AQ PERMITTING UPDATE

Frank Steitz Air Quality Permitting Program 10/12/2012 10/12/12 1

FOUR SECTIONS OF AIR QUALITY PERMITTING • • Bureau of Air Permits (BAP) – Operating Permit Section (OPS) – Preconstruction Permit Section (PPS) Bureau of Technical Services (BTS) – Risk Assessment Section (RAS) – Emission Measurement Section (EMS) 10/12/12 2

FEDERAL RULES AND GUIDANCE • • • • New Source Performance Standards (NSPS) • 91 Source Categories National Emission Standards for Hazardous Air Pollutants (NESHAP aka MACT) • 120 Source Categories Control Technique Guidelines • 17 as of March 2009 Every Month EPA promulgates additional standards so these numbers will increase 10/12/12 3

• • • • • • ITEMS DISCUSSED DURING PERMIT STAKEHOLDER PROCESS Permit Format Streamlining of Compliance Plans Level of Monitoring Level of Monitoring & Enforcement History Permit application supplemental information Redefining insignificant sources in NJ Title V program 10/12/12 4

ITEMS DISCUSSED DURING STAKEHOLDER PROCESS • • • • • • • • On-site pre/post application meetings Developing General Operating Permits Shortening Permit Processing Time Classifying More Changes as Minor Modifications Like-kind Replacement of Equipment Minimizing Permit appeals Air Toxics Cost Benefit Analysis 10/12/12 5

BAP TRANSFORMATION EFFORTS (COMPLETED) • Streamlining of Compliance Plans – on going • • • Templates for Federal Rules Other Templates Better Permits • Accurate • Complete • User-friendly 10/12/12 6

BAP TRANSFORMATION EFFORTS (COMPLETED) • • • General Permits (GPs & GOPs) • Combined Heat & Power (Engines & Turbines) – Pre-application Meetings • On-site if necessary Completeness Checklists developed and available on Permitting web page www.state.nj.us/dep/aqpp 10/12/12 7

BAP TRANSFORMATION EFFORTS (COMPLETED) • • • General Guidance • • • • Construction, Repair & Maintenance Temporary Equipment @ Major Facilities Greenhouse Gases PM-2.5

Permit Review Procedures • PSD Delegation • Hearing Requests Posted on web page http://www.state.nj.us/dep/aqpp/permitguide.html

10/12/12 8

BAP TRANSFORMATION EFFORTS (COMPLETED) • • • • Engaging Overburdened Communities Enhanced Notification Procedure • • EJ Communities Facilities of Interest Promote Engagement with Community • Sharing of Applications and Draft Permits • Conduct Informational Meeting with Community Additional Air Quality Modeling to assure no adverse air impacts 10/12/12 9

BAP TRANSFORMATION EFFORTS (COMPLETED) • Imaging of Paper Permits into PDF Documents • • • Project using State Funds and EPA grant money scan permits issued on paper prior to 1998 Immediate goal is to make these permits available to DEP staff on NJEMS system Eventually these permits will be available on Web 10/12/12 10

BAP TRANSFORMATION EFFORTS (IN PROGRESS) • Netting Analysis Tool for Subchapter 18 (emission offset rule) permits • Standardized calculation tool for Netting Analysis • • • • • Removes calculation burden/errors Common format for NJDEP staff and facilities Facilitates on-site maintenance of netting analysis Better enforceability Pilot Testing with 8 facilities currently underway 10/12/12 11

BAP TRANSFORMATION EFFORTS (IN PROGRESS) • General Permits (GP) and General Operating Permits (GOP) • New GOP for Emergency Generators • • Updated GP for Boilers 10-50 MMBtu/hr Updated GP for Gasoline Dispensing 10/12/12 12

BAP TRANSFORMATION EFFORTS (IN PROGRESS) • Developing module for the Department's e-Government portal to allow electronic submittal of all air permit applications • • • • Case-by-case permits (major & minor) and annual emission statements currently prepared electronically but must be mailed to department General Permits are already submitted via this portal Internal Testing is complete Pilot Testing with facilities set to begin this Fall 13 10/12/12

BAP TRANSFORMATION EFFORTS (IN PROGRESS) • Track Permit Changes Utility • • • • Requested by permit applicants in both 2011 NJDEP Transformation Initiative and 2012 Enforcement and Permitting joint stakeholder session Shows any changes in facility’s compliance plan Automate the comparison between approved and draft permits Generate a list of changes that shows the differences 10/12/12 14

BAP TRANSFORMATION EFFORTS (IN PROGRESS) • Track Permit Changes Utility • • • • • Beta Testing (Completed) Install on AQPP Staff PCs (Completed) Develop Instruction Manual (Completed) Staff Training (September 27, 2012) Roll Out to Facilities (October 2012) 10/12/12 15

TRACKING CHANGES IN AIR PERMITS Approved Modified Marked-Up List of Changes 10/12/12 16

EMS TRANSFORMATION EFFORTS (COMPLETED) • Development of Electronic Reporting Tool (ERT) using EPA Grant • Standardize