Baron Environmental Associates, L.L.C.
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571 Central Ave, New Providence, NJ 07974

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Quarterly Industrial Stakeholder Group meeting

October 2, 2017

 

Baron Environmental Associates recently attended the quarterly Industrial Stakeholders Group (ISG) meeting held by the NJDEP’s Air Quality Permitting Department on Friday, September 1st.  The purpose of these meetings is to allow consultants and those in industry to meet with DEP officials to discuss and comment on regulation and rule updates. Below is a brief description of the major talking points from the meeting:

 

Organizational Update

 

Within the NJDEP Division of Air Quality (DAQ) there is a new regulatory and policy team that will be headed by Danny Wong. This team will be tasked with assisting those with questions about the interpretation of regulations including State-of-the-Art (SOTA) manuals and other topics.

 

Many DAQ positions have been newly-filled including Section Chief of the Preconstruction Unit and Bureau Chief. The ISG website will be updated to include a chart of the positions with the new personnel.

 

Rule Updates

 

There are several proposals in the works for adoption of new air permitting requirements. These include:

 

  • CTGs & NOx RACT –The NJDEP will adopt the following Control Technique Guidelines (CTGs) as issued by the EPA:

    • Paper, Film, and Foil Coatings (PFFC)

    • Fiberglass Boat Manufacturing Materials (FBMM)

    • Miscellaneous Metal and Plastic Parts Coating (MMPPC)

    • Industrial Cleaning Solvents (ICS)

This update also includes CTGs VOC emission reduction. The NOx Reasonably Achievable Control Technology (RACT) will be updated to regulate combustion sources not previously subject to the requirements such as engines and simple cycle turbines combusting natural gas and compressed gaseous fuels at major NOx facilities

 

  • PM 2.5 & SSM– PM 2.5 permitting rules will be updated to include particulate matter (PM) less than 2.5 microns, which will include Federal requirements 40 CFR Part 51, Appendix S. Within Startup, Shutdown, & Malfunction (SSM) Provision, it is proposed to removed an antiquated exemption in N.J.A.C. 7:27 – 7 regarding the Control of Sulfur rule.

 

  • Stage I/II – Gasoline Dispensing Rules in New Jersey are to be amended to require decommissioning of Stage II vapor returns at existing gasoline dispensing facilities because some stage II system are incompatible with onboard fueling vapor recovering systems that are required by the federal government to collect gasoline refueling emissions within the vehicle.  Manufacturers of t-butyl acetate (TBAC) will no longer have to report TBAC emissions as the intent is to repeal this requirement.

 

  • Air Toxics and Resiliency Rule – Air Toxics thresholds are to be updated for HAP reporting to ensure the most updated information available is being utilized that will also include human health impacts. All Air Toxic thresholds will be consolidated into N.J.A.C. 7:27-17 “Control and Prohibition of Air Pollution by Toxic Substances”. The Resiliency Rule update will also include clarifications of the exemptions for emergency operations, temporary equipment, portable equipment, and construction, repair and maintenance.

 

  • SOTA Manuals – Several State-of-the-Art (SOTA) Manuals are currently under review or are to be reviewed soon. It is expected that a few will be withdrawn, and several more are to be revised and one or two new ones are to be proposed.

 

Technical Manuals 1002 & 1003

 

Technical Manual 1002 for “Guidance on Preparing an Air Quality Modeling Protocol” will be updated to include new modeling data, updated National Ambient Air Quality Standards, and more background and guidance on air quality information.


Technical Manual 1003 for “Guidance on Preparing a Risk Assessment for Air Contaminant Emissions” is to be updated to include updated air quality models, unit risk factors and reference concentrations, and metrological data. A few items were deleted including risk assessment applicability and comprehensive risk assessments.

 

On October 12, 2017 there will be a Stakeholder meeting by invitation only for open discussion on these Technical Manual updates and the formal comment period will begin in the fourth quarter of 2017.

 

General Permits (GP) Update

 

The following are new General Permits that will take effect in 2017 in order to implement MACT 6’Js for Industrial, Commercial and Institutional boilers.

 

  • GP-017A (will replace GP-017)

    • For boilers and heaters each less than 5 MMBTU/hr

    • Effective date: March 20, 2017

  • GP-018A (will replace GP-018)

    • For boilers and heaters each greater than or equal to 5 MMBTU/hr and less than 10 MMBTU/hr

    • Effective date: August 7, 2017

 

The following are General Permits that are under construction.

 

  • GP-004B

    • For Fuel Dispensing facilities for Stage I only

    • This GP will be revised to incorporate the revised regulation of N.J.A.C. 7:27-16.3 for Gasoline Transfer Operations to eliminate installation of Stage II Vapor recovery systems in Gas stations.

    • Status: In development and will be available beginning of 2018.

  • GP-016A

    • For Manufacturing and Materials Handling Equipment (Former SEGAP)

    • This GP will replace three existing GP’s: GP-016 (SEGAP), GP-002 (Confined Abrasive Blasting Equipment) and GP-003 (Woodworking Equipment)

    • Status: In development and will be available December 4, 2017.

  • GP-015A (will replace GP-015)

    • For Non MACT Plating Operations

    • This GP will implement MACT requirements.

    • Status: In development

  • GP-009B (will replace GP-009A)

    • For boilers and heaters each greater than or equal to 10 MMBTU per hour and less than 50 MMBTU per hour

    • This GP will implement MACT 6J (NESHAP for Area Sources: Industrial, Commercial, and Institutional Boilers - 40 CFR Part 63 Subpart JJJJJJ), include boilers burning No.2 fuel oil, and automatic PTE calculations

    • Effective date: Beginning/ mid 2018

  • GP-019A (will replace GP-019)

    • For Portable Equipment (Temporary Equipment)

    • This GP will incorporate Subchapter 8 changes to allow for multiple pieces of equipment.

  • GP-008A (will replace GP-008)

    • For Site Remediation Activities for Gasoline Contamination at Vehicle Fueling Stations (SVE)

    • This GP is to be revised to make it only available for five years.

 

The following is a General Operating Permit (GOP) that has recently been approved.

 

  • GOP-008

    • For boilers or heaters greater than or equal to 5 MMBTU per hour and less than 10 MMBTU per hour

    • This GOP will implement MACT 6J (40 CFR Part 63 Subpart JJJJJJ) for Industrial, Commercial and Institutional boilers.

    • Effective date: August 7, 2017

 

The following are General Operating Permits (GOP) that are under construction.

 

  • GOP-002A (will replace GOP-002)

    • For Manufacturing and Materials Handling Equipment

    • (Former SEGAP)

    • Status: Working on online design

  • GOP-009

    • For boilers or heaters each greater than or equal to 10 MMBTU per hour and less than 50 MMBTU per hour

    • This GP will implement MACT 6J (40 CFR Part 63 Subpart JJJJJJ), include boilers burning No.2 fuel oil, and automatic PTE calculations

    • Effective date: Beginning/ mid 2018

 

Emission Credits Update

 

  • There will be Frequently Asked Questions (FAQs) updates to include more questions and answers.

  • There is a shortage of credits in North Jersey and the DEP is working on a plan for those in North Jersey to use other unused credits.

    • This may include those credits that go back to the state when they are unused – to be made available to those in North Jersey (possibly in 2018).

 

For more information on ISG meetings past, present and future, you can contact Baron or visit the DEP website here.

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