,820$
NOx Boiler
Reduction (tpy)0.25 0.82
Cost Assumptions
Labor Cost $63 per hour
Electricity Costs $0.120 kWhr Provided by RMP
Natural Gas Costs $9.12 per MSCF Provided by Questar
Hours of Operation 4,488 hrs per year
Cost to Operate 150 Hp Steam boiler $280,906 per year
Cost to Operate 150 Hp Low NOx $250,618 per year
Engineering Costs 15% per hour Provided by vendor estimate
Overhead Costs 15% of direct installation total
Start up Costs 7.5% of direct installation total
Performance Costs 7.5% of direct installation total
Insurance 7%
Capital Recovery Factor - other2 0.14
Interest Rate 8%
Boiler Life 10
Other Control Equipment Life 10 years
Supervisor Labor 10% of Operational labor
Maintenance labor 15% of operation labor
Operation labor 120 hours per year
Operating Materials 32000 one time cost
FGR Fans 7000 one time cost
Operating Materials (ULNox) 35000 one time cost
04 15 21 App_FNL_BACT costs(rev2).xls revised Boiler Page 1 of 1

www.erm.com Version: 1.0 Project No.: 0592594 Client: Comfort Research 14 April 2021

APPENDIX F SPECIFICATION SHEETS/SAFETY DATA SHEETS

Product Name:STYROPEK P 240LN(800kg SS)
Article/Product #:5100822
Lot #:12Z26978G
Quantity / UOM:10,400 KG
Packing Type:super sack 800 Kg
Scheduled Delivery Date: 12.21.2020
Delivery:37194920
Styropek Order:5104926
Customer PO:18299-1-7
Test Description Test Code Result Unit
Pentane Content, % G.C.5.51 %
CERTIFICATE OF ANALYSIS
The Product listed below has met the manufacturing specifications and quality control
requirements of Styropek USA, INC.
Residual Styrene Monomer content less than 1,000 PPM.
The test data on this certificate has been generated, evaluated, and approved by the Quality
Assurance Department at the respective production facility.
Thank you for your interest in StyropekTM Expandable Polystyrene products. If you have any
questions regarding this document, please call your Styropek USA or Styropek Canada Sales
Representative.
StyropekTM Quality Assurance Department at (1) 832 446 6154.
StyropekTM Expandable Polystyrene Products.
StyropekTM is a registered trademark of Grupo Styropek S.A. de C.V.
Date:12.18.2020
Customer Name:COMFORT RESEARCH
Plant:Tremonton, UT
Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 1/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
1. Identification

Product identifier used on the label

STYROPEK® P40 Series

Recommended use of the chemical and restriction on use
Recommended use*: for industrial processing only; expanding-agent containing plastic for the
production of foam plastics

* The “Recommended use” identified for this product is provided solely to comply with a US Federal requirement and is not
part of the seller's published specification. The terms of this Safety Data Sheet (SDS) do not create or infer any warranty,
express or implied, including by incorporation into or reference in the seller's sales agreement.

Details of the supplier of the safety data sheet
Company:
Styropek México SA de CV
Fernando Montes de Oca 71
Col. Condesa, C.P. 06140,
Ciudad de México, México

Telephone: [phone]

Manufacturer / importer:

STYROPEK S.A. DE C.V.

Emergency telephone number

24 Hour Emergency Response Information
SETIQ Mexico 01 800 0021400
CHEMTREC: 01 800 424-9300
832-446-6154 (in USA)
Int.: [phone]

Altamira Plant (01833) 500 24 00 EXT: (3934), (3910)
Available 24 Hours

Other means of identification

Chemical name: Polystyrene
Commercial name: Styropek P40
Chemical family: Polymer
Synonyms: Expandable Polystyrene
__________________________________________________________

2. Hazards Identification

According to Regulation 2012 OSHA Hazard Communication Standard; 29 CFR Part 1910.1200

Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 2/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
Classification of the product

No need for classification according to GHS criteria for this product.

Label elements

Hazard Statement:
EUH018 In use may form flammable/explosive vapour-air mixture.

