March 14 and 21, 2017
NCMA Workshops
Management and Regulation of Volatile Organic
Compounds (VOC) in North Carolina
Department of Environmental Quality
Overview
• VOC Regulation Background
• DAQ VOC Rules
• Existing 2D .0958 Rule
• Review/Revision
• Permittee Implications
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VOC Regulation Background
• “Clean Air Act National Ambient Air Quality Standards (NAAQs)
• Criteria Pollutants:
•
•
•
•
•
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Particulate Matter (PM)
Ozone (O3)
Sulfur Dioxide (SO2)
Nitrogen Dioxide (NO2)
Carbon Monoxide (CO)
Lead
• State submits implementation plan to demonstrate attainment with
NAAQS
• 15A NCAC 2D and 2Q Rules part of implementation plant to
achieve attainment
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VOC Regulation Background
• Ozone Formation
• Complex photochemistry
• Volatile Organic
Compounds + NOX +
Sunlight = O3
• Ozone NAAQ regulation
refers to tropospheric
ozone formation
• Typically a concern in
warmer months
• EPA’s “Ozone Season,”
when DAQ Monitors
ozone is from March 1October 31
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VOC Regulation Background
• Ozone NAAQ
• 70 parts per billion (ppb)
• 2015 Standard
• 8 hour average
• 3 year average taken to
make ozone “design
value” for attainment
designation
• North Carolina currently
demonstrating
compliance with standard
according to preliminary
2014-2016 data
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VOC Regulation Background
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DAQ Rules
• DAQ addresses Ozone NAAQ attainment through rules for:
• VOC Emissions- 15A NCAC 2D .0900
• NOX Emissions- 15A NCAC 2D .1400
• 2D .0900 Rules:
• Some of these rules apply statewide
• The remainder of these rules apply to facilities with potential to emit (PTE) 100
tons or more of VOC per year AND to facilities with PTE of less than 100 tons
per year VOC located in the maintenance are for the 1997 8-hour ozone
standard. These counties/areas are:
• Cabarrus County;
• Gaston County;
• Lincoln County;
• Mecklenburg County;
• Rowan County;
• Union County; and
• Davidson Township and Coddle Creek Township in Iredell County.
• These rules establish Reasonably Available Control Technology (RACT) based
on EPA Control Technique Guidelines (CTG)
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Existing 2D .0958 Rule
• Work Practices for Sources of Volatile Organic
Compounds History
• Current rule replaced original VOC rule effective July 1, 2000.
• Amended effective September 1, 2010, to apply regardless of emission
level.
• Establishes work practice standards for facilities that use volatile
organic compounds as:
• Solvents
• Carriers
• Material processing media
• Industrial chemical reactants,
• Other similar uses
OR Facilities that:
• Mix, blend, or manufacture volatile organic compounds OR
• Emit volatile organic compounds as a product of chemical
reactions.
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Excising 2D .0958 Rule
• Rule Summary:
• Store VOC containing materials (including waste material) in
containers covered with a tightly fitting lid when not in use.
• Clean up spills as soon as possible
• Store wipe rags in closed containers
• Solvent cleaning:
• Drain used solvents into closable containers and close immediately.
• Close mixing/blending vats prior to agitating cleaning solvents and
drain solvent into a closed container
• Part Cleaning Guidelines:
• Flush parts in the freeboard area
• Reduce pooling of solvents
• Rotate parts to drain solvent and allow 15 seconds of drying time or
until dripping has stopped
• Do not fill cleaning machines above fill lines
• Do not agitate solvent to the point causing splashing
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DAQ Rule Review
• NCGS 150B-19.1(b) directs agencies to
conduct an annual reviews to identify existing
unnecessary rules.
• In this process DAQ identified 2D .0958 as a candidate for
revisions based on these requirements.
• Ozone formation in North Carolina is NOX limited
• Meaning, Ozone formation in NC is limited by the availability of
NOX, rather than VOCs.
• Background VOC emissions occur in NC from tress and other
vegetative sources.
• Biogenic (natural) VOC emissions make up approximately 90%
of total VOC emissions statewide.
• Supported by study published in the Journal of Environmental
Management
• Bottom line: In NC, controlling NOX emissions is a far more
effective tool for reducing Ozone levels than controlling VOC
emissions.
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DAQ Rule Revision
• 2Q .0902- “Applicability” amended effective 11/1/2016 to limit
applicability of 2D .0958 from statewide to the maintenance area
for the 1997 8-hour ozone standard.
• Clean Air Act provisions require VOC requirements previously
implemented in nonattainment areas prior to redesignation to
remain in place
• Remaining areas in NC subject to .0958:
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Cabarrus County;
Gaston County;
Lincoln County;
Mecklenburg County;
Rowan County;
Union County; and
Davidson Township and Coddle Creek Township in Iredell County.
What this means for YOU
• 1997 8-hour Ozone Standard Maintenance
Area:
• No Change
• VOC Major Sources (>100 TPY VOC)
• No Change
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What this means for YOU
• Sources Outside of Maintenance Area
• 2D .0958 will be removed from permits next time DAQ touches
permit for any reason (renewal, modification, ownership
change, etc.)
• If facility wishes to remove rule, they may apply for permit
modification
• Title V Application will be a Minor Modification.
• Synthetic Minor/Small will be normal permit modification
application
• No application fee
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What this means for YOU
• Compliance Requirements for Sources Outside of Maintenance
Area
• Title V
• Continue to comply with Permit until rule is removed
• Including Monitoring/Recordkeeping and Reporting
• Synthetic Minor/Small
• Rule no longer applicable
• No monitoring/recordkeeping/reporting required by permit
• Note: Sources Subject to Wood Furniture Manufacturing MACT (40 CFR
Part 63 Subpart JJ) exempt from .0958 due to work practice standards
contained in Subpart JJ. Work practice standards under JJ still apply.
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Air Quality Regional Offices
Winston-Salem
Raleigh
Asheville
Mooresville
Washington
Fayetteville
Wilmington
Regional Offices
Asheville Regional Office
2090 US Hwy 70
Swannanoa, NC 28778
Phone: (828) 296-4500
Fax: (828) 299-7043
Fayetteville Regional Office
225 Green Street Suite 714
Fayetteville, NC 28301
Phone: (910) 433-3300
Fax: (910) 485-7467
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Phone: (252) 946-6481
Fax: (252) 975-3716
Mooresville Regional Office
610 E. Center Avenue Suite 301
Mooresville, NC 28115
Phone: (704) 663-1699
Fax: (704) 663-7579
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Phone: (910) 796-7215
Fax: (910) 350-2004
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Phone: (919) 791-4200
Fax: (919) 881-2261
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Phone: (336) 776-9800
Fax: (336) 776-9797
Local Environmental Programs
Buncombe County
Western NC Regional Air
Pollution Control Agency
49 Mount Carmel Road
Asheville, NC 28806
Phone: (828) 250-6777
Fax: (828) 255-5226
Forsyth County
Environmental Affairs Dept.
201 North Chestnut Street
Winston-Salem, NC 27101
Phone: (336) 703-2440
Fax: (336) 727-2777
Mecklenburg County
Mecklenburg County Air Quality
700 N. Tryon Street, Suite 205
Charlotte, NC 28202
Phone: (704) 336-5430
Fax: (704) 336-4391
Questions?/Contact Information
Robert Bright
Compliance Coordinator, Washington Regional Office
252-948-3829
[email protected]
Davis Murphy
Compliance/Permitting Engineer, Winston-Salem Regional Office
336-776-9644
[email protected]
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