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Applicant: Brightmark Circularity Center Thomaston LLC
Application No.: 29749
Draft Permit Number: 2869-293-0040-S-01-0
Facility AIRS Number: 04-13-293-00040
5.21.26
Introduction & Statement of Interest
Coastal Communities United submits these formal comments on Draft Air Quality Permit No. 2869-293-0040-S-01-0 — and we ask EPD to take a different approach to this permit, which requires more monitoring, measuring and reporting requirements to protect Thomaston in the surrounding communities.
This permit, as drafted, is a regulatory fiction. It allows Brightmark Circularity Center Thomaston LLC to operate what is functionally a Major Title V source while wearing the paperwork and regulatory burden of a minor one. The gaps are not technical oversights. They are structural — and they will cost Upson County residents their air quality and peace of mind.
While we appreciate advanced solutions to plastics and recycling, we will not accept a solution that allows toxic air over an inland community that deserves better. The pyrolysis products generated at this facility — pyrolysis oil, light-cut liquids — move through regional rail and truck corridors directly to coastal ports and chemical hubs. This is our supply chain. This is our problem too. One of our board members lives in nearby Lamar County, and she sees firsthand how much concern exists with citizens of the region.
We reviewed this draft permit alongside peer-reviewed academic literature on pyrolysis emissions, advanced recycling system failures, and area-source permitting vulnerabilities. What we found demands that EPD either strengthen this permit or deny it outright. The deficiencies outlined below are not negotiable.
Community Exposure Context: This Is Not an Abstract Risk
Before addressing technical deficiencies, EPD must reckon with who lives downwind of this facility. Thomaston and the surrounding Upson County community are not an industrial corridor. Residential neighborhoods, churches, and active recreational facilities sit within the direct airshed of this proposed plant. Children play on ballfields. They walk to school. They ride bikes in driveways. They do not receive air quality alerts. They do not have monitors in their neighborhoods. They have no warning system — and this permit does nothing to create one.
Air pollution does not honor county lines. Prevailing wind patterns in this region carry emissions northeast and east, placing portions of Pike, Lamar, Monroe, and Spalding Counties within the realistic impact zone of routine and upset emissions from this facility. Families in those counties have no seat at this permitting table and no knowledge that a plastic-to-fuel chemical conversion plant may be shaping the air their children breathe on a Tuesday afternoon.
The populations most vulnerable to HAP and VOC exposure — children, the elderly, individuals with asthma and respiratory conditions — are precisely the populations least equipped to protect themselves without advance warning. A permit that contains no community notification requirements, no real-time public air monitoring, and no emergency alert protocol is not a protective permit. It is a liability waiver dressed in regulatory language.
Critical Requested Condition — Community Air Monitoring and Public Warning System:
EPD must require Brightmark to fund, install, and maintain a network of continuous ambient air quality monitors at the facility fence line and at a minimum of two community receptor locations — prioritizing sites within one mile of schools, parks, ballfields, and dense residential areas. Monitor data must be transmitted in real time to a publicly accessible dashboard. EPD must further require that Brightmark establish and maintain a community air quality alert system — including automated text and email notifications to registered residents within a five-mile radius — triggered any time fence-line monitors detect VOC, HAP, or particulate matter readings that exceed 75% of any applicable standard. Children cannot read a permit. They deserve a warning they can actually receive.
Major Technical and Regulatory Deficiencies
1. No Feedstock Controls Means No Emissions Control
Pyrolysis thermally degrades plastics in an oxygen-absent environment. That sounds clean until you understand what's actually in post-consumer plastic waste: polyvinyl chloride (PVC), polyurethanes, and a cocktail of halogenated contaminants that no sorting facility reliably removes (Rollinson & Oladejo, 2019). When PVC hits a pyrolysis reactor, it releases hydrogen chloride (HCl) — a listed hazardous air pollutant — and generates precursors to chlorinated dioxins and furans (Patterson & Tang, 2021).
The Permit Gap: The draft sets facility-wide HAP caps to maintain Area Source Classification but says nothing — not one word — about what goes into the reactor. No maximum allowable PVC percentage. No halogenated contaminant threshold. No feedstock specification whatsoever. You cannot cap what comes out of a process you refuse to define going in.
