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Air Quality Permitting

Air Quality Permitting. Air Quality Committee William D. Willets, P.E. Engineering Supervisor DAQ Permitting Section May 7, 2014. Do I need a permit?. Yes By statute, codified under … Title 15A NCAC Subchapter 2Q .0101

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Air Quality Permitting

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

  2. 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? • 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? • Applicable requirements • State enforceable, federally enforceable, both • Construction and operation • Means to demonstrate compliance with applicable requirements • Monitoring, recordkeeping, and reporting requirements • General conditions

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

  6. 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? • Construction and operation permit(s) • Operating permit • Type of facility • Potential to emit regulated air pollutants

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

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

  11. 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

  12. 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

  13. 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

  14. 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

  15. 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

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

  17. Questions?

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