Regulatory Analysis, Planning & Permitting

Successful and timely business growth requires effective regulatory planning and permitting. A misunderstanding of the vast array of air quality regulations can put a stranglehold on a company’s plans to modify or expand its facility. JBR personnel monitor federal, state and county rulemaking processes through on-line and subscription services to evaluate the potential impact of proposed regulations on our clients. This provides effective planning for complying with new requirements prior to final rulemaking.

JBR’s knowledge of federal and local air quality regulations allows development of strategies that minimize lengthy and cumbersome permit processes. Our planning and permitting services include:

• Regulatory Analysis
• Permit Application Planning and Development
• Regulatory Liaison Services
• Minor Source Demonstrations
• Major Source Determinations
• PSD/NSR Applicability Determinations
• Air Pollution Control Requirement Determinations (MACT, BACT, RACT, LAER)
• GEP Stack Height Determinations
• Emissions Inventory Preparation and Documentation
• Compliance Plan Development

Integrating regulatory experience and various levels of technical support allows JBR to offer efficient and cost effective permitting services for new sources and modifications to existing sources. JBR prepares air quality permit applications and related evaluations for: 

• Title V and Non-Title V Operating Permits
• New Sources and Modifications to Existing Sources
• Significant and Minor Permit Revisions
• Environmental Impact Statements (EIS)
• Sources of Hazardous Air Pollutants (Title III of the Clean Air Act)
• Portable Sources

Some changes to existing sources may be exempt from permitting or may only require submittal of a notification to the permitting agency. JBR has the expertise and understanding of the federal and state regulations necessary to make these demonstrations and to assist you in preparing the proper notifications to ensure continued compliance.

Emission Inventories
JBR uses standard emission factors available in the literature and from application of basic scientific principles to develop complete emission inventories for anthropogenic and naturally occurring emission sources.  For very complex processes where emission factors do not apply, JBR has designed and implemented field testing programs to measure actual emission rates. These procedures have been utilized in preparing applications for a multitude of Title V sources and hundreds of individual air quality permit modifications or revisions.

Data bases and methodologies utilized by AEC to develop emission factors include:

• Compilation of Air Pollution Emission Factors for Stationary and Mobile Sources, USEPA
• AIRS Facility Subsystems Source Classification Codes (SCC) and Emission Factor Listing for Criteria Pollutants, USEPA
• Factor Information Retrieval (FIRE) System, USEPA
• Toxic Air Pollutant Emission Factors, USEPA
• Air Emissions Models for Waste and Wastewater, USEPA
• VOC/PM Speciation Data System (Speciate), USEPA
• Other USEPA and technical documents
• Mass balance analyses
• Reference method emission source tests
• Special field programs designed to measure actual emission rates

Depending upon the client’s needs, emission inventories are generally prepared using electronic spreadsheets that can subsequently be modified, summarized, or processed for further applications including dispersion modeling analyses.