For an asphalt client, Barr performed a stationary-source determination to ascertain whether two facilities located on the same property should, for air permitting purposes, be considered a single source.
The two facilities had previously been owned and operated by the same company and covered under a single permit, but now a portion of the facility, including one emission source, was leased by a new operator.
After considering all relevant factors in state and U.S. EPA guidance, Barr concluded that for air permitting applicability, the portion of the facility leased by the new operator should be considered a separate stationary source.