Precautionary Statement:
P210 Keep away from heat, hot surfaces, sparks, open flames and other
ignition sources. No smoking.
P233 Keep container tightly closed.
P243 Take precautionary measures against static discharge.
P403 + P235 Store in a well-ventilated place. Keep cool.

Hazards not otherwise classified

May cause some eye irritation which should cease after removal of the product.

Labeling of special preparations (GHS):
Product releases a flammable hydrocarbon.

According to Regulation 1994 OSHA Hazard Communication Standard; 29 CFR Part 1910.1200

Emergency overview

WARNING:
FLAMMABLE.
Releases flammable vapour.
MAY CAUSE EYE, SKIN AND RESPIRATORY TRACT IRRITATION.
PROLONGED OR REPEATED CONTACT MAY DRY SKIN AND CAUSE IRRITATION.
CONTAINS MATERIAL WHICH MAY CAUSE KIDNEY DAMAGE BASED ON ANIMAL DATA.
Eye wash fountains and safety showers must be easily accessible.
Use with local exhaust ventilation.
Avoid contact with the skin, eyes and clothing.
__________________________________________________________________

3. Composition / Information on Ingredients

Chemical Name: Polystyrene
Commercial Name: Styropek BF
Chemical Family: Polymer
Synonymous: Expandable Polystyrene

Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 3/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
According to Regulation 2012 OSHA Hazard Communication Standard; 29 CFR Part 1910.1200

CAS Number Un Number Content (W/W) Chemical name
78-78-4 1265 >= 0.3 - < 3.0 % isopentane
109-66-0 1265 >= 3.0 - < 5.0 % Pentane

According to Regulation 1994 OSHA Hazard Communication Standard; 29 CFR Part 1910.1200

CAS Number Un Number Content (W/W) Chemical name
9003-53-6 2211 > 90.0 % polystyrene
109-66-0 1265 > 3.0 - < 7.0 % Pentane
__________________________________________________________________

4. First-Aid Measures

Description of first aid measures

If on skin:
Wash affected areas thoroughly with soap and water. If irritation develops, seek medical attention.

If in eyes:
In case of contact with the eyes, rinse immediately for at least 15 minutes with plenty of water. If
irritation develops, seek medical attention.

If swallowed:
No hazards anticipated. Rinse mouth and then drink plenty of water. If difficulties occur: Obtain
medical attention.

Most important symptoms and effects, both acute and delayed

Symptoms: headache, dizziness, incoordination, dazed state, Eye irritation, skin irritation
Hazards: No hazards anticipated.

Indication of any immediate medical attention and special treatment needed

Note to physician
Treatment: Treat according to symptoms (decontamination, vital functions), no
known specific antidote.
_______________________________________________________________
5. Fire-Fighting Measures

Extinguishing media

Suitable extinguishing media:
water spray, foam, dry powder, carbon dioxide

Unsuitable extinguishing media for safety reasons:
water jet

Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 4/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
Special hazards arising from the substance or mixture
Hazards during fire-fighting:
carbon monoxide, carbon dioxide, Styrene, aliphatic hydrocarbons
The substances/groups of substances mentioned can be released in case of fire.

Advice for fire-fighters
Protective equipment for fire-fighting:
Wear self-contained breathing apparatus and chemical-protective clothing.
__________________________________________________________________
6. Accidental release measures
Further accidental release measures:
High risk of slipping due to leakage/spillage of product. Shut off or stop source of leak.
Substance/product can form explosive mixture with air.

Personal precautions, protective equipment and emergency procedures
Sources of ignition should be kept well clear. Ensure adequate ventilation. Note that this gas is
heavier than air and can spread along the ground in the direction of the wind. Beware of pits and
confined spaces. Use antistatic tools. Vapours are heavy and collect in low areas. Avoid al l sources
of ignition: heat, sparks, open flame.

Environmental precautions
Do not allow to enter drains or waterways. Discharge into the environment must be avoided.

