Air Quality Permitting Air Quality Committee William D

Air Quality Permitting Air Quality Committee William D. Willets, P. E. Engineering Supervisor DAQ Permitting Section May 7, 2014 1 2/20/2021

Do I need a permit? l Yes – By statute, codified under … – Title 15 A NCAC Subchapter 2 Q. 0101 l l (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 15 A NCAC 2 Q. 0102 l Currently undergoing revision for clarification and simplification 2

What kinds of permits are there in NC? l Construction Permits – State pre-construction – PSD/NSR permits l Operating Permits – State permits – Title V permits l l Developed under the federal 1990 CAAA to consolidate all applicable requirements into a single compliance tool Construction/Operating Permits – “Traditional” combination of the above l Air toxics permits – Not exclusive of other permitting programs 3

What’s in a permit? l Applicable requirements – State enforceable, federally enforceable, both – Construction and operation l Means to demonstrate compliance with applicable requirements – Monitoring, recordkeeping, and reporting requirements l General conditions 4

What can I do without a permit? 2 Q. 0102 activities l Basic earth work (clearing and grubbing) l NC construction bill l – Notification – Public notice – Fee 5

How do I get a permit? l Procedures in 15 A NCAC 2 Q. 0300 and. 0500 – Subchapters designate permitting procedures based on State or Title V processes – PSD/NSR procedures also in 2 D. 0530/. 0531 l l l Permit application submittal Completeness review Engineer review – May include requests for additional information l l Public/EPA participation Final agency action – Issue or deny permit 6

How do I know what kind of permit to get? Construction and operation permit(s) l Operating permit l Type of facility l Potential to emit regulated air pollutants l 7

Potential to Emit l l l Maximum capacity Physical and operational design Physical or operational limitation Air pollution control equipment Restrictions Definable by the permit 8

Major Source Thresholds l PSD – 250 tpy or 100 tpy – Depends on source type – Lower thresholds for modifications l NAA – 100 tpy l Title V – 100 tpy – 10/25 tpy 9

Small Facilities Unrestricted PTE below all major source thresholds l State (2 Q. 0300) construction and operation permit l Administered by Regional Office l 10

Synthetic Minor Facilities Permit restrictions (including control devices) to maintain PTE below all major source thresholds l State (2 Q. 0300) construction and operation permit l Administered by Regional Office l 11

Non-PSD/NSR Major Facilities Title V facilities l Permitted PTE above one or more Title V major source thresholds l State (2 Q. 0300) construction and operation permit l Title V operation permit (2 Q. 0500) l Administered by Central Office l 12

PSD/NSR Major Facilities Also Title V facilities l Permitted PTE above one or more PSD/NSR major source thresholds l PSD (2 D. 0530/. 0531) construction permit l State pre-construction permit l Title V operation permit l Administered by Central Office l 13

Permit Modifications Depends on type of permit and scope of modification l Non-Title V modifications administered by Regional Office l Title V and PSD/NSR modifications administered by Central Office l 14

Air Toxics Permits Coupled with other permitting programs l Procedures under 2 Q. 0700 l Air toxics rules have recently been revised (effective May 1, 2014) in accordance with State statute l 15

Permitting Section Emerging Issues Revisions to 02 Q. 0102 permitting exemptions l Recent revisions to Toxic Air Pollutant regulations l Ongoing incorporation of MACTs/GACTs into permits l 16

Questions? 17