Requested Condition: EPD must establish an explicit, legally enforceable feedstock specification limit — no greater than 0.1% PVC by weight — with mandatory daily composite testing of incoming shredded plastic using Fourier-transform infrared spectroscopy (FTIR) or equivalent technology. Annual back-calculations do not catch acute spikes. They document them after the damage is done.
2. Five-Year Testing Cycles on an Unstable Process Is Not Compliance — It's Willful Blindness
Condition 6.5(b) allows VOC and HAP performance testing once every 30 months after initial testing. If two consecutive tests show emissions at or below 50% of the limit, that interval stretches to 60 months — five years.
The Permit Gap: Pyrolysis is not a stable process. Feedstock composition shifts daily. Moisture content, plastic type ratios, and residual contaminants directly alter process gas chemistry and control device performance (Tang et al., 2023). A facility attempting to avoid Title V Major Source designation should face *more* scrutiny, not less. A 5-year testing window on a plastic-to-fuel chemical conversion plant is not a compliance schedule — it is an invitation to operate unchecked.
Meanwhile, the children at the nearest school do not get a five-year break from breathing. They are outside at recess every single day, in every season, with no knowledge of what is being emitted a mile away and no system to tell them to go inside.
Requested Condition: Condition 6.5(b) must be amended to require annual VOC and HAP performance testing for the life of this permit. The 60-month relaxation provision must be struck entirely. Public health protection does not get a relaxation schedule.
3. Flaring Without Limits Is Just Permitted Pollution
Condition 4.5 allows emergency flares (FL-1 and FL-2) during startup, shutdown, malfunction, and emergencies. Condition 1.1 states emissions must be minimized "at all times."
The Permit Gap: "Minimize" is not a limit. In pyrolysis systems, thermal imbalances and downstream equipment failures regularly direct large volumes of unrefined, highly toxic syngas to flares (Rollinson & Oladejo, 2019). Flare combustion efficiency varies dramatically with crosswind conditions and gas composition. The result: significant uncombusted VOC and HAP releases during SSM windows — none of which violate a single enforceable number in this permit because no enforceable numbers exist for flaring events.
Flaring events frequently occur at night, during early morning startup, or on weekends — precisely when no regulatory observer is present and when families have windows open and children are sleeping. Without a community alert system and without enforceable flaring limits, residents have no way of knowing a toxic release event is occurring in their airshed until they smell it — or until they don't, because many HAPs are odorless.
Requested Condition: EPD must establish a strict rolling 12-month cap on non-emergency flaring hours. Flare gas composition and combustion efficiency must be continuously monitored via automated gas chromatography. All SSM flare emissions must be calculated and integrated into the monthly rolling HAP and VOC totals under Condition 7.4. Flaring events must trigger immediate notification to the community alert system described above. If it burns, it counts.
4. Letting a Facility Write Its Own Emissions Math After Startup Is Regulatory Malpractice
Condition 7.4 gives Brightmark 60 days after initial startup to submit its emissions calculation protocol — the mathematical framework that determines whether this facility stays below Major Source thresholds.
The Permit Gap: This is not a minor procedural issue. The public cannot evaluate whether the "practically enforceable emission limitations" keeping this facility out of Title V are real or theoretical without seeing the emission factors, mass balance formulas, and engineering assumptions first. Allowing a facility to define its own compliance math after it begins processing post-consumer plastics is not permitting — it is post-hoc rationalization with regulatory letterhead.
The community surrounding this facility — including parents, school administrators, and local health providers in Upson, Pike, Lamar, Monroe, and Spalding Counties — deserves to know before the first reactor fires whether the numbers actually work. Once operations begin, the burden of proof quietly shifts. That shift should not happen on the public's dime.
Requested Condition: The emissions calculation protocol must be finalized, reviewed by EPD engineers, and published for public review before this permit is finalized. Startup must be legally contingent on an approved protocol. No exceptions.
5. A 40% Opacity Standard in 2026 Is Inappropriate
Condition 2.5 sets the opacity threshold at 40%. Condition 5.3 requires one daily visual check of dust control devices.
