Air Quality Permitting

04/22/231

Air Quality PermittingAir Quality Permitting

Air Quality CommitteeWilliam D. Willets, P.E.Engineering SupervisorDAQ Permitting SectionMay 7, 2014

2

Do I need a permit?Do I need a permit?

Yes– By statute, codified under …– Title 15A NCAC Subchapter 2Q .0101

(a) No owner or operator shall do any of the following activities … without first applying for and obtaining an air quality permit …

Unless you don’t– Exemptions under 15A NCAC 2Q .0102

Currently undergoing revision for clarification and simplification

3

What kinds of permits are there in NC?What kinds of permits are there in NC? Construction Permits

– State pre-construction– PSD/NSR permits

Operating Permits– State permits– Title V permits

Developed under the federal 1990 CAAA to consolidate all applicable requirements into a single compliance tool

Construction/Operating Permits– “Traditional” combination of the above

Air toxics permits– Not exclusive of other permitting programs

4

What’s in a permit?What’s in a permit?

Applicable requirements– State enforceable, federally enforceable, both– Construction and operation

Means to demonstrate compliance with applicable requirements– Monitoring, recordkeeping, and reporting

requirementsGeneral conditions

5

What can I do without a permit?What can I do without a permit?

2Q .0102 activitiesBasic earth work (clearing and grubbing)NC construction bill

– Notification– Public notice– Fee

6

How do I get a permit?How do I get a permit?

Procedures in 15A NCAC 2Q .0300 and .0500– Subchapters designate permitting procedures based on

State or Title V processes– PSD/NSR procedures also in 2D .0530/.0531

Permit application submittal Completeness review Engineer review

– May include requests for additional information Public/EPA participation Final agency action

– Issue or deny permit

7

How do I know what kind of permit to get?How do I know what kind of permit to get?

Construction and operation permit(s)Operating permitType of facilityPotential to emit regulated air pollutants

8

Potential to EmitPotential to Emit

Maximum capacity Physical and operational design Physical or operational limitation Air pollution control equipment Restrictions Definable by the permit

9

Major Source ThresholdsMajor Source Thresholds

PSD

– 250 tpy or 100 tpy

– Depends on source type

– Lower thresholds for modifications NAA

– 100 tpy Title V

– 100 tpy

– 10/25 tpy

10

Small FacilitiesSmall Facilities

Unrestricted PTE below all major source thresholds

State (2Q .0300) construction and operation permit

Administered by Regional Office

11

Synthetic Minor FacilitiesSynthetic Minor Facilities

Permit restrictions (including control devices) to maintain PTE below all major source thresholds

State (2Q .0300) construction and operation permit

Administered by Regional Office

12

Non-PSD/NSR Major FacilitiesNon-PSD/NSR Major Facilities

Title V facilitiesPermitted PTE above one or more Title V

major source thresholdsState (2Q .0300) construction and

operation permitTitle V operation permit (2Q .0500) Administered by Central Office

13

PSD/NSR Major FacilitiesPSD/NSR Major Facilities

Also Title V facilitiesPermitted PTE above one or more

PSD/NSR major source thresholdsPSD (2D .0530/.0531) construction permitState pre-construction permitTitle V operation permitAdministered by Central Office

14

Permit ModificationsPermit Modifications

Depends on type of permit and scope of modification

Non-Title V modifications administered by Regional Office

Title V and PSD/NSR modifications administered by Central Office

15

Air Toxics PermitsAir Toxics PermitsCoupled with other permitting programsProcedures under 2Q .0700Air toxics rules have recently been revised

(effective May 1, 2014) in accordance with State statute

16

Permitting Section Emerging Permitting Section Emerging IssuesIssuesRevisions to 02Q .0102 permitting

exemptionsRecent revisions to Toxic Air Pollutant

regulationsOngoing incorporation of MACTs/GACTs

into permits

17

Questions?Questions?