Regulatory/Permitting

A wide range of a facility’s design and operational aspects is affected by air quality regulations. With greater attention and resources being dedicated to air quality issues, ensuring cost-effective on-going compliance with these regulations is an increasingly important goal for the owner and operator of an energy production facility. Owners desire air quality compliance to strike a balance between operational flexibility, staff requirements, simplicity, economics, and positive relationships with regulatory agencies.

Our Approach

We provide air quality regulatory consulting services to the energy production industry by senior level, experienced engineers. While we know the regulations and requirements that apply to the energy production industry, being at an engineering firm we also understand how these facilities are designed and how the owner desires to operate them. Drawing on our lessons learned, we work with the owners as an extension of their staff to jointly permit and determine how to best comply with the regulatory and permit requirements.

Overview of Services

When it comes to energy production, air quality continues to be one of the top public concerns. This occurs despite significant decreases in emissions and improvements in monitored levels through the enactment of numerous laws and regulations specifically aimed at the energy production industry. Facility owners are not only responsible for current and future air quality compliance plans at existing facilities, owners must incorporate them into the design, permitting, and operation of proposed new or modified facilities.

The following list provides some common services we perform for the energy production industry:

New Source/Modification Permitting

  • Applicability determinations and netting analysis
  • New Source Review (NSR) / Prevention of Significant Deterioration (PSD) / New Source Performance Standard (NSPS) permitting
  • Input to facility design, layout, emissions, and schedule
  • Negotiations with agency staff
  • Title V (Operating Permit Program) permitting, renewal, and modification

Applicability, Compliance & Planning Studies

  • Ongoing operational compliance support
  • Future compliance planning for GHG, Transport Rule, MACT, NAAQS
  • Input to air quality control equipment feasibility and specification

Continuous Emissions Monitoring System (CEMS) and Testing Oversight

  • CEMs and stack testing oversight and contracting
  • CEMs and stack testing specification
  • Implementation of Low Mass Emitter (LME) alternative to CEMs
  • Acid Rain Monitoring Plans, QA/Certification, and quarterly emission submittals

MACT Compliance

  • Applicability assessment for boilers, turbines, and engines
  • Compliance planning and implementation
  • Diagnostic and compliance oversight