March 12, 2019  

• Thinking Strategically by Leslie Rhodes, Director
• A Message From The Chair of Your Air Quality Commission
• Permitting & Enforcement Activities in 2018
• MCAPCO Revisions
• Continuous Fine Particulate Matter (PM2.5) Monitoring Implementation
• 2018 Annual Forum
• AQ Forum Attendees Prioritize “Breathing Room” Strategies
• Mecklenburg County Solid Waste to Host Discount Collection Events for Businesses Producing Small Volumes of Hazardous Waste
• Creek Week

Thinking Strategically by Leslie Rhodes, Director

“The technical proficiency of MCAQ staff is commendable.” – USEPA Technical Systems Audit

 “MCAQ goes above and beyond to help with air permit compliance.” – Regulated facility survey response

 “This group actively engages businesses, individuals and the public on how to improve air quality and promote transportation and industrial solutions to reduce mobile and point source air pollution.” – Sustain Charlotte Award Nomination

Excellence doesn’t happen by accident.  At Mecklenburg County Air Quality (MCAQ), we recognize this and, as a result, we think and plan strategically.  MCAQ is a division of the County’s Land Use and Environmental Services Agency, a department of approximately 500 employees with a customer-focused service approach.  To build upon our achievements in the areas of customer service and environmental stewardship, MCAQ is presently developing our strategic plan through Fiscal Year 2022. 

Our goals and objectives will be supported by innovative actions such as:

• Design and install an Air Quality Learning Station to engage residents, visitors, and students;
• Develop a path forward to create “Breathing Room” between local ozone concentrations and the federal health-based standard; and
• Evaluate air monitoring technology with a smaller footprint for future use.

Take a look at the current strategic plan and stay tuned for more information about the development of the 2022 plan.

A Message From The Chair of Your Air Quality Commission

Permitting & Enforcement Activities in 2018

MCAQ staff were out in the field a lot in 2018 and found that most Mecklenburg County permitted sites were consistently following their air quality permits.  In fact, 92% of our inspections resulted in a finding of “in compliance.”  More and more sites have improved their environmental management systems to comply with their air quality monitoring, recordkeeping, and reporting requirements.  Here’s a snapshot of Permitting & Enforcement (P&E) staff activities and the most common violations we encountered:

Compliance Tools For You

MCAQ wants you to stay in compliance with your air quality permit.  To help, we’ve created a number of tools, such as:

1. 2019 Report Tracker emails and annual reporting calendars – Air Quality Specialists composed chronological reporting calendars for sites that have additional reports due outside of the annual emissions report. These calendars were emailed to facilities by January 30, 2019.
2. Baghouse and scrubber monitoring log templates – To help facilities more easily keep track of common monitoring requirements, MCAQ created monitoring log templates for baghouses and scrubbers. All templates can be found on the Forms page of MCAQ’s website.
3. Online applicability determination – If you’re unsure whether a new piece of equipment or process might need to be permitted, you can submit this information quickly and easily for review using MCAQ’s online “Air Permit Applicability Questionnaire” tool.
4. Inspection Checklists – MCAQ has made the inspection checklists designed and used by our Air Quality Specialists available to sites for their use. The checklists show data points and work practices inspectors will be reviewing by industry type.
5. Improved Access to Federal Rule Requirements – We’ve updated our rules page to highlight the most common industries we permit and their corresponding federal rule requirements.

The bottom line is we want you to know and understand your permit requirements.  If you have any questions, please contact your assigned Air Quality Specialist to discuss.

Stay on Track with the 

2019 MCAQ Compliance Calendar (linked)

MCAPCO Revisions

On December 18, 2018, MCAQ adopted the most recent revisions to state air quality rules into the county’s air pollution control regulations, the Mecklenburg County Air Pollution Control Ordinance. The changes were primarily based on revisions made to state rules as part of the North Carolina Department of Environmental Quality - Division of Air Quality’s (NCDEQ-DAQ) Periodic Review of Existing Rules Process, as required by North Carolina General Assembly Session Law 2013-413. With the large number of rules that need to be reviewed, NCDEQ-DAQ has divided them into six groups for re-adoption. This adoption included the first two groups processed for re-adoption by the state (referred to as Group 1 and Group 2 rules), which deal with air pollution source classifications, air pollution emergencies, the National Ambient Air Quality Standards (NAAQS), and minor source and Title V permitting procedures.

While most of the changes made were editorial in nature (e.g. clarifications and correcting mistakes), two significant changes were adopted:

• The October 26, 2015 revisions made by EPA to the Ozone NAAQS, establishing a daily maximum eight-hour average standard of 0.070 parts per million.
• Public notice of any draft Title V permit for an existing facility for which a public hearing is not scheduled can now be given by posting on the MCAQ web site.

The state continues to work to re-adopt the remaining four groups of rules, with a target to complete the entire process by the end of 2020. MCAQ will adopt the revisions as they are completed by the state.

Continuous Fine Particulate Matter (PM2.5) Monitoring Implementation

PM2.5 (fine particulate matter) monitoring is conducted at three (3) sites in Mecklenburg County. Data collected at those sites is used to determine compliance with the National Ambient Air Quality Standard (NAAQS).

Historically, the method for measuring PM2.5 has been a manual filter-based method.  MCAQ began a process to evaluate and implement newer continuous PM2.5 monitoring methods in the MCAQ network in 2017.  USEPA provided supplemental funding for air monitoring agencies operating in the southeast to install and operate newer continuous monitors at that time.

