1. AIR CONSULTING QUALIFICATIONS
Air Permitting Qualifications
Burns & McDonnell has an experienced, full service air permitting division. Our air compliance services have
included in-depth regulatory analyses and permit application preparation, development of facility-based emissions
calculations and overall compliance reviews, and implementation of environmental management and data
collection/tracking systems. Burns & McDonnell assists clients in meeting air regulatory requirements with a full
complement of scientific and engineering disciplines backing our air quality professionals. This unique combination
of technical experience and regulatory knowledge has assisted numerous industrial, commercial and governmental
clients, especially those within the aerospace and general manufacturing arenas.
Our team has assisted numerous clients through the permitting process for new projects or facility modifications in
orderto help thefacilitymaintain annual compliance. Forming a cohesive partnership for such projects has offered
such outcomes to:
• Redirect resources from environmental requirements to production
• Recognize and proactively address environmental challenges before they happen
• Reduce therisk of potential fines and penalties
• Comply with less cost and effort
• Meet reporting deadlines
• Keep up with environmental requirements
• Improve public perception of the facility
Our staff has over 100 years of combined experience in preparing permit applications, helping clients comply
with regulations, performing air regulatory assessments, and many other air permitting tasks. We excel by fully
understanding the rules and regulations that apply to air emissions.
Industry Experience
Our air quality team members are experienced in a multitude of industries and facilities, including but not limited
to:
• General Manufacturing • Steel Production
• Paints and Coatings • Rendering
• Surface Coating • Secondary Aluminum Processing
• Printing Facilities • Metals Scrap Production/Handling
• Printing/Graphic Arts • Petroleum Retail Marketing
• Landscaping/Materials Processing • Telecommunications
• Chemical • Power Generation
• Asphalt • Boilers
• Cement/Aggregate • Mobil Source Emissions
• Engines • Highway/Traffic
• Automotive Parts • Ethanol Plants
• Grain Processing • Natural Gas Storage and Transmission
• Injection Molding • Water and Wastewater Utilities
• Leather Processing • Landscaping/Materials Processing
• Aerospace Manufacturing • Military Installations

2. AIR CONSULTING QUALIFICATIONS
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Specifically within the aircraft/aerospace manufacturing area, Burns & McDonnell has assisted with various
engineering projects and facility air compliance needs, such as the following:
• Aircraft manufacturing
o Commercial airlines
o Helicopter manufacturers
o Private aircraft manufacturers
• Depart of Defense aerospace manufacturing and maintenance
o Military aircrafts
o Space vehicles
o Satellites
• Commercial airlines airport operating stations
• Aircraft supplier manufacturing
• Parts manufacturers
• Feeder plants
• Research and Development laboratories
Air Quality Services
Burns & McDonnell provides a full range of air permitting and compliance services, with experience with various
environmental statutes and regulations, and in development of numerous permit applications and permits under
federal, state and local regulatory requirements and permit structures, such as:
• Clean Air Act Permit Program (CAAPP/Title V)
• Federally Enforceable State Operating Permit (FESOP) programs
• State construction/operating permit programs
• Development of potential to emit (PTE) emissions summaries, alternate scenarios
• Determination of controls and emissions under the National Emission Standards for Hazardous Air
Pollutants (NESHAP) program
• New Source Performance Standards (NSPS) regulations
• New Source Review (NSR)
• Prevention of Significant Deterioration (PSD) and PSD avoidance
• Dispersion modeling of anticipated or actual emissions, including visibility modeling
• Best available control technology (BACT) analyses
• Lowest Available Emission Rate (LAER) review and analysis
• Emission Reduction Credit (ERC) negotiation and trading
• Volatile Organic Compound (VOC) control design, redesign, alternative abatement system analysis
• Acid rain permits and monitoring plans (Title IV of the Clean Air Act)
• Compliance Assurance Monitoring (CAM)
• Emission source testing/stack testing
• Historical audits and assistance with Notice of Violation (NOV) and Section 114 requests, responses
• Risk Management Plans (RMP) and Process Safety Management (PSM), including Process

