Baron Environmental Associates recently attended the quarterly Industrial Stakeholders Group (ISG) meeting held by the NJDEP’s Air Quality Permitting Department on Friday, March 2, 2018. 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:
Danny Wong is the new head of the Bureau of Stationary Sources.
There is currently only one newly adopted air permitting rule. This is:
Air Toxics and Resiliency Rule – (Adopted 12/14/17, Effective 2/12/18) - Air Toxics thresholds were updated for HAP reporting to ensure the most updated information available is being utilized that also includes human health impacts. All Air Toxic thresholds were consolidated into N.J.A.C. 7:27-17 “Control and Prohibition of Air Pollution by Toxic Substances”. The Resiliency Rule update also includes clarifications of the exemptions for emergency operations, temporary equipment, portable equipment, and construction, repair and maintenance.
On 1/29/18 Governor Murphy signed Executive Order 7 which directs New Jersey to rejoin the Regional Greenhouse Gas Initiative (RGGI).
This will require two new rulemakings:
• RGGI mechanics – How the auctions will be completed
• Dispersals of RGGI proceeds – How the proceeds will be distributed
VOC Testing in Natural Gas Engines
An informational letter was issued by the NJDEP to all holders of preconstruction (PCP) permits for non-emergency engines combusting natural gas 90 days prior to the expiration date of the specific PCP that a new air permit must be applied for. This is due to the discovery by the NJDEP that Volatile organic compounds (VOC) and formaldehyde emissions have been underreported. DEP recommends that if the PCP can be replaced by a General Permit (GP), it should be. Otherwise a new PCP application must be submitted with formaldehyde properly quantified for inclusion in the VOC emission limit.
Risk Analysis Flow Chart
An Air Toxics Health Risk Assessment flow chart has been made available by the NJDEP for Title V air permits. It can be found at http://www.state.nj.us/dep/aqpp/risk.html
General Permits (GP) Update
The following updated General Permits are now in effect:
-For Existing Fuel Dispensing facilities with Stage I and Stage II Vapor Recovery Systems
-This GP was updated 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: Available since 1/16/18
-For Fuel Dispensing facilities with Stage I only
-This GP was updated 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: Available since 1/16/18
The following are General Permits that are under revision:
-For storage tank(s) storing VOC(s)
-Will limit each facility to one GP-007A that may cover multiple tanks
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
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) to include boilers burning No. 2 fuel oil and automatic PTE calculations
-Effective date: Anticipated to be summer 2018
GP-013A (will replace GP-013):
-For Non-HAP dry cleaning operations
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-019A (will replace GP-019):
-For Portable Equipment (Temporary Equipment)
-This GP will incorporate Subchapter 8 changes to allow for multiple pieces of equipment on the same GP
The following are General Operating Permits (GOP) that are under modification:
GOP-002A (will replace GOP-002):
-For Manufacturing and Materials Handling Equipment
-This permit was previously called Small Emitters General Air Permit (SEGAP)
-Status: Working on online design, available early in 2018
-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
RADIUS 5.0 was released on 1/23/18.
RADIUS 4.0 will no longer be accepted.
RADIUS 5.0 requires a single download as opposed to several downloads required in previous versions.
It was a trouble free rollout.
Emission Statements Update
2017 statements are due in paper form by 5/15/18.
Diskettes, email, and USB drives are no longer accepted.
Submissions must use RADIUS 5.0 (RADIUS 4.0 is no longer accepted)
New stricter limits for various emissions will be implemented for the 2018 reporting year.
New HAPs limits for 2017 reporting include the following;
For more information on ISG meetings past, present and future, can contact Baron or visit the DEP website here.