Recap of the CAPCA 2023 Spring Technical Workshop and Forum
Posted: May 17th, 2023
Authors: Claire C.
A long time ago in a galaxy far, far away Darth Vader, C-3PO, R2-D2, Chewbacca, and the Mandalorian attended the Carolinas Air Pollution Control Association (CAPCA) technical workshop and forum. This unexpected band of Star Wars visitors enjoyed the space-themed exhibitors social on Thursday night and the technical sessions, including but not limited to a regulatory update from the United States Environmental Protection Agency (U.S. EPA) and a fireside chat with the air directors from South Carolina Department of Health and Environmental Control (SC DHEC) and the North Carolina Department of Environmental Quality (NC DEQ). The galactic travelers learned about a variety of technical topics and heard the latest air permitting and compliance news. Highlights of air regulatory changes on the horizon are below.
PM2.5 NAAQS
The comment period closed on March 28, 2023 on the proposed changes to the particulate matter of less than 2.5 microns (PM2.5) National Ambient Air Quality Standard (NAAQS). Comments were requested on a range of 8 ug/m3 to 11 ug/m3 for the annual standard. As we anxiously wait to learn where the standard will be set, the presenters reviewed limitations of the current air dispersion models and guidelines and suggested improvements and strategies for dealing with a lower NAAQS. Multiple layers of conservatism are built into the models and guidelines and with a lower standard these conservative elements cause increased difficulty with modeling demonstrations. Emissions factor refinement and working closely with the state agencies will be key for upcoming air permitting projects.
Electronic Permitting and Reporting
SC DHEC is internally testing the ePermitting system under the air quality program and is closer to taking the program live externally. Electronic submittal of compliance reports and air permit applications will be available and the system will provide notifications when items are due.
NC DEQ is currently working on a permitting transformation project. The air program is expected to be the last one implemented due to complexity; however, NC Division of Air Quality’s (DAQ) Electronic Public Records Management System (Laserfiche) is now available, making public records more accessible.
Minor New Source Review
U.S. EPA has been evaluating the sufficiency of state implementation plan minor New Source Review (NSR) programs with the focus on public noticing procedures and if permitting procedures are protective of the NAAQS. Currently NC DEQ does not require NAAQS modeling for minor NSR air permit applications. SC DHEC requires criteria pollutant modeling under Regulation 61-62.5, Standard No. 2 but allows modeling exemptions and deferrals under the current “Modeling Guidelines for Air Quality Permits.” At this time, it is unknown how either program will be impacted. U.S. EPA anticipates a notice of proposed rulemaking later this year.
“Once In, Always In”
U.S. EPA withdrew the “once in, always in” policy and promulgated the Major MACT to Area Source (MM2A) rule on January 19, 2021. This rule allows facilities that emit hazardous air pollutants and were previously classified as major sources to be reclassified as area sources when the facility’s potential to emit is limited to below major source thresholds. Details of the rule changes expected to be proposed this summer were not shared; however, possible recission of the MM2A rule and reinstatement of the “once in, always in” policy is a concern.
ALL4 is tracking regulatory developments on these topics and looks forward to seeing you in the fall at the CAPCA technical workshop and forum in Myrtle Beach, SC! We’ll put our space outfits away and get out the tailgating gear. If you have questions about how these regulatory changes might affect you or need help with air permitting and compliance in North or South Carolina, please reach out to Claire Corta at ccorta@all4inc.com or 919-578-4195.
