ESS prepared a comprehensive permit application for the RTO that demonstrated Best Available Control Technology (BACT) by improving the control efficiency from 95% to 98%, reduced facility emissions of VOC and hazardous air pollutants (HAPs) even further by venting mix room emissions to the RTO, and maintaining 100% capture efficiency through the design of a room permanent total enclosure about the coating lines.
ESS subsequently conducted compliance testing of the RTO and enclosure, demonstrating an overall control efficiency in excess of that required by the permit. The facility was commended by local community for eliminating the odorous emissions. As part of the SEP agreement, the facility was able to credit surplus VOC emission reductions against the purchase of VOC offsets required by an earlier regulatory action.