Gulf Coast Waste Disposal Authority (GCA) owns and operates the Washburn Tunnel Facility (WTF), an industrial publicly owned treatment works (POTW), in Pasadena, Texas. The WTF treats a combination of industrial and municipal wastewater in a biological treatment system. Although the WTF very efficiently removes the organic chemical constituents in the influent wastewater, it was determined that additional control of emissions of volatile organic compounds (VOC) would be required to comply with the applicable air emissions regulations for the Houston-Galveston-Brazoria Non-Attainment Area.After a comprehensive study, GCA concluded that conversion of one of the existing primary clarifiers to a first step, pure-oxygen aerated, activated sludge unit would achieve the BACT goal and would reduce the WTF's total VOC emissions by over 60 percent. The modifications to the WTF were completed in early 2007 and full operation with the modified facility began in March 2007.