Methods and material for containment and cleaning up
For small amounts: Sweep/shovel up. Pack in tightly closed containers for disposal.
For large amounts: Pick up with vacuum equipment approved for use in hazardous locations. Pack
in tightly closed containers for disposal.
Ensure adequate ventilation. Dispose of absorbed material in accordance with regulations. Avoid
raising dust.
__________________________________________________________________

7. Handling and Storage

Precautions for safe handling
Protection against fire and explosion:
The product is combustible. Vapours may form ignitable mixture with air. Keep away from heat.
Prevent electrostatic charge - sources of ignition should be kept well clear - fire extinguishers should
be kept handy. Avoid all sources of ignition: heat, sparks, open flame. Containers should be earthed
during decanting operations. It is recommended that all conductive parts of the machinery are
grounded. All parts of the plant and equipment should be electrically bonded together and grounded.
Electrical continuity should be checked at regular intervals. Higher line velocity can increase the build-
up of static electric charge. Avoid flammable gas mixtures. Ensure an efficient ventilation (at least
one air change per hour). Vapours are heavier than air and may accumulate in low areas and travel
a considerable distance up to the source of ignition. Because of danger of explosion, avoid vapours
reaching the cellar, sewage water and pits. Empty containers may contain flammable residue.

Conditions for safe storage, including any incompatibilities
Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 5/11
Version: 2.0 (2018-USA/ENG-P40V2.0)

Further information on storage conditions: Protect against heat. Keep away from sources of ignition
- No smoking. Keep only in the original container. Keep container tightly sealed. Protect against
moisture. Avoid direct sunlight. Protect containers from ph ysical damage. The authority permits and
storage regulations must be observed. Store protected against freezing. Keep tanks under inert gas.
Air monitoring should be used to alert any build up of explosive mixtures. Equipment to be installed
in an environment with potentially explosive atmospheres should conform to the requirements of
ATEX Directive 94/9/EC. Ventilate freight container with open door for 30 minutes before unloading.

Storage stability:
Keep container tightly closed and dry.
Keep only in the original container in a cool, dry, well -ventilated place away from ignition sources,
heat or flame.
__________________________________________________________________

8. Exposure Controls/Personal Protection

Components with occupational exposure limits
Pentane Exposure TWA value 600 ppm 1,800 mg/m3 ; STEL
limits value 760 ppm 2,250 mg/m3 ;
NIOSH REL value 120 ppm 350 mg/m3 ; Ceil_Time
Pocket Guide 610 ppm 1,800 mg/m3 ;
to Chemical
Hazards (US)

Personal protective equipment

General safety and hygiene measures:
Avoid inhalation of dusts/mists/vapours. No special precautions necessary. When using do not eat or
drink. When using do not smoke.
__________________________________________________________________

9. Physical and Chemical Properties
Form: beads
Odor: of pentane
Odor threshold Not applicable information available
Odour threshold: not determined
Colour: white
pH value: not soluble
softening temperature: approx. 70 °C
onset of boiling: The substance / product
decomposes therefore not
determined.
Sublimation point: not applicable
Flash point: Vapours are flammable.
Flammability: not highly flammable (UN Test N.1 (ready combustible
solids))
Flammability of Aerosol not applicable, the product does not
Products: form flammable aerosoles)
Lower explosion limit: Product not examined: Value is
calculated from the data of the
components.
Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 6/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
Upper explosion limit: Product not examined: Value is
calculated from the data of the
components.
Autoignition: 285 °C (DIN 51794)
Vapour pressure: not applicable
Density: approx. 1.02 - (20 °C)
1.05 g/cm3
Bulk density: approx. 600 (20 °C)
kg/m3
Vapour density: 2.5 Heavier than air.
Partitioning coefficient noctanol/ not applicable
water (log Pow):
Self-ignition not self-igniting
temperature:
Viscosity, dynamic: not relevant
Miscibility with water: immiscible
Solubility (quantitative): No applicable information available.
Solubility (qualitative): soluble
solvent(s): aromatic hydrocarbons, ketones, organic
solvents,
Evaporation rate: The product is a non-volatile solid
Decomposition temperature Not available
Molecular weight: 260,000 Da
__________________________________________________________________

10. Stability and Reactivity

Reactivity
No hazardous reactions if stored and handled as prescribed/indicated., Vapours may form
explosive mixture with air.

Oxidizing properties:
not fire-propagating

Chemical stability
Product is stable if is storage and handled correctly.

Possibility of hazardous reactions
Formation of explosive gas/air mixtures.