From January 2017 through early 2018, MCAQ tested the new monitors to assess comparability of the continuous method with the manual filter-based method.  The comparisons indicated the new analyzers were able to provide data that was comparable to the filter-based method. In the spring of 2018 MCAQ began using data from new continuous PM2.5 analyzers as the primary data source in the MCAQ monitoring network.

Continuous methods offer several advantages that include:  acquisition of near real-time hourly data, every day sampling rather than every 3^rd or 6^th day sampling, improved efficiency because monitoring sites require fewer operator visits, fewer steps in the monitoring process thus eliminating steps where breakdowns can occur, improved reliability, and a reduction in the number of filters sampled and processed that results in lower costs.  Compliance data for 2018 was measured using the new continuous methods.

The chart below shows the compliance values measured in the MCAQ network since 2008.  The most recent annual PM2.5 design (compliance) value for Mecklenburg County is 8.8 mg/m³, which is well below the annual PM2.5 NAAQS level of 12 mg/m³.  The design value was measured at the Remount monitoring site.

2018 Annual Forum

The 2018 Annual Air Quality Forum was held on November 8, 2018 at the Mecklenburg County Land Use and Environmental Services Agency building.  Fifty-two (52) representatives from thirty-six (36) businesses attended the Forum. 

Guest Speaker, Steve Hall, Technical Services Section Chief of the North Carolina Division of Air Quality provided an air quality update from a statewide perspective, while MCAQ Permitting & Enforcement (P&E) and Monitoring staff gave updates from a local perspective.

A new MCAQ initiative called Breathing Room was introduced to attendees by Megan Green, Mobile Sources Program Manager.  The aim of this program is to provide additional “breathing room” between the compliance value and current standard for ozone in Mecklenburg County.  Following the presentation, attendees were able to provide valuable feedback by voting for their favorite NOx reduction strategies that were discussed during the presentation.

2018 marked the fifth year of MCAQ’s Air Compliance Excellence (ACE) award program.  To highlight this permitted facility recognition program, MCAQ invited a guest speaker from one of the sites that has received an ACE award each of the five years since the program’s inception.  Mike Davis, Plant Superintendent & EHS Manager with INX International Ink Company, gave a thought-provoking presentation about ways to manage and prioritize compliance from an industry perspective. 

To view presentations from the 2018 Forum, visit http://airquality.charmeck.org/forum.

AQ Forum Attendees Prioritize “Breathing Room” Strategies

MCAQ is leading the Charlotte region's “Breathing Room” initiative to take proactive steps to reduce ozone-forming air pollution, in partnership with the North Carolina Division of Air Quality and U.S. Environmental Protection Agency's Advance Program. After reviewing stakeholder-developed plans (e.g. Connect our Future, LivableMeck, etc.) to identify regional priorities that align with air quality, 15 new, voluntary emission reduction strategies were identified. 

Throughout 2018 MCAQ has sought public input on how to prioritize these strategies for implementation, including at the annual Air Quality Forum.  Attendees completed a “voting” activity that prioritized the following strategies for implementation:

1. Complete Streets
2. Transit Expansion Advocacy
3. Greenway Expansion Advocacy
4. Community Solar
5. Zoning Incentives: EV Charging Infrastructure

These results will be combined with results from other groups to create a Path Froward for the region in spring/summer 2019. 

Mecklenburg County Solid Waste to Host Discount Collection Events for Businesses Producing Small Volumes of Hazardous Waste

Businesses are legally required to responsibly dispose of hazardous waste. Hazardous waste includes items such as fluorescent bulbs, chemicals and pesticides. This law is based upon standards established by the Resource Conservation and Recovery Act (RCRA) – the Federal Statute outlining how hazardous waste, non-hazardous waste and underground storage tanks should be managed in the United States. States have adopted regulations to administer and enforce the RCRA Standards. In North Carolina, these duties fall to N.C. Department of Environmental Quality (NCDEQ).

Under RCRA, businesses are categorized by the volumes of hazardous waste that they generate. There are three such categories, each with specific compliance criteria: Large Quantity Generators (LQG’s), Small Quantity Generators (SQG’s) and Very Small Quantity Generators (VSQG’s). Of these three, VSQG’s are the smallest generators of hazardous waste -- producing less than 220 pounds of hazardous waste and 2.2 pounds of acute hazardous waste each month. While VSQG’s have the fewest regulation requirements under RCRA, they are still required to responsibly dispose of their hazardous waste.

Unlike Mecklenburg County residents, businesses are unable to utilize Mecklenburg County’s four Full-Service Recycling Centers to dispose of hazardous waste. This is because these four centers are permitted by the State of North Carolina to only accept Household Hazardous Waste (i.e. hazardous waste generated from households). Unable to use these public sector resources, businesses waste must contract with a licensed private-sector company to dispose of their hazardous waste. Unfortunately, these services can be expensive. Many VSQG’s are small businesses and cannot afford to pay the disposal fees charged by these hazardous waste disposal companies, creating a significant barrier for RCRA compliance.

To help overcome this financial barrier, Mecklenburg County Solid Waste created VSQG Hazardous Waste Collection Events. Launched in 2017, these nationally recognized, one-day events are held in partnership with ECOFLO – a licensed hazardous waste disposal company. Through this partnership, Mecklenburg County was able to cut the cost of hazardous waste disposal for qualifying businesses by an average of 20%. Recent changes to the program promise additional savings for VSQG’s.

Mecklenburg County Solid Waste’s next VSQG Hazardous Waste Collection Event is scheduled for May 22, 2019. This event is by appointment only. For additional information please visit the Mecklenburg County Solid Waste website or email solidwaste@mecklenburgcountync.gov.

Creek Week