Air Quality Permitting
Air Quality Committee
William D. Willets, P.E.
Engineering Supervisor
DAQ Permitting Section
May 7, 2014
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4/13/2015
Do I need a permit?
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Yes
– By statute, codified under …
– Title 15A NCAC Subchapter 2Q .0101
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(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
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Currently undergoing revision for clarification and
simplification
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What kinds of permits are there in NC?
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Construction Permits
– State pre-construction
– PSD/NSR permits
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Operating Permits
– State permits
– Title V permits
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Developed under the federal 1990 CAAA to consolidate all
applicable requirements into a single compliance tool
Construction/Operating Permits
– “Traditional” combination of the above
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Air toxics permits
– Not exclusive of other permitting programs
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What’s in a permit?
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Applicable requirements
– State enforceable, federally enforceable, both
– Construction and operation
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Means to demonstrate compliance with
applicable requirements
– Monitoring, recordkeeping, and reporting
requirements
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General conditions
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What can I do without a permit?
2Q .0102 activities
 Basic earth work (clearing and grubbing)
 NC construction bill
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– Notification
– Public notice
– Fee
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How do I get a permit?
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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
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Permit application submittal
Completeness review
Engineer review
– May include requests for additional information
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Public/EPA participation
Final agency action
– Issue or deny permit
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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
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Potential to Emit
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Maximum capacity
Physical and operational design
Physical or operational limitation
Air pollution control equipment
Restrictions
Definable by the permit
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Major Source Thresholds
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PSD
– 250 tpy or 100 tpy
– Depends on source type
– Lower thresholds for modifications
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NAA
– 100 tpy
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Title V
– 100 tpy
– 10/25 tpy
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Small Facilities
Unrestricted PTE below all major source
thresholds
 State (2Q .0300) construction and
operation permit
 Administered by Regional Office
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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
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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
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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
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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
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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
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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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Questions?
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