In an effort to address ambient levels of hazardous air pollution in the state of New Jersey, the New Jersey Department of Environmental Protection (NJDEP) adopted in August, 2017, revisions to many of its regulations. The rulemaking consisted of three major categories: 1) exemptions from air emission control and permitting requirements to improve resiliency in emergency and similar situations, and provide flexibility for facilities to use low-emitting temporary and portable equipment; 2) updates to Hazardous Air Pollutants (HAP) reporting thresholds using the most recent science-based methodologies; and 3) repeal of N.J.A.C. 7:27-30, CAIR NOx Trading Program, and 31, NOx Budget Program, which have been Federally preempted. Additional proposed amendments conform the administrative penalties at N.J.A.C. 7:27A-3.10 to the proposed rules, and correct errors and inconsistencies throughout N.J.A.C. 7:27. In addition, the NJDEP is currently in the process of adopting new dispersion modeling and risk assessment technical manuals that will result in new modeling policies and procedures. Some the changes that are expected to affect the air permitting process include:
· Revised HAP reporting thresholds. For example, the new reporting threshold for benzene changes from 400 lbs/year down to 6 lbs/year.
· New requirements for facility-wide risk assessments. Title V operating permits are now required to evaluate all emissions of HAP upon major modifications and 5-year renewals.
· HAPs listed in emission statements but not necessarily permitted may be evaluated as part of a facility-wide risk assessment if the facility has many pieces of equipment that are deminimus but add up to greater than the emission statement reporting threshold.
· Risk minimization plans will be required for major facilities that show a risk above the established guidelines.
· Tanks are required to list the maximum lb/hr emission rate expected to occur for HAPs with acute (short-term) reference concentrations.
· Revisions to the Department’s Risk Screening Worksheets will most likely be more conservative and result in more permits needing additional review.
EnviroCOP can help you navigate these changes to the air permitting process. If you are interested, we are currently offering a complimentary meeting and facility walk-through to discuss these and any other environmental compliance needs.
We are enviroCOP, LLC, an environmental compliance consulting company that can assist you with your environmental compliance needs. Our staff are retired, former high-level managers from the New Jersey Department of Environmental Protection. We can assist you in submitting and obtaining required air permits and working with the NJDEP.
For further information or to contact us, please see our website at http: www.enviroCOP.com or call us at (609) 304-9662.