3. AIR CONSULTING QUALIFICATIONS
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Hazard Assessments (PHAs)
• Toxics release inventory (TRI, Tier II/III, SARA) reporting
• Compliance audits
• Emissions inventories
• General regulatory compliance (e.g., RCRA, EPCRA, SPCC, SWPPP, PSM, REACH, etc.)
• Regulatory interpretations and compliance evaluations
• Custom database development for tracking emissions or compliance demonstration
• Client Advocacy and Regulatory Negotiations
• Six Sigma, Root Cause Analysis and Corrective Action Plans
Permitting
Burns & McDonnell has assisted corporate and facility personnel with review and modification of numerous
construction and operating permits, such as major source NSR/PSD and Title V permits. Our experience ranges
from documenting state permitting exemptions to complex PSD and NSR permits. Analyses required review of
current manufacturing and processing activities, material safety data sheets (MSDS) and facility-based operating
parameters. Potential regulatory requirements and emissions scenarios were reviewed with facility staff and state
agency personnel, as necessary, to secure operational flexibility for the respective facilities.
In support of such permitting, potential and actual emissions calculations and analyses were performed, with state
and federal rules being reviewed to assess potential applicability. Various NESHAP and NSPS standards were
reviewed in conjunction with actual and potential hazardous air pollutant (HAP) emissions. Such assistance
included, when necessary, preparation of successful technology-based BACT demonstrations and emissions
modeling analyses, review and assessment of LAER control technologies, and procurement of VOC emissions
offsets as dictated under the NSR regulations. All of which resulted in issuance of flexible permits and regulatory
conditions to support each facility’s needs.
Based on our broad experience and industry knowledge, our air compliance team can assist in addressing the variety
of challenges the air regulatory and permitting requirements may present to your facility and its operations.
Burns & McDonnell’s experience has included preparation of numerous construction and operating permit
applications for a variety of industries, including Title V/CAAPP, FESOP, and state construction/operating permit
applications. Such permitting projects have included development of permits and associated conditions for
facilities in conjunction with state and local governmental bodies, as well as the USEPA. Such permitting
exercises have included regulatory review and assessment, emissions inventory development and compliance‐
related document preparation. As part of each permitting project, Burns & McDonnell combines its industry
knowledge with site‐specific information to properly characterize emissions, and to develop site‐specific emissions
factors. Various tasks have included:
• Appropriateidentification and characterization of plant emission units and/or processes
• Review of material usages and technical data to ensure criteria pollutants and waste streams are properly
identified
• Development of process knowledge to assist in evaluation of facility operations and in

4. AIR CONSULTING QUALIFICATIONS
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determination of optimum compliance alternatives
• Review of historical production and equipment emissions levels for development of facility emissions
summaries and assessmentof potential NSR/PSD applicability.
Burns & McDonnell has assisted with Title V permit application preparation, including amendments and renewals.
Burns & McDonnell has worked with facilities and state agency representatives to ensure the appropriate
paperwork and equipment information was on file with the Agency to reflect appropriate equipment replacements
and operational changes. Such projects have included emissions review and regulatory assessment to address
equipment modifications, as well as facility process changes and material substitutions. In conjunction with
such permitting projects, Burns & McDonnell has prepared, reviewed and submitted associated annual emission
reports (AERs), semi‐annual monitoring reports, seasonal Emission Reduction Market System reports, and
compliance certifications for the Title V facilities as required by the facility’s permit. The preparation of
these reports has included in‐depth review of state and federal regulations, calculation of emissions of criteria
pollutants, and determination of facility compliance status. After the permit is issued, our compliance management
tools will simplify your compliance burden.
NESHAP
Our air quality professionals also have assisted clients in tracking regulatory developments and in determining
regulatory applicability of specific state and federal regulations on facility operations. Conditions of various
NESHAPs and NSP), as well as state regulatory requirements, were reviewed to determine potential regulatory
implications on facility operations and to develop possible alternate operating scenarios to avoid triggering such
regulatory requirements. Project management and experience with various NESHAP, NSPS and state/federal
regulatory programs, such as rules applicable to the aerospace industry, also have included assisting with
preparation of requisite notification and compliance filings, development and implementation of regulatory driven
monitoring programs, establishing comprehensive regulatory compliance manuals, (i.e., Operations and Maintenance
[O&M] Plans; Startup, Shutdown and Malfunction (SSM)Plans, and preparing recordkeeping/reporting proceduresand
methodologies.
Dispersion Modeling
Burns & McDonnell has extensive experience in air dispersion modeling and is considered a leader in the field.
Our modeling experts have a combined modeling experience of 53 years. They use stationary and mobile source
models to determine a project’s impact on National Ambient Air Quality Standards and PSD increments.
Our modelers have worked in each of USEPA’s 10 regions on hundreds of different modeling projects, from fatal
flaw analyses and siting studies to PSD applications. Numerous project challenges have been overcome by our
modelers, such as redesigning new facilities to minimize the impact on ambient air and determining cost-effective
modifications to existing facilities located in increment limited areas. Our modeling experience includes
proficiencyin:
• CALPUFF (CALMET, CALPOST, POST UTIL, CALPUFF)
• AERMOD (AERMET, AERSURFACE, AERMAP)

