On June 29, 2020, the New Jersey Department of Environmental Protection (NJDEP) finalized a revision to its Air Quality Risk Screening Worksheet for Carcinogenic Effects and Noncarcinogenic Long-Term and Short-Term Effects (Worksheet). The Worksheet Assessment is one of the three types of risk assessments that are conducted if air toxics are emitted above their applicable reporting thresholds within a preconstruction permit application pursuant to N.J.A.C. 7:27-8.5(b) or an operating permit application pursuant to N.J.A.C. 7:27- 22.3(cc). The other two risk assessments that could be conducted are a Refined Risk Assessment and a Facility Wide Risk Assessment, both of which add cost and time to the application approval process.
The NJDEP Risk Screening Worksheet Fact Sheet can be found here, and the revisions are summarized below:
The minimum stack height for sources to use the Worksheet has been increased to 15 feet from 10 feet as stack heights less than 15 feet do not provide sufficient dispersion. This is not expected to impact the application process as most stacks in air pollution control permit applications are currently greater than 15 feet tall.
Carbonyl sulfide and 1-bromopropane (n-propyl bromide or nPB) have been added to the Worksheet on the basis of 2017 toxicity data from the California Environmental Protection Agency (CalEPA) and the Agency for Toxic Substances and Disease Registry (ATSDR), respectively. Compared to carbonyl sulfide, the addition of nPB is expected to have more impact on the New Jersey DEP air permitting process due to its potential for significant use in dry cleaning and other commercial operations.
The Unit Risk Factor (URF) for “nickel and compounds” has changed, and is the most stringent listed URF for any nickel compound. Additionally, nickel refinery dust and nickel subsulfide have been added to the Worksheet along with their corresponding URFs.
Toxicity Values for Inhalation Exposures for thirteen (13) listed chemicals have been updated as a result of published toxicity values. All revised toxicity values are lower than the previous values. Data sources for this update came from: CalEPA’s Office of Environmental Health Hazard Assessment, the U.S. Environmental Protection Agency’s Integrated Risk Information System (IRIS) or the U.S. Department of Health and Human Services ATSDR.
Taken as a whole, the revisions make the worksheet more conservative and will result in more applications receiving a result of “Needs Further Evaluation” or “NFE”. More applicants will be required to conduct refined health risk analyses in order to show negligible risk to public health and the environment. Applicants utilizing any toxic air pollutant listed in N.J.A.C. 7:27-17 should properly plan for the time and costs to complete full risk assessments if necessary.
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