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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

Air Quality Permitting

Air Quality Committee

William D. Willets, P.E.

Engineering Supervisor

DAQ Permitting Section

May 7, 2014


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


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


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 requirements

  • General conditions


What can i do without a permit
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
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
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
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
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


Small facilities
Small Facilities

  • Unrestricted PTE below all major source thresholds

  • State (2Q .0300) construction and operation permit

  • Administered by Regional Office


Synthetic minor facilities
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
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
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
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
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
Permitting Section Emerging Issues

  • Revisions to 02Q .0102 permitting exemptions

  • Recent revisions to Toxic Air Pollutant regulations

  • Ongoing incorporation of MACTs/GACTs into permits



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