Conditions to avoid
> 70 °C
Avoid all sources of ignition: heat, sparks, open flame. Avoid direct sunlight. Avoid electro -static
discharge.

Incompatible materials
Explosive substances according UN transport regulations class 1, Propellant release will be boosted
with increasing temperature.

Hazardous decomposition products
Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 7/11
Version: 2.0 (2018-USA/ENG-P40V2.0)

Decomposition products:
Possible thermal decomposition products: Pentane, styrene monomers, Heated product evolves
combustible vapors.
__________________________________________________________________

11. Toxicological information

Primary routes of exposure

Routes of entry for solids and liquids are ingestion and inhalation, but may include eye or skin contact.
Routes of entry for gases include inhalation and eye contact. Skin contact may be a route of entry for
liquefied gases.

Acute Toxicity/Effects

Acute toxicity
Assessment of acute toxicity: Contact with heated product can cause thermal burns.

Oral
Type of value: LD50
Value: > 2,000 mg/kg

Inhalation
Type of value: LC50
Value: > 5 mg/l

Dermal
Type of value: LD50
Value: > 2,000 mg/kg

Irritation / corrosion
Assessment of irritating effects: No irritation is expected under intended use and appropriate
handling.
No data available concerning irritating effects.

Skin
Result: non-irritant

Eye
Result: non-irritant

Sensitization
Assessment of sensitization: There is no evidence of a skin-sensitizing potential.
Result: Non-sensitizing.

Chronic Toxicity/Effects
Repeated dose toxicity
Information on: isopentane
Assessment of repeated dose toxicity: Chronic overexposure has been shown to cause adverse
kidney effects in experimental animals.
----------------------------------
Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 8/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
Genetic toxicity
Assessment of mutagenicity: Based on our experience and the information available, no adverse
health effects are expected if handled as recommended with suitable precautions for designated
uses.

Carcinogenicity
Assessment of carcinogenicity: Based on our experience and the information available, no adverse
health effects are expected if handled as recommended with suitable precautions for designated
uses.

Reproductive toxicity
Assessment of reproduction toxicity: Based on our experience and the information available, no
adverse health effects are expected if handled as recommended with suitable precautions for
designated uses.

Other Information
No reports of ill effects provided product was correctly handled and processed.
Information on: Pentane
Has a degreasing effect on skin.
----------------------------------
Symptoms of Exposure
headache, dizziness, incoordination, dazed state, Eye irritation, skin irritation
__________________________________________________________________

12. Ecological Information

Toxicity

Aquatic toxicity
Assessment of aquatic toxicity:
There is a high probability that the product is not acutely harmful to aquatic organisms. No toxic effects
occur within the range of solubility.

Aquatic invertebrates
EC50 (48 h) > 100 mg/l, Daphnia magna (OECD Guideline 202, part 1, static)
Nominal concentration. The product has low solubility in the test medium. An eluate has been tested.
No toxic effects occur within the range of solubility. The product has not been tested. The statement
has been derived from substances/products of a similar structure or composition.

Aquatic plants
EC50 (72 h) > 100 mg/l (growth rate), Desmodesmus subspicatus (OECD Guideline 201, static)
Nominal concentration. The product has low solubility in the test medium. An eluate has been tested.
No toxic effects occur within the range of solubility. The product has not been t ested. The statement
has been derived from substances/products of a similar structure or composition.

Aquatic toxicity
Information on: Pentane
Assessment of aquatic toxicity:
Acutely toxic for aquatic organisms.
----------------------------------

Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 9/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
Persistence and degradability

Assessment biodegradation and elimination (H2O)
In accordance with the required stability the product is not readily biodegradable. The product has
not been tested. The statement has been derived from the structure of the pro duct. The product is
virtually insoluble in water and can thus be separated from water me chanically in suitable effluent
treatment plants.

On the basis of the data available concerning eliminability/degradation and bioaccumulation potential,
longer-term harm to the environment is improbable. No data available concerning biodegradation and
elimination.

Bioaccumulative potential

Bioaccumulation potential
The product will not be readily bioavailable due to its consistency and insolubility in water.

Mobility in soil

Assessment transport between environmental compartments
Study scientifically not justified.

Additional information

Add. remarks environm. fate & pathway:
Because of the product's consistency and low water solubility, bioavailability is improbable.

