March 3rd ISG Meeting Summary
Baron Environmental Associates regularly attends the quarterly Industrial Stakeholders Group (ISG) meetings hosted by the New Jersey Department of Environmental Protection (NJDEP) Bureau of Stationary Sources.
These meetings update the public on regulatory proposals and guidance for air quality permitting in NJ. The latest meeting was held March 2, 2017. Attendees include DEP employees from Bureau of Stationary Sources, Bureau of Mobile Sources, and Air Compliance & Enforcement as well as EHS professionals and engineers from New Jersey consulting firms and industrial facilities.
Baron has summarized the most important findings from the meeting below:
DEP has scheduled a 2-day training session that will cover various permitting topics. The first day will focus on permit applications. The second day will cover Emission Statements and Risk Assessment. The training will take place on the Rutgers campus in New Brunswick on June 6th-7th. The class costs $425 per person with a discount for multiple individuals. Interested parties can find more information and sign up using the link below: http://www.cpe.rutgers.edu/courses/current/en0203ca.html
The changes that DEP has been planning for the Small Emitter General Air Permit (also known as the SEGAP or GP-016) are finally happening. The current GP-002 and GP-003 are being combined with GP-016 to make a new GP-016A that will cover equipment previously covered by any of the three. This new GP-016A permit is expected to be available from DEP beginning on March 20, 2017.
DEP is encouraging facilities to use their permitting process helplines. DEP explained that their associates can help professionals through any aspect of the permitting process. The two hotlines can be reached at:
Minor Source (non-Title V) Permitting 609-633-2829
Major Source (Title V) Permitting 609-633-8248
DEP is planning to revise Subchapter 8 (Minor Source air permits) in the near future. This has the potential to be a major change as Subchapter 8 covers Hazardous Air Pollutants (HAPs). For facilities whose HAP emissions are higher than the thresholds established in Subchapter 8, a Risk Assessment is required in addition to permitting. Because this Risk Assessment can lead to additional compliance requirements, industry personnel tend to dislike these requirements and often take measures to avoid the need for a Risk Assessment altogether. DEP is encouraging industry to stay in contact with the Department as they will be making more information available about the changes. The proposed changes will not likely be finalized for at least a year, and therefore industry feedback on the proposal has the potential to be a significant factor in the final regulations.