Air Quality Permitting Air Quality Committee William D. Willets, P.E. Engineering Supervisor DAQ Permitting Section May 7, 2014 5/21/2019

Do I need a permit? Yes Unless you don’t 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

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

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 requirements General conditions

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

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

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

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

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

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

Synthetic 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

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

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

Permit 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

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

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

Questions?