The Permit Gap: Forty percent opacity is visually dense, heavily particulate-laden air. Modern industrial facilities with competent filtration routinely operate below 10–20% opacity. This standard belongs in a 1975 permit, not one issued for a new facility in 2026. Compounding this, a single daily manual visual check leaves nighttime emissions and intermittent daytime failures entirely undetected. Human eyes cannot monitor what they cannot see.
Fine particulate matter — PM2.5 — is invisible to the naked eye and among the most dangerous pollutants for developing lungs. A child running bases on a ballfield a half-mile downwind has no idea what they are inhaling. A 40% opacity standard does not protect them. It simply ensures the smoke is thick enough to see before anyone acts.
Requested Condition: Condition 2.5 must be amended to reduce the maximum allowable opacity from 40% to 20%, consistent with modern standards for new industrial sources. Shredding dust collectors DC-1 and DC-2 must be equipped with continuous bag leak detection systems (BLDS). Manual daily checks are insufficient for high-capacity units handling raw and shredded plastic feedstock.
Review of Health Concerns Related to Dioxin Emissions
Dioxins are highly toxic, persistent environmental pollutants that bioaccumulate within adipose tissue, posing severe acute and chronic health risks through inhalation, dermal contact, and dietary ingestion (Agency for Toxic Substances and Disease Registry [ATSDR], 2019). Short-term elevated exposure can induce acute systemic toxicities, including liver function alteration, nausea, vomiting, muscle aches, and chloracne—a severe, disfiguring skin disease (World Health Organization [WHO], 2016). Chronic, low-dose exposure is comprehensively linked to severe systemic degradation, including permanent immune suppression, endocrine disruption, impaired fertility, and adverse neurodevelopmental outcomes (National Institute of Environmental Health Sciences [NIEHS], 2023). Notably, 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) is classified by the International Agency for Research on Cancer (IARC) as a known human carcinogen (IARC, 2012).
Spatial Dispersion and Pediatric Vulnerability Near Industrial Sources
The operation of a continuous dioxin-emitting facility within a one-mile radius of educational infrastructure presents an acute risk to public health. Meteorological vectors—such as prevailing wind patterns, stack height efficiency, and localized atmospheric temperature inversions—dictate that significant concentrations of particulate-bound dioxins settle into surrounding soils and dust, facilitating prolonged indoor and outdoor exposure pathways (Environmental Protection Agency [EPA], 2020).
Children represent a uniquely vulnerable subpopulation to these ambient emissions. Due to their higher respiration rates relative to body mass and ongoing neurological, immunological, and endocrine development, pediatric populations experience disproportionately higher internal doses of environmental toxins (Landrigan & Goldman, 2011). Empirical research corroborates these toxicological frameworks, demonstrating significantly degraded student health and academic outcomes for schools located within a one-mile radius of active Toxic Release Inventory (TRI) infrastructure (Persico et al., 2020). Consequently, a one-mile buffer zone cannot be considered inherently protective against an active, continuous source of ambient dioxin emissions.
Conclusion
This permit, as written, does not protect Upson County. It does not protect Pike, Lamar, Monroe, or Spalding Counties. It does not protect the child on the soccer field, the grandmother on her porch, or the family with the windows open on a warm Georgia evening. It protects Brightmark's operational flexibility at the public's expense.
Coastal Communities United calls on Georgia EPD to deny Permit No. 2869-293-0040-S-01-0 in its current form. Re-evaluate this facility's potential to emit under realistic, variable feedstock conditions. Incorporate the enforceable modifications detailed above — including mandatory community air monitoring, a real-time public alert system, and multi-county receptor protections. Then subject the revised draft to a second round of public comment — because at that point, it would be a substantially different permit to review.
The people of Thomaston and the surrounding region are not a sacrifice zone. Georgia EPD has the authority and the obligation to get this right.
