The New Jersey Department of Environmental Protection’s (NJDEP) Air Permitting group held its quarterly Industrial Stakeholders Group (ISG) meeting on September 7, 2018 to provide an update to the regulated community on actions in progress.
General Permits (GP)/General Operating Permits (GOP)
GP-016A for Manufacturing and Material Handling Equipment is being updated to add one exclusion so that it is clear that the permit is not intended to cover fumigation operations. The permit currently excluded emissions of Hazardous Air Pollutants (HAPs) and was intended to exclude other air toxics, but this was not clear in the GP. The numbering system will not receive an update for this change; the permit will remain GP-016A.
The update of GP-13A for non-HAP Dry Cleaning is in web design and will be available by the end of 2018. An update is in process for the paper-only application for GP-015 covering Non-MACT Plating Operations. An update of GP-015 is anticipated to affect no more than twenty facilities in the state.
GP-009A covering larger boilers combusting gaseous fuels will be updated to be consistent with the recent updates of GP-017A and GP-018A. This update will allow facilities to enter a specific fuel usage limit and avoid artificial increases in potential emissions due to the current size bands offered from DEP.
DEP intends to update GP-019 (Portable Equipment), GP-021 (Combined Heat & Power) and GP-022 (CHP and RICE) to include the updated Subchapter 8 thresholds issued earlier in 2018. GP-007 (Storage Tanks) and GP-008 (Site Remediation) will also be updated at some point in the future.
Risk Screening
Significant changes are forthcoming to the risk screening process within New Jersey. The Risk Screening Worksheet was updated a second time in 2018. Additional changes were published on 8/30/18; the most current spreadsheet and associated guidance must be used moving forward for any source with a single stack. The Technical Manual update is nearly finished.
DEP has provided a new version of the Risk Screening Spreadsheet to some ISG members to verify its performance. This "future" version has been updated to include the newest version of AEROMOD and is slightly more conservative. It includes options for two types of land use (urban and rural), three areas of meteorology (northern, central and southern NJ) and flat terrain. All of the changes are contained within the locked portion of the spreadsheet. Some stakeholders indicated that they are seeing results with 400-1300% higher exposures. As a result, modeling requirements may substantially increase as part of the permit application process impacting costs and permit processing time.
DEP employees also reiterated the importance of alignment within submitted permit application documents. Specifically the risk screening spreadsheet and the permit application must match. DEP has been receiving a number of applications where the information entered into the two documents are not the same.
Startup, Shutdown and Malfunction Plans (SSMP)
New guidance relating to the SSMP process has been posted on DEP’s website. New Operating Scenarios (OSs) are being added for start and shutdown within air permits. Malfunctions continue to be covered under the Affirmative Defense policy. Additionally, facilities may request an OS covering commissioning (or “shakedown” in EPA language) during the permitting process to cover unusual scenarios that occur during this period. Facilities must ask for this OS in their permit application; it will not be automatically included. The Compliance group specified that their hands are tied on commissioning “violations” unless an OS is put into the permit at the time of the application.
Permitting Guidance
Per previous requests at ISG meetings, all permitting guidance now lists the posting date along with its title on the DEP webpage so that it is easier to see what has changed. If any documents are not listed, please contact Danny Wong.
1996/1997 Minor Source Permits
DEP recently issued a compliance advisory related to minor source permits that begin with PCP96 or PCP97. These permits were digitized in either 1996 or 1997 however they were not updated to include any of the current DEP terms and conditions. 1996 and 1997 permits do not meet NJ’s State Implementation Program (SIP) and will need to be replaced with a current permit. DEP is not simply encouraging facilities to update their permits in this category. Additional department action will follow.
Future Meetings/Topics
Ken Ratzman made the request to reduce the frequency of ISG meetings to twice per year. This option was resoundingly not supported by attendees. A compromise plan was discussed and approved. Beginning in 2019, ISG meetings will be scheduled for the first Friday in February, June and October.
If any facility has an issue that they would like discussed at future ISG meetings, please send these items in advance to Kenneth.ratzman@dep.nj.gov.