Implementing EPA’s New Clean Air Act Policies Under NSR and Title V (December 2020)

 Implementing EPA’s New Clean Air Act Policies Under NSR and Title V (December 2020)
Over the last several years, EPA has issued several policy memoranda and rulemakings pertaining to preconstruction permitting requirements under New Source Review (NSR) and operating permit requirements under Title V of the Clean Air Act. Experts in NSR and Title V permitting matters will discuss challenges and implementation issues with regard to the recent policy changes listed below, facing both permitting authorities and the regulated community.

Item Number: WEBINAR-101
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This webinar will cover:
• Interpretation of “Adjacent” based upon physical proximity between properties
• Scoping “Ambient Air” based upon a limited change to the application of the “access” element in the regulatory definition of ambient air
• Interpreting “Begin Actual Construction” proposed guidance, allowing physical on-site activities prior to obtaining an NSR permit, provided that those activities do not constitute physical construction on an emissions unit
• Plantwide Applicability Limitation (PAL) permitting issues guidance with respect to permit reopening, expiration, termination, and renewal, and monitoring requirements under PAL
• In the final rule on major MACT to area source (“MM2A”), EPA provides that a major source can be reclassified to area source status at any time upon reducing its potential to emit of hazardous air pollutants below the major source thresholds of 10/25 tpy

Presenters: Eric Hiser, Partner, Jorden, Hiser & Joy, PLC; Dave Jordan, Partner, ERM; Matthew Porter, Meteorologist, Division of Air Quality, Permitting Section, Air Quality Analysis Branch, North Carolina Department of Environmental Quality; Booker Pullen, New Source Review Supervisor, Air Permitting Section, DAQ; Annette Switzer, PE, Permit Section Manager, Air Quality Division, Michigan Department of Environment, Great Lakes and Energy

Moderator: Rahul Thaker, P.E., QEP, Environmental Engineer, North Carolina Department of Environmental Quality, Division of Air Quality