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

2. 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

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 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
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 permitting exemptions
Recent revisions to Toxic Air Pollutant regulations
Ongoing incorporation of MACTs/GACTs into permits

17. Questions?