5. AIR CONSULTING QUALIFICATIONS
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• MOVES
• MOBILE5
• SCREEN3
• VISCREEN
• ISC3
• Water8
Air Pollution Control Technology Analyses
Often the most contentious aspect of a PSD or NSR application is the BACT analysis. Burns & McDonnell stays
on top of the constantly shifting level of BACT for multiple industries. Our experience with control technologies
is unparalleled. Our experts have determined and defended BACT in numerous states and USEPA regions. From
permitting to design of the selected controls, we have the staff to meet your needs. We are very well experienced
with USEPA’s top-down BACT protocol and understand what is required by USEPA to accept such a detailed
analysis.
Ambient Air Monitoring
Burns & McDonnell performs ambient air monitoring in support of PSD permits and remediation actions. The
monitoring uses U S EPA- approved continuous PM10, SO2, ozone and meteorological systems to help
demonstrate the projects will not produce unhealthy amounts of emissions. An ambient air monitoring system
begins with approval of a Quality Assurance Project Plan (QAPP). A QAPP describes the siting, monitoring
equipment, maintenance and reporting. A typical monitoring site includes monitoring equipment, dataloggers,
communication devices, and a shelter. Each monitor must be sited to gain approval from state regulators, as well
as be accessible to electricity and communication links.
Recordkeeping and Compliance Support
Burns & McDonnell has prepared recordkeeping/compliance summary documents and web-based solutions to assist
facility personnel in tracking process-based material usages and calculating monthly/annual emissions pursuant to
air permit requirements. Such documentation and operational tools have allowed facility staff to address and
maintain compliance with state/federal permit conditions and limitations efficiently and effectively, and provide a
solid foundation for preparing and filing ongoing compliance reports and certifications.
Ongoing compliance assistance also has included preparing upgrades to facility recordkeeping documentation and
emission-based summaries, and tracking and identifying potential regulatory concerns due to material substitutions,
process changes and/or new regulations. In assessing product and/or material changes, Burns & McDonnell staff
has reviewed current and proposed regulatory standards, such as state/federal technology-based requirements,
NESHAP rules (area and major source), NSPS, and consumer product-based regulations, to determine applicability
to current or proposed facility operations and production activities. Review and explanation of such regulatory
standards has allowed our air team members to assist corporate and facility personnel with internal compliance
analyses and determinations, which in turn, have led to more cost-effective process expansions and overall facility
management.

6. AIR CONSULTING QUALIFICATIONS
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Compliance Reporting
Burns & McDonnell also can assist facility personnel in filing seasonal and annual emissions, Tier II and Toxics
Release Inventory (TRI) (i.e., Form R) reports using state/federal forms and web-based submission sites. Ongoing
compliance assistance includes upgrades to facility recordkeeping documentation, maintenance of current MSDS
information and chemical inventory data, and identification of any potential regulatory concerns due to material
substitutions and/or process changes. In assessing product and/or material changes, Burns & McDonnell staff
reviews current and proposed regulatory standards for changes to the state and federal reporting requirements in
tracking and reporting hazardous chemicals.
Ongoing Compliance Management
Burns & McDonnell has developed custom environmental compliance management manuals to aid plant managers
and operators comply with the myriad of environmental regulations. The manual is written to use on a day to day
basis, explains environmental concepts in practical terms, and is intended to serve as a quick reference. The
manual covers federal and state requirements, and provides samples of many of the required reports.
When a manual is finalized, our staff again visits the facility and presents customized training sessions to the facility.
The training covers the manual and general environmental concepts. The goal of the training is to provide
knowledge to the people actually operating the equipment and those managers responsible for compliance. These
one to three hour sessions are designed to maximize retention of the compliance management techniques needed on
a daily basis.
Risk Management Plans
Burns & McDonnell established a Risk Management Planning (RMP) Team shortly after the regulation was
passed in order to provide RMP services to our affected clients. The team has held training sessions for industrial
clients in several states. RMPs have been developed for water and wastewater utilities, electric utilities, propane
storage facilities, and multiple manufacturing entities. Burns & McDonnell's RMP team provides facilitators for
process hazard assessments who lead the industry RMP program teams through detailed analyses using "What If",
Question and Answer, Check List or other approved methods. Complete RMP plans are compiled and the federal
submittals are prepared as required. The Burns & McDonnell RMP team can provide assistance with the
development of standard operating procedures, employee training and programaudits for a specific facility or
facilities nationwide to maintain consistency with corporate practices and guidelines.
Audits/Section 114 Requests
In addition to ongoing compliance-related activities, Burns & McDonnell also can review existing regulations to
ensure the facility is aware of its requirements and i s o p e r a t i n g in compliance with applicable standards. Our
team recently has assisted many i n d u s t r ia l -b a se d c li e n t s a nd coal-fired power plant utilities with
Section 114 requests and responses. Assistance includes helping the facilities and clients with preparation of the
proper responses based on identified potential issues and infinalizingsuch informationrequired to be provided to the
USEPA.

7. AIR CONSULTING QUALIFICATIONS
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Regulatory Interpretations
Whether for an active project or a core client, our regulatory experts can assist with ongoing review and
analysis of new and /or revised regulations to determine if such rules apply to a specific facility or
process, and if so, what impact the available compliance options will have on your operations. This is especially
important now with the NAAQS being continually lowered, and new air regulations – especially NESHAPs –
being issued daily by the USEPA.
Toxics
As with BACT, maximum achievable control technology (MACT) case-by-case determinations are often
controversial. Our team has in-depth project experience in calculating and controlling toxic emissions from
coating operations, manufacturing, and various industries and processes. We also are up-to-date with the status of
impending new NESHAPs for industries, including those potentially impacting the aerospace sector.
Emissions/Stack Testing
The breadth of our air compliance support also has included providing emissions testing services and oversight for a
variety of industries. Whether it be continuous monitoring, annual compliance testing, performance testing and
analysis, or preparation and implementation of engineering studies needed to support proposed process or facility
expansions, our emissions testing experts provide the background and knowledge of USEPA and state-based testing
programs to provide the support needed in addressing facility concerns and implementing the correct emissions
testing program.