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:
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.
There are several proposals in the works for adoption of new air permitting requirements. These include:
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.
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.
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.
The following are General Permits that are under construction.
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.
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)
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)
GP-008A (will replace GP-008)
The following is a General Operating Permit (GOP) that has recently been approved.
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.
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.
For more information on ISG meetings past, present and future, you can contact Baron or visit the DEP website here.