Respectfully submitted,
Kristen Stampfer, Director
Coastal Communities United
coastalcommunitiesunited@gmail.com
Alana Olson, Board Member
Coastal Communities United
Lamar County Resident
References
Agency for Toxic Substances and Disease Registry (ATSDR). (2019). Toxicological profile for chlorinated dibenzo-p-dioxins (CDDs). U.S. Department of Health and Human Services. https://www.atsdr.cdc.gov/toxprofiles/tp104.pdf
Environmental Protection Agency (EPA). (2020). Exposure and human health re-assessment of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) and related compounds (National Center for Environmental Assessment No. EPA/600/R-10/038F). https://cfpub.epa.gov/ncea/risk/recordisplay.cfm?deid=241723
Georgia Department of Natural Resources, Environmental Protection Division. (2026). Air Quality Permit No. 2869-293-0040-S-01-0: Brightmark Circularity Center Thomaston LLC (Draft). https://epd.georgia.gov/air-protection-branch-public-notices
International Agency for Research on Cancer (IARC). (2012). Chemical agents and related occupations: A review of human carcinogens (IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, Volume 100F). World Health Organization. https://publications.iarc.fr/Book-And-Report-Series/Iarc-Monographs-On-The-Evaluation-Of-Carcinogenic-Risks-To-Humans/Chemical-Agents-And-Related-Occupations-2012
Landrigan, P. J., & Goldman, L. R. (2011). Children's vulnerability to environmental toxic chemicals. Lancet Oncology, 12(8), 719-721. https://doi.org/10.1016/S1470-2045(11)70104-X
National Institute of Environmental Health Sciences (NIEHS). (2023). Dioxins. National Institutes of Health. https://www.niehs.nih.gov/health/topics/agents/dioxins
Patterson, M. A., & Tang, L. (2021). Thermal cracking of municipal plastic waste streams: Characterizing hazardous air pollutant yields from halogenated polymers. Journal of Hazardous Materials, 412, 125–138. https://doi.org/10.1016/j.jhazmat.2021.125138
Persico, C., Figlio, D. N., & Roth, J. (2020). The effects of increased exposure to toxic chemicals on student achievement. Journal of Human Resources, 55(4), 1161-1202. https://doi.org/10.3368/jhr.55.4.1017-8947R2
Rollinson, A. N., & Oladejo, J. M. (2019). 'Advanced recycling': Thermodynamic realities and spatial emission profiles of plastic pyrolysis systems. Environmental Science & Technology, 53(20), 11621–11632. https://doi.org/10.1021/acs.est.9b03398
Tang, Y., Zheng, M., & Liu, K. (2023). Process instability in commercial polymer pyrolysis: Feedstock heterogeneity and its direct impact on volatile organic compound emissions. Waste Management, 156, 44–53. https://doi.org/10.1016/j.wasman.2023.01.012
World Health Organization (WHO). (2016). Dioxins and their effects on human health (Fact Sheet No. 225). https://www.who.int/news-room/fact-sheets/detail/dioxins-and-their-effects-on-human-health
11.16.20
Pike County Residents,
I am an emergency medical services worker whose service includes all of Pike County. I am concerned about our ambulances and the rescue vehicles struggling to locate residences that are not clearly marked by a numerical address.
When a resident is having a heart attack, stroke, or serious bleeding issue, seconds may mean the difference in a resident’s survival or demise. If our vehicles lose cell and radio signals in a rural area, we could arrive at the scene much later than desired. A simple numerical placard near the roadway would be the perfect solution to aid the police, fire, and emergency services in completing their roles successfully.
This has been done in many rural counties for the same reasons and has been a success for the first responders and delivery vehicles, mail carriers, and passers-by. A second suggestion would be to keep the trees and bushes surrounding street signs that are already in place to ensure that their visibility is 100% from the roadway.
Tonie P. Biles
Pike County
[Note from the Editor: The Pike County Emergency Service Auxillary is selling reflective address signs to Pike County citizens. Proceeds benefit all emergency services personnel with disaster assistance in the form of gatorade, water, and other necessary items. Green signs are 6 inches by 18 inches with 4 inch reflective numbers on each side. To order, call 770-468-8633 for more information. All orders for reflective address signs must be made in writing.
I am leaving this up in the interest of safety because these signs are still being made and sold to citizens as indicated above.]