Emission Statement Deadline:
There has been confusion concerning the correct due date for Emission Statement submittals. In the past, the NJDEP has allowed annual Emission Statements prepared in the RADIUS format to be submitted up until June 15th as opposed to the stated May 15th deadline. This was a temporary allowance for the first few years to promote electronic submissions. The NJDEP reviewed existing rules at N.J.A.C. 7:27-21 in response to questions and clarified that the 2019 Emission Statements are now due May 15, 2020. Any Emission Statement submitted past the May 15th deadline will be considered late and be subject to possible enforcement action. It should be noted that while the rules do allow for an extension until June 15th, extensions are no longer automatically granted with an electronic submission. A specific written request must be submitted to the Department by May 1st and a site-specific approval must be received.
What is the purpose of the Emission Statement rule N.J.A.C. 7:27-21?
Most of the state of New Jersey is in “non-attainment” of the ozone National Ambient Air Quality Standards (NAAQS). Since 1990, the Clean Air Act has required states with designated ozone non-attainment areas to gather emissions data of volatile organic compounds (VOC) and oxides of nitrogen (NOx). These two air contaminants react in the presence of sunlight to form ozone in the lower atmosphere, the troposphere, where it affects human health. The Clean Air Act also requires a periodic, comprehensive inventory of all air pollutant sources in the state. The Emission Statement rule, N.J.A.C. 7:27-21, establishes regulations for the annual reporting of air contaminant emissions from stationary sources. Emission Statements provide an estimate of actual annual emissions to assist in the monitoring of the State’s progress toward the e
mission reduction goals and attainment of the NAAQS.
Who must report?
The NJDEP requires an Emission Statement from any facility whose actual emissions or facility wide potential-to-emit (PTE) meet or exceed any of the following thresholds (N.J.A.C. 7:27-21.2):
5 tons per year of Lead (Pb)
10 tons per year of VOC
25 tons per year of NOx
100 tons per year of any of the following – CO, NH3, PM2.5, PM10, SO2, or TSP
What contaminants are reported?
The air contaminants reported in the Emission Statements include Carbon Monoxide (CO), Sulfur Dioxide (SO2), Ammonia (NH3), Particulate Matter (TSP, PM10, PM2.5), Lead (Pb), Volatile Organic Compounds (VOC), Oxides of Nitrogen (NOx), Carbon Dioxide (CO2), Methane (CH4) and 36 toxic air pollutants (TAPs). Depending upon the facility classification (e.g., a major Title V site or a minor non-Title V site), there are varying requirements for air contaminants that must be reported.
If your facility needs assistance with preparing and submitting the 2019 NJDEP Air Emission Statement, please contact Baron Environmental Associates at (908) 508-9000 or send an email to any of Baron's key staff Contacts.