Air Quality Permitting in North Carolina

The most recent change to the 1970 Clean Air Act was the 1990 Clean Air Act Amendments. These amendments created a comprehensive Title V operating permit program for the major sources of air pollutants, created an acid rain program to control sulfur dioxide and nitrogen oxides emissions from power plants, and identified 189 new hazardous air pollutants for future standards development.

Generally, all facilities in North Carolina that generate air pollution are required to have an air quality permit unless specifically exempted by the regulations. In North Carolina, air pollution control requirements and air quality permit requirements for stationary (paint spray booths, metal degreasers, boilers, etc.) and mobile sources (cars, trucks, aircraft) are codified in Title 15A, Subchapters 2D, 2H, and 2Q of the North Carolina Administrative Code. This also includes the Title V operating permit rule in 2Q.0500. The North Carolina Division of Air Quality (DAQ) issues one type of permit that addresses both the construction and operation requirements (2Q.0300). [To download specific regulations, visit the Division of Air Quality.] However, there are three different categories of permitted facilities based upon emission thresholds.

1. Title V: A facility has the potential to emit 100 tons or more per year of a common regulated pollutant, 10 tons or more per year of any hazardous air pollutant, or 25 tons or more per year of combined hazardous air pollutants.

2. Synthetic Minor: A facility takes action to ensure emissions remain below Title V thresholds. The facility’s permit obligates it to maintain these lower levels of emissions.

3. Small: A facility has no potential for exceeding Title V emission thresholds.

Common Questions About Permitting

• completed applicable forms
• appropriate fees
• zoning consistency determination
• process flow diagram
• detailed calculations
• supporting documentation showing the use of emission factors
• material balances
• control efficiencies
• professional engineering seal, if required

• Three copies each:
  1. Construction and operation permit
  2. Transportation facility permit
• Six copies each:
  1. Prevention of significant deterioration (PSD)
  2. National Emissions Standards for Hazardous Air Pollutant (NESHAP) permits
  3. Air toxic permits
• Two copies:
  1. Name change and renewals
• Six copies plus one each for affected states:
  1. Title V permit involving PSD, NESHAP’s, and air toxic issues
• Four copies plus one each for affected states:
  1. Title V permit not involving PSD, NESHAP’s, and air toxic issues

See DENR regional offices map and the next story, Common Violations Found During an Air Inspection.

Common Violations Found During an Air Inspection

Two of the most common violations found during an air inspection are:

1. Inadequate reporting and record-keeping — for example, failure to record daily operational hours of boiler, failure to perform daily calculations of photochemically reactive volatile organic compound (VOC) emissions. The permit specifies the types and frequency of data collection, emission calculations, monitoring of operational parameters for sources and control devices, and reporting requirements.
2. Maintenance violations — for example, holes in duct work of control devices, missing bags on bag filters. The permit specifies the type and frequency of inspection and maintenance requirements for control devices.

It is important that records are carefully kept to document emissions. This not only satisfies the permit requirement, but it also may be helpful to qualify for exemptions and to certify compliance. Proper equipment maintenance and operation can improve operational efficiency, prolong equipment life, and improve the cost-effectiveness of the process.