On the first Friday of every quarter, the NJDEP Air Permitting Group holds an Industrial Stakeholders Group (ISG) meeting. In keeping with social distancing rules this quarter the meeting was held via Microsoft Teams. Baron had a representative present at this meeting. Below is a summary of the discussions:
Fumigation / Air toxics rule:
The NJDEP is in the process of preparing an update to the regulations related to Fumigation and Air Toxics. At this time, the rule has not been proposed, however it is currently drafted and under legal review. This rule will address the need for clarification for fumigation and how it applies to warehouses and manufacturing facilities. Additionally, this rule will add a few new chemicals to the Air Toxics list including Hydrogen Sulfide (H2S) and n-propyl bromide. Finally, this rule will include requirements for additional reporting for a few substances to be filed in annual Emission Statements.
The Department released the latest version of the organization chart in their slides. At this time, documents have not been uploaded to the NJDEP's website. However, when they are released they will be found here.
Update to the Risk Screen Worksheet:
The NJDEP updated and released the first level risk screening document titled NJDEP Division of Air Quality Risk Screening Worksheet for Long-Term Carcinogenic and Noncarcinogenic Effects and Short-Term Effects in June of 2020. The link below is a fact sheet highlighting the specific changes that the document underwent:
Beyond this, the Department also mentioned that there are likely going to be additional changes made to this document, however they were waiting for the release of data from the California EPA on certain chemical toxicities. Therefore any future changes to this document would likely not be proposed until 2021 (after which they would still need to go through a public comment and approval period).
Environmental Justice (EJ):
This topic was a hot button issue at this quarter's meeting as it follows the recently approved legislation from the NJ Senate. However, at this time, the process to address this program has only just begun and the Department was unable to provide a great deal of detail regarding the potential changes.
Currently, the NJDEP as a single entity is working to address the new legislation and prepare rules. This means that rules are being devised by Air, Waste, Water Quality and all other individual programs as a single entity. As such, there is a possibility that individual departments will need to update their own rules to address how changes to EJ will specifically effect their programs. Combined, these two facts mean that the timeline for the new EJ rule remains a complete unknown.
The Department did however, release a preliminary list of EJ municipalities on 9/30/20. This can be found here: https://www.nj.gov/dep/ej/docs/furthering-the-promise.pdf within the NJ Document, "Furthering the Promise: A Guidance Document for Advancing Environmental Justice Across State Government”.
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