Carolinas Air Quality Updates

The Carolinas Air Pollution Control Association (CAPCA) hosted the 52^nd Annual Fall Technical Workshop and Forum on October 13-15, 2021 in Myrtle Beach, South Carolina.  ALL4 Carolinas staff were excited to participate in an in-person conference for the first time in quite a while.  As attendees arrived on Wednesday morning, they were immersed in a technical session on environmental control equipment or enjoying a round of golf.  The young professional committee hosted a lunch on Wednesday and a cornhole hour that evening, followed by dinner by the pool where we were able to connect with old friends and make some new ones. The main social event was on Thursday evening where conference attendees were transported back to their childhood, put on their Halloween costumes, and went trick-or-treating at each of the booths.  Only this time, those that found the special pieces of candy were entered into a drawing for two nights free stay at the Hilton.  We heard from the SC Attorney General Friday morning and closed out the conference with lunch and the annual business meeting.

The technical sessions included air program updates from the United States Environmental Protection Agency (U.S. EPA) Region IV, the South Carolina Department of Health and Environmental Control (SC DHEC) and the North Carolina Department of Environmental Quality (NC DEQ).  There were also sessions focused on public engagement, climate change, and sustainability. Technical session highlights are summarized below.

U.S. EPA Update

The U.S. EPA update was provided by Caroline Freeman, Director of the Air and Radiation Division in Region IV. The U.S. EPA is reconsidering the 2020 decision to retain the annual National Ambient Air Quality Standards (NAAQS) for Particulate Matter less than 2.5 micrometers in aerodynamic diameter (PM_2.5) of 12 micrograms per cubic meter and is evaluating whether the current standards are enough to protect public health based the latest available technical information. A proposed rule is anticipated in summer 2022 with a final rule in the spring of 2023. The agency notes that the reconsideration process will provide opportunities for public engagement and will also consider environmental justice (EJ).  If revised, the Clean Air Act (CAA) deadline for nonattainment designations would be no later than Spring 2025 and will be based on 2021-2023 or 2022-2024 monitoring data.

EJ continues to be a focus of the agency, with ongoing efforts to refine the objectives and strategies for incorporating EJ into rulemaking, permitting, and compliance. For permitting, the focus is on best practices for promoting meaningful engagement in communities and using developed tools to identify these communities of concern.  The agency also plans on implementing and enhancing rulemaking guidance for considering EJ during the development of regulatory actions.

Other highlights include withdrawal of the 2020 startup, shutdown, malfunction (SSM) policy and reinstating the 2015 policy (U.S. EPA will revisit the individual State Implementation Plan (SIP) actions in 2020 for Texas, North Carolina, and Iowa that withdrew the SSM SIP Calls), review of the ethylene oxide regulations, and continued research and development related to Per- and Polyfluoroalkyl Substances (PFAS).

SC DHEC Update

The SC DHEC update was provided by Rhonda Thompson, Chief of the Bureau of Air Quality (BAQ).  SC DHEC is preparing the draft Regional Haze SIP for public notice and is currently addressing comments from the federal land managers and U.S. EPA. Based on the level of public interest in other states, SC DHEC expects a high level of public engagement when the pre-hearing draft SIP is released to public notice.

SC DHEC is proposing to reorganize the permit division to transition from geographical sections to sector-based sections. The goal of the reorganization is to improve efficiency by increasing industry and facility knowledge of the permit writers and to increase consistency between permit decisions. Some facilities will receive a new permit writer as new applications are submitted and the timing is expected to align with the rollout of ePermitting for air permitting and compliance.  SC DHEC will be looking for stakeholders, targeted for late 2021/early 2022, to help test the ePermitting System prior to the external release.

NC DEQ Update

The NC DEQ update was provided by Mike Abraczinskas, Director of the Division of Air Quality (DAQ). North Carolina has achieved significant visibility improvements since 1998 and is ahead of the uniform rate of progress glidepath toward achieving natural conditions by 2064.  The pre-hearing draft Regional Haze SIP was posted to public notice on August 30, 2021 and the public comment period closed on October 15, 2021 following the virtual public hearing held on October 6, 2021.  NC DEQ will be reviewing and preparing a response to comments.

NC DEQ provided a status update on the Regional Greenhouse Gas Initiative (RGGI) following a vote to grant the petition for rulemaking by the NC Environmental Management Commission (EMC) on July 13, 2021.  The rulemaking process has commenced and NC DEQ is developing a fiscal analysis which will be followed by preparation of an EJ report and later a public comment process including a public hearing prior to final action by the EMC.

Greenhouse Gases and Sustainability

The audience heard from a variety of speakers discussing the science of greenhouse gases (GHG), anticipated climate impacts to the Carolinas, the impact of GHG regulations on stationary sources, and company specific sustainability programs and progress.  With a high focus on carbon policy under the current administration, it will be important for stakeholders to stay up to date on programs under consideration including establishing a Carbon Dioxide (CO₂) NAAQS (which has new source review (NSR) permitting implications), emission standards for methane sources, and state carbon tax or cap and trade programs (e.g., RGGI).  A few companies shared insights and progress in implementing their CO₂ reduction strategies based on classification of scopes 1, 2, or 3 emissions and plans for future reductions.

Public Participation

Another theme of the technical workshop was centered around increased public interest in environmental issues including providing comment on proposed environmental regulations and new or revised air quality permits.  Additionally, the volume of emissions data has increased via the availability and use of handheld ambient sensors. The U.S. EPA, the state agencies, and other partners including sensor manufactures are working together to deliver high quality information to the public and to clarify results via the Air Quality Information Exchange Workgroup.  Questions have increased from the public related to interpreting different air quality results collected in the same location and time.  It is recognized that air quality products should provide clear information on what the data represents and the level of data quality as results from sensors will differ from air regulatory monitors which, unlike many sensors, are driven by NAAQS and have heavily regulated quality assurance and control procedures. The U.S. EPA and state agencies continue to emphasize the importance of community outreach as well as engaging the public at the beginning of projects requiring air permitting.

We look forward to seeing you all for the Spring 2022 event in Asheville, NC! If you have questions regarding air permitting and compliance in North or South Carolina or the issues mentioned here, please reach out to Claire Corta at ccorta@all4inc.com or 919-578-4195.