Managing Emissions, Mitigating Risk and Securing Approval for Facility Growth
Challenge
A snack food manufacturer wanted to expand production to keep up with rising customer demand, but the planned installation of new equipment lines quickly revealed several regulatory challenges. The facility was located in a serious ozone non-attainment area, where small increases in emissions could trigger complex permitting requirements. It was also classified as a source of hazardous air pollutants (HAPs) and bordered a state biodiversity conservation area, placing the project under heightened environmental scrutiny. These conditions created significant pain points for the client, including uncertainty about required permits, the risk of emissions thresholds delaying construction and the potential for the entire project to stall without a clear and defensible technical basis for state review.
Solution
TRC addressed the risks by first developing detailed emissions estimates to determine how the expansion would impact regulatory requirements. The analysis showed that the smaller line could proceed without New Source Review (NSR), while the larger line required an NSR permit and Title V operating permit modifications. With this pathway defined, TRC completed the technical work needed for agency approval, including single-source air dispersion modeling to assess Significant Impact Levels and demonstrate compliance with NAAQS and PSD increments. TRC also conducted comprehensive regulatory applicability reviews and performed a Best Available Control Technology (BACT) analysis for PM-10 emissions after projections exceeded the state’s threshold. Each step was designed to remove uncertainty, reduce permitting risk and provide a clear foundation for the state’s evaluation.
Results
TRC prepared and submitted a comprehensive NSR permit application along with a Title V operating permit modification package, integrating all emissions estimates, dispersion modeling results and regulatory applicability reviews completed throughout the project. The documentation provided a clear, defensible technical foundation, reducing uncertainty and streamlining the review process. During agency evaluation, TRC remained actively engaged responding promptly to technical questions, supplying supplemental data when needed and incorporating revisions to ensure alignment with regulatory expectations. This close coordination helped prevent administrative delays and kept the permitting timeline on track.
The state issued both permits on schedule, enabling the facility to move forward with construction and install the new production lines without disruption. With approvals secured, the manufacturer successfully expanded its production capacity while maintaining full compliance with all applicable air quality standards and environmental requirements.
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