Business Objective

Legal counsel for a power cable manufacturing facility contacted ALG to provide strategic and technical guidance to secure the planned expansion of the facility. In permitting this new productive capacity, it would also be necessary to correct existing permits. To complicate matters, the project required local agency approvals within a relatively compressed period. ALG was selected based on its technical expertise and working knowledge of local district permitting protocols and requirements.

Technical Approach

ALG first researched and documented the permit history of the facility relative to the local air district pre-construction review requirements that were in place at the time prior facility modifications were made. Our analysis revealed that an improved understanding of the emissions profile of specific equipment within the facility emerged over time. Recognizing that these new emissions data were pivotal to resolving past permit issues, ALG developed a strategic plan, in coordination with local district engineering staff, to obtain improved emissions data through on-site testing of existing operations. These site-specific emissions data would used to correct past permitting actions and to support the expansion of the facility. As part of this process ALG verified that the facility did not trigger air toxic modeling nor would it be classified as a major source of Hazardous Air Pollutants (HAP).

These accurate emissions data and refined material throughput data were also instrumental in crafting emission limits for the new permit that provided the necessary operational flexibility to our client. Finally, these refined data also demonstrated that concurrent emission reductions, or offsets, would not be required and supported reasonable Best Available Control Technology (BACT) determinations.

Results

ALG’s strategy to obtain accurate emissions data, with the full support of local district engineering staff, provided a sound basis to correct past permitting decisions and to support the planned expansion. Our technical expertise in these air quality matters, coupled with our solid relationship with local air district engineering staff, allowed our client to successfully navigate an otherwise difficult path of “shift-in-load”, Best Available Control Technology, and acquiring offsets, which likely would have de-railed the project.