Permit Compliance Issues Identified

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Much of the work we perform at enviroCOP®, LLC deals with addressing and correcting non-compliance identified by the New Jersey Department of Environmental Protection (NJDEP).  Much of this non-compliance can be avoided if companies took the time to look at their operations to ensure that if environmental permits are required, that the appropriate permit is obtained prior to a change in their operations.  For example, installation of an emergency generator may make great sense from a continuity of operations perspective but failing to obtain an air pollution permit from the NJDEP could expose you to substantial penalties going back as far as 5 years in some instances.  Another area where we at enviroCOP®, LLC find non-compliance is with modification of existing equipment. For example, substituting a new more efficient boiler for an existing boiler may make good economic and environmental sense but failing to modify your existing air pollution permit could subject you to an enforcement action from NJDEP with penalties.

When it comes time to renew your air pollution permit, especially if it’s a preconstruction air pollution permit (PCP) don’t simply send in your payment to renew the permit.  First check and see if a “General Permit” is available for your situation.  General Permits are less expensive and could save you facility a substantial amount of money over time.  enviroCOP®, LLC can help you determine if a General Permit is appropriate. 

Unpermitted modifications do not solely fall within the air permitting arena and could involve other NJDEP programs.  For example, changes to site plan for a solid waste or recycling facility.  Even simple modifications like changing traffic direction or the location or the volume of material recyclable could subject your facility to substantial penalties.

Finally, there is a certain amount of relief when you finally get your permit or approval from the NJDEP but the worst thing you can do is to simply put it in a drawer and forget about it.  It’s been our experience that permit holders fail to review their permits, understand its contents and ensure that all of permit conditions are being met.

At enviroCOP®, LLC C we are here to help you with your compliance concerns.  Contact us today at: www.enviroCOP.comor by calling (609) 304-9662.

Understanding Indirect User Requirements in New Jersey

SQGs ARE REQUIRED TO RE-NOTIFY EVERY 4 YEARS STARTING SEPTEMBER 1, 2021