Pilot Flexible Air Permit Profile

Source: Lasco Bathware Corporation
Facility Type: Fiberglass reinforced plastic bathware manufacturer
Location: Yelm, Washington

On June 7, 1997, Lasco’s facility in Yelm, Washington received a flexible title V air operating permit (Permit No. 01-97) as part of EPA’s Pollution Prevention Performance Partnership (P4) Program.  Lasco produces bath fixtures including fiberglass reinforced plastic bathtubs, shower stalls, and whirlpools.  The flexible permit contained minor New Source Review (NSR) advanced approvals that enabled Lasco to add new spray booths, change spray equipment, and change mechanical equipment in a timely manner without triggering Major NSR.  The flexible permit ensured the best available pollution control technologies were installed and that total air emissions remained under the approved plantwide emissions limits.

Tools & Methods Used in the Pilot Permit

Environmental Benefits and Pollution Prevention

• Reduced allowable and actual air emissions. Lasco had been actively pursuing pollution prevention (P2) opportunities prior to the flexible permit.  The P2 program requirement within the flexible permit formalized and broadened Lasco’s ongoing efforts to reduce emissions.  At the outset of the flexible permit development process, it became clear to both Lasco and OAPCA that the community had concerns, primarily associated with styrene emissions and associated odor issues.  Prior to and soon after permit implementation, Lasco undertook a series of P2 initiatives that resulted in a 14% decrease in emissions per unit of production. 
• Easier P2 implementation. From 1996 to 2001, Lasco estimates it has reduced VOC emissions per unit by approximately 32%.  Lasco representatives reported that the flexible permit made it more attractive for the facility to look for and implement P2 opportunities. In addition to the P2 program requirements, Lasco also voluntarily installed a regenerative thermal oxidizer (RTO) pollution control device to accommodate pollution from a third line while remaining below its potential to emit (PTE) cap.  According to OAPCA representatives, the measures undertaken by Lasco have reduced regional emissions for bathware products since the local need for them would otherwise be met by less efficient sources with more pollution emitted per unit of production.  Lasco, through P2, limited its emissions per unit of production so as to allow greater overall production under its emissions cap. 

Economic Competitiveness Benefits

• Agile manufacturing. Lasco engaged in a series of advanced-approved changes, including updating its emission factor and voluntarily installing an RTO.  These actions combined to create head room under Lasco’s cap which then enabled the company to increase production.  In the past, managers at the Yelm facility had been very averse to making changes that would trigger permitting actions and they would wait to undertake changes until the time of permit renewal, postponing implementation of some P2 opportunities.  The advanced approvals allowed Lasco to make a series of modifications that created the opportunity to increase production from 126,045 units per year (in 1997) to 132,548 units per year (in 2000) generating a significant annual increase in profit. After the RTO was installed emissions decreased per unit to 3.13 pounds per unit allowing production to increase and reducing costs associated with styrene loss.  The flexible permit has enabled Lasco to shorten significantly the time it needs to respond to a change in market demand or the emergence of a process efficiency improvement opportunity.

Monitoring and Enforceability

• Replicable monitoring and routine reporting. During the course of the flexible permit, Lasco conducted two stack tests to determine emissions levels and to estimate future calculations of emissions based on material usage.  Lasco measures all VOC emissions, including fugitive emissions, using an emission factor approach.  The additional reporting and monitoring required under the flexible permit assures enforceability and results in additional data availability for both the permitting authority and the public.

Government Efficiency

• Paperwork and backlog reduction. OAPCA representatives reported that the flexible permit saved both the agency and Lasco staff time associated with preparing and processing notice of construction applications. During the flexible permit, Lasco made five advanced-approved changes that would have otherwise triggered case-by-case minor NSR permit actions.  The time savings also includes time spent drafting a permit to construct, ensuring NAAQS compliance, modifying the title V permit, and conducting the change-specific public review process.

Public Response

• Public support. When Lasco prepared their first title V permit application in 1996, many residents in the Yelm community did not view the company as a “good neighbor” due primarily to past odor issues. During the permit development process, OAPCA therefore decided to surpass standard title V public review and comment procedures by holding several public information sessions to discuss the innovative flexibility and P2 provision’s in Lasco’s draft permit. OAPCA was also proactive about notifying participants of community meetings and associated information, issuing fact sheets about the pilot permit project, releasing newsletters, and improving communications between the facility, the local community, and environmental agencies. During the title V hearing, no concerns were voiced by the community with regard to the draft permit.

For More Information

• Pilot Permit
  
• Technical Support Document and Statement of Basis for the Lasco Air Operating Permit. July 7, 1997
• Technical Support Document 2005 Operating Permit Renewal Lasco Yelm Facility. April 26, 2005.
• For more information on flexible air permitting, see the U.S. EPA’s 2001 report, Evaluation of Implementation Experiences with Innovative Air Permits
• For more information about Lasco's pilot flexible air permit, see EPA’s Lasco Permit Review Report