New Jersey Air Quality Updates – Have You Missed Anything?

Within the past couple of years, the New Jersey Department of Environmental Protection (NJDEP) has made several updates to its air quality practices and documents that may have flown under the radar on their own.  Read on to make sure you haven’t missed any changes that could affect your facility’s future reporting or permitting obligations.

Annual Emission Statements

Each year, NJDEP requires that facilities in New Jersey that emit above certain air contaminant reporting thresholds submit an Emission Statement for the previous year.  During the implementation of an electronic submittal system, NJDEP implemented an informal policy of granting 30-day extensions for submittal of the Emission Statement.  However, this extension was not expected to be permanently implemented into New Jersey rules and has been deemed no longer necessary with the implementation of the electronic reporting system.  Title V facilities in New Jersey should continue to plan Emission Statement development around the original due dates of May 15 for electronic submittals and April 15 for paper submittals.  For a paper submittal, a formal request must be submitted to NJDEP detailing the reasons an electronic submittal would cause hardship for the facility.  Similarly, if an extension is required, a formal request must be submitted to NJDEP by May 1 for electronic submittals or April 1 for paper submittals, and the request must detail the reasons the original deadline would cause hardship for the facility.

Regarding the contents of Emission Statements, to satisfy U.S. EPA’s requirements for their Emissions Inventory System, NJDEP is requiring additional details.  For example, facilities will be required to include technical information on emission points that may not currently exist in NJDEP RADIUS from previous years.  NJDEP has provided a guidance document to help with complexities associated with atypical, non-combustion, significant sources.

Risk Screening Worksheets

Risk screening worksheets (RSWs) are used for estimating health risks from air toxics during the permit application process.  This is traditionally expected of major source permitting and permit renewal if any changes have been made to the facility.  However, minor sources must also complete a risk assessment under certain circumstances [e.g., emitting new hazardous air pollutants (HAP), increases in existing HAP, changing stack parameters, emitting HAP in excess of the reporting threshold].  NJDEP provides two types of worksheets: The Cancer Risk Screening Worksheet for Nonroad Diesel Engines and the NJDEP Division of Air Quality Risk Screening Worksheet for Long-Term Carcinogenic and Noncarcinogenic Effects and Short-Term Effects.  In August 2018, NJDEP released a revised version of the latter that included changes to unit risk factors, long-term reference concentrations, and short-term reference concentrations.  The nonroad diesel engine RSW is not affected by this update.  The revisions are also incorporated into NJDEP’s “Toxicity Values for Inhalation Exposure” resource.  If you have used this RSW in the past, it is recommended that you download the most recent version dated August 2018.  Download links for RSWs and the associated resources can be found on NJDEP’s website.

NJDEP has proposed a new version of the NJDEP Division of Air Quality Risk Screening Worksheet for Long-Term Carcinogenic and Noncarcinogenic Effects and Short-Term Effects.  Proposed changes include new requirements for use of the RSW, inclusion of several compounds not previously listed in the RSW, and updated toxicity values.  Refer to NJDEP’s fact sheet for a full list of proposed changes and supporting information.  NJDEP has also begun development of an RSW for natural gas combustion sources in order to provide more realistic risk potentials for affected sources than are currently available using the existing RSW.

General Permits and General Operating Permits

Since 2018, NJDEP has updated and revised several of its pre-approved general permits (for non-major facilities) and general operating permits (for major facilities), as listed below.  Facilities may only hold one of each general permit type at any time and must submit a new registration if adding, replacing, or modifying any sources.  Facilities may hold more than one of a general operating permit type, but each general operating permit only permits equipment belonging to one emissions unit.

If your facility possesses one of the following permits and you are making a change that would require registering for a new permit, the revisions may be applicable to your project.

• GP-004A – Fuel Dispensing Facilities
• GP-004B – Fuel Dispending Facility Equipped with a Phase I Vapor Recovery Control System
• GP-005A – Emergency Generator(s) Burning Distillate Fuels
• GP-005B – Emergency Generator(s) Burning Gaseous Fuels
• GP-013A – Non-HAP Dry-cleaning
• GP-015A – Plating, Etching, Pickling and Electropolishing Operations
• GP-016A – Manufacturing and Materials Handling Equipment
• GOP-002A – Manufacturing and Materials Handling Equipment
• GOP-003 – Emergency Generator
• GOP-004 – Emergency Generator Burning Gaseous Fuels

NJDEP has replaced or has proposed replacing or discontinuing several general permits and general operating permits as well.  If your facility possesses one of the following permits and you are making a change that would require registering for a new permit, these changes may be applicable to your project.

• GP-008 – Site Remediation Activities for Gasoline Contamination at Vehicle Fueling Stations (SVE)
• GP-009A – Boiler(s) and Indirect Fired Process Heater(s) Each Greater Than or Equal to 10 MMBTU/hr and Less Than 50 MMBTU/hr Combusting Gaseous Fuel (replaced by GP-009B)
• GP-019 – Portable Equipment
• GP-021 – Combined Heat and Power Combustion Turbine(s) less than or equal to 65 MMBTU per hour
• GP-022 – Combined Heat and Power Stationary Spark Ignition Reciprocating Engine(s) less than or equal to 65 MMBTU per hour
• GOP-005 – Combined Heat and Power Combustion Turbine(s) less than or equal to 65 MMBTU per hour
• GOP-006 – Combined Heat and Power Stationary Spark Ignition Engine(s) less than or equal to 65 MMBTU per hour

If you’d like to learn more about these updates and how they affect your New Jersey facility, don’t hesitate to reach out to ALL4.  You can contact me at (610) 933-5246, extension 173, or by email at jmartin@all4inc.com.