On December 1st, Baron Environmental Associates attended the quarterly Industrial Stakeholders Group (ISG) meeting held by the NJDEP’s Air Quality Permitting Department. 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:
Most DAQ positions have been filled by the time of the ISG meeting. Michael Adhanom is the new head of Preconstruction Permits. The head of the Bureau of Stationary Sources is still open and needs to be filled. The ISG website has been updated to include a chart of the positions with the new personnel.
There are several newly adopted air permitting rules. These include:
CTGs & NOx RACT (Adopted 9/1/17, Effective 9/5/17) –The NJDEP adopted 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) was 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/Sulfur SSM (Adopted 10/10/17, Effective 11/6/17)– PM 2.5 permitting rules were updated to include particulate matter (PM) less than 2.5 microns, which include Federal requirements 40 CFR Part 51, Appendix S. Within Startup, Shutdown, & Malfunction (SSM) Provision, it has removed an antiquated exemption in N.J.A.C. 7:27 – 7 regarding the Control of Sulfur rule.
Stage II/TBAC (Adopted 10/24/17, Effective 11/20/17) – Gasoline Dispensing Rules in New Jersey now require decommissioning of Stage II vapor returns at existing gasoline dispensing facilities because some stage II systems 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.
There is still one proposal in the works for adoption of new air permitting requirements.
Air Toxics and Resiliency Rule – (Projected to make the NJ Register on 1/2/18) 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 - UPDATE
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.
There was a Stakeholder meeting by invitation only held on October 12, 2017 for open discussion on these Technical Manual updates. They are currently ready for the formal comment period.
Plot Plan Requirements
The NJDEP indicated that they will not accept reproductions or photographic copies of a plan or survey.
All plans, surveys, or maps shall be prepared by a licensed land surveyor or P.E.
The NJDEP indicated that it is necessary to conduct accurate air quality modeling impact and health risk assessments.
Plot plan requirements are in section 6.2 of the Technical Manual 1002 which is in the process of being updated.
Risk Screening Worksheet Changes
Sulfuryl fluoride has been added as a pollutant.
Generated from California Pesticide Regulation, Toxic Air Contaminant Assessment.
Primarily used as a fumigant
Ethylene oxide unit risk factor change
Changed from 8.8E-5 ug/m3 to 3E-3 ug/m3
Two orders of magnitude more stringent.
n-Propyl Bromide is under consideration to be added as a pollutant.
General Permits (GP) Update
The following General Permit is now in effect as of 12/4/17.
For Manufacturing and Materials Handling Equipment (Former SEGAP)
This GP replaces three existing GP’s: GP-016 (SEGAP), GP-002 (Confined Abrasive Blasting Equipment) and GP-003 (Woodworking Equipment)
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: Out for public comment and will be available 1/16/18.
GP-015A (will replace GP-015)
For Non MACT Plating Operations
This GP will implement MACT requirements.
Status: Permit text and compliance plan under 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: Summer 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 are General Operating Permits (GOP) that are under construction.
GOP-002A (will replace GOP-002)
For Manufacturing and Materials Handling Equipment
Status: Working on online design
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: Summer 2018
The NJDEP confirmed that RADIUS is Windows 10 compatable.
It is recommended to update all 11 of the reference tables.
RADIUS 5.0 will be available in early 2018.
All users will be required to download the new version when it becomes available.
Emission Credits Update
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).
The New York State emission credit agreement has been exhausted.
For more information on ISG meetings past, present and future, you can contact Baron or visit the DEP website here.