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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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