Other ecotoxicological advice:
At the present state of knowledge, no negative ecological effects are expected. No toxic effects
occur within the range of solubility.

Information on: Pentane
Other ecotoxicological advice:
The substance has a very low Global Warming Potential and no Ozone Depleting Potential.
---------------------------------
______________________________________________________________

13. Disposal considerations

Container disposal:
Remove all packaging for recovery or disposal
__________________________________________________________________

14. Transport Information
Land transport
TDG
Hazard class: 9
Packing group: III
ID number: UN 2211
Hazard label: 9
Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 10/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
Proper shipping name: POLYMERIC BEADS, EXPANDABLE

Sea transport
IMDG
Hazard class: 9
Packing group: III
ID number: UN 2211
Hazard label: 9
Marine pollutant: NO
Proper shipping name: POLYMERIC BEADS, EXPANDABLE

Air transport
IATA/ICAO
Hazard class: 9
Packing group: III
ID number: UN 2211
Hazard label: 9
Proper shipping name: POLYMERIC BEADS, EXPANDABLE

Environmental Risks
This material does not contain toxic chemicals in excess or above what is pre -indicated in
toxicological regulation programs or that can be harmful to the environment.

Special warnings for the user

Safety Data Sheet
STYROPEK® P40 Series
Revision date: 05/31/2018 Page: 11/11
Version: 2.0 (2018-USA/ENG-P40V2.0)
__________________________________________________________________

15. Regulatory Information

Federal Regulations

Not applicable

NFPA Hazard codes:
Health : 1 Fire: 2 Reactivity: 0 Special:

HMIS III rating
Health: 1 Flammability: 2 Physical hazard: 0
_________________________________________________________________

16. Other Information

SDS Prepared by:
Styropek Product Regulations
SDS Prepared on: 03/01/2018

We support worldwide Responsible Care® initiatives. We value the health and safety of our
employees, customers, suppliers and neighbors, and the protection of the environment. Our
commitment to Responsible Care is integral to conducting our business and operating our facilities in
a safe and environmentally responsible fashion, supporting our customers and suppliers in ensuring
the safe and environmentally sound handling of our products, and minimizing the impact of our
operations on society and the environment during production, storage, transport, use and disposal of
our products.

STYROPEK is a registered trademark of STYROPEK DE MEXICO SA DE CV or STYROPEK USA,
INC. IMPORTANT: WHILE THE DESCRIPTIONS, DESIGNS, DATA AND INFORMATION
CONTAINED HEREIN ARE PRESENTED IN GOOD FAITH AND BELIEVED TO BE ACCURATE, IT
IS PROVIDED FOR YOUR GUIDANCE ONLY. BECAUSE MANY FACTORS MAY AFFECT
PROCESSING OR APPLICATION/USE, WE RECOMMEND THAT YOU MAKE TESTS TO
DETERMINE THE SUITABILITY OF A PRODUCT FOR YOUR PARTICULAR PURPOSE PRIOR TO
USE. NO WARRANTIES OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING
WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, ARE
MADE REGARDING PRODUCTS DESCRIBED OR DESIGNS, DATA OR INFORMATION SET
FORTH, OR THAT THE PRODUCTS, DESIGNS, DATA OR INFORMATION MAY BE USED
WITHOUT INFRINGING THE INTELLECTUAL PROPERTY RIGHTS OF OTHERS. IN NO CASE
SHALL THE DESCRIPTIONS, INFORMATION, DATA OR DESIGNS PROVIDED BE CONSIDERED
A PART OF OUR TERMS AND CONDITIONS OF SALE. FURTHER, YOU EXPRESSLY
UNDERSTAND AND AGREE THAT THE DESCRIPTIONS, DESIGNS, DATA, AND INFORMATION
FURNISHED BY OUR COMPANY HEREUNDER ARE GIVEN GRATIS AND WE ASSUME NO
OBLIGATION OR LIABILITY FOR THE DESCRIPTION, DESIGNS, DATA AND INFORMATION
GIVEN OR RESULTS OBTAINED, ALL SUCH BEING GIVEN AND ACCEPTED AT YOUR RISK.
END OF DATA SHEET

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