Air Permitting Industrial Stakeholders Group (ISG) Feb. 5th Meeting Summary






The New Jersey Department of Environmental Protection (NJDEP) held the latest iteration of its Industrial Stakeholders Group Meeting for Air Permitting on Friday February 5th. Below is a summary of the topics discussed during this meeting.


Rule Updates:


Outer Continental Shelf - Currently air regulations are regulated by the US Environmental Protection Agency (EPA) for this region. The NJDEP has submitted a request for delegation to the EPA and an agreement is currently in discussions. The hope is that this will be finalized by Summer 2021.


Air Toxics - The NJDEP expects a proposal to be issued before Spring of 2021 for the following changes:

  1. Fumigation operations will be covered by the air permitting program. Risk screening will need to be passed which will require min stack heights and permit requirements will apply.

  2. New toxics Sulfuryl Fluoride, n-propyl bromide, Hydrogen sulfide will be added to the screening worksheet.

  3. New substances will be included in the Emission Statement (details on this item were not discussed during this meeting).

Consumer Products, AIMS, Aftermarket Catalysts - Three rules will be included in one proposal. The NJDEP expects this proposal to occur in Fall 2021.


Protecting Against Climate Threats (PACT)

  1. A new monitoring and reporting rule will address greenhouse gas and short lived climate pollutant (SLCP) emissions for fossil fuel distributors, electric generation, gas public utilities, and significant sources including waste management (methane) and refrigeration systems. Specifically, facilities that have refrigeration systems would have to submit a report documenting sources with refrigerant charges greater than 50-lbs to the state. A proposal is expected in the Spring of 2021, with reporting potentially due as early as next year.

  2. Climate Pollutant Rules (CPR): Per the NJDEP, the timeframe for these changes is: "Sooner Rather than Later".

  3. Fossil Fired electrical generating units -

  4. A newly introduced CO2 emission limit regardless of fuel that ratchets down over time.

  5. Commercial industrial boilers -

  6. The NJDEP plans a phase down of small (<5 MMBTU) boilers. When small boilers are replaced, facilities will need to obtain a non-fossil fuel boiler.

  7. The plan is to impose conditions for permit approval that will allow facilities to obtain a fossil fuel boiler if it can be proven a that it would be a technical infeasibility to obtain a non-fossil fuel boiler.

  8. Ban on sale of No.4 and No. 6 liquid heavy fuels

A final note on the rule updates is that per the NJDEP, this is the first time the Department has ventured into regulation of CO2 emissions, however it is not expected to be the last.


General Permit (GP) and General Operating Permit (GOP) Updates:


The DEP has released a new GOP-009 for a large boiler greater than 10 MMBtu/hr and less than 50 MMBtu/hr. This permit has been available since November 2, 2020 and applies to natural gas and oil during curtailment. Unlike GP's the GOP is for one boiler at a time but a facility can have more than one GOP.


The NJDEP is also proposing a discontinuation of the GP-020 R&D general permit. This permit does not currently address risk or potential to emit thresholds from all Hazardous Air Pollutants (HAPs) consistent with newly approved thresholds. Nor does it include PM10 or 2.5 emission limits. There are only 27 active GP-020's in the state so the demand is low. Any facilities with a current GP-020 will need to reapply under a preconstruction permit (PCP).


The NJDEP plans to introduce an online registration service for used oil space heaters less than or equal to 0.5 MMBtu/hr, R-001. This is applicable to units that utilize used oil produced onsite. According to the NJDEP, it should be available by the end of the 1st quarter of 2020 at the latest.


Gas Station Air Permitting:


For facilities that have a vapor recovery system that isn't compatible with ORVR, it must be removed from service and a new permit must be applied. This rule was announced in December 2017 and had a compliance due date of December 2020. Facilities that have not yet made this change are operating out of compliance.


Other Topics Discussed:


The NJDEP indicated that there is currently a shortage of personnel in the permitting group due to turnover. There may be delays to permit approvals in the near future.


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