04/22/231

Air Quality PermittingAir Quality Permitting

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

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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

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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

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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

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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

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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

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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

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Potential to EmitPotential to Emit

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

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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

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Small FacilitiesSmall Facilities

Unrestricted PTE below all major source thresholds

State (2Q .0300) construction and operation permit

Administered by Regional Office

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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

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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

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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

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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

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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

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

exemptionsRecent revisions to Toxic Air Pollutant

regulationsOngoing incorporation of MACTs/GACTs

into permits

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Questions?Questions?