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NJDEP Air Program Update – Industrial Stakeholders Group (ISG) Meeting

The NJ Department of Environmental Protection’s (DEP) Air Permitting group held its triannual Industrial Stakeholders Group (ISG) meeting on June 7, 2019 to provide an update to the regulated community on actions the permitting group is working on at this time.

General Permits (GP)/General Operating Permits (GOP)

GOP-002A for Manufacturing and Material Handling Equipment for major facilities is being updated to revise applicability requirements for consistency, now allows multiple emission points, limits the potential to emit per equipment, and now allows cartridge filters and baghouses if the particulate emissions after the control device are below the reporting thresholds. Other control devices are allowed as long as all the emissions before controls are below the reporting thresholds. This permit replaced GOP-002.

Emergency Generator permits GP-005A / GOP-003 and GP-005B /GOP-004 are being revised to reflect the current definition of an emergency generator in regard to construction, repair and maintenance (CRM) activities. They will be available for public comment in July 2019.

GP-009B and GOP-009 for boilers between 10 and 50 MMBTU/hr are in the process of being revised to include smart calculations and limiting the minimum stack height to 20 feet. They will be available for public comment in August 2019.

The NJDEP plans to update GP-019 (Portable Equipment), to include the updated Subchapter 8 thresholds by the end of 2019. GP-007/GOP-011 (Storage Tanks) and GP-008 (Site Remediation) will also be updated at some point in the future.

Risk Screening

The general Risk Screening Worksheet (RSW) along with the associated fact sheet were issued on May 7th2019 for public comment. Revisions to the worksheet included raising the minimum stack height from 10 to 15 feet and adding three new compounds. The ISG attendees expressed concern that the new proposed RSW will result in more significant health risk determinations which will trigger an increase in the number of refined analyses and result in a backlog in the permitting process. The NJDEP will evaluate the feedback before finalizing the worksheet.

Preconstruction Review for Title V facilities

The NJDEP participated in an EPA audit of New Jersey’s Title V permitting program in 2016. As a result of that audit, New Jersey was required to clarify within its rules that the NJDEP will conduct a preconstruction permit review under N.J.A.C. 7:27-8 and operating permit review under N.J.A.C. 7:27-22 for an application for a minor modification or significant modification. After the NJDEP made this change in the rule (effective October 10, 2017), they noticed that there are some inconsistencies between the preconstruction provisions set forth in Subchapters 8 and 22. The NJDEP intends to correct any inconsistencies through a future rule revision, which will take a phased-in approach to incorporating any necessary revisions to permits. Until then, the NJDEP is advising that if there is a variation between a requirement in Subchapters 8 and 22, the NJDEP will implement the requirement that is more stringent.

Community Corner Demonstration

There was a demonstration by the NJDEP of their new application located on the top right corner of the NJDEP Bureau of Stationary Sources webpage. This application enables users to find any air permit information of a facility by locating it on a map. The information included is current air permits as well as pending permits, CO2 Emissions Reports, Air Toxics Reports, and Criteria Pollutants and Methane Emissions reports.

The third (and last) meeting of the ISG for 2019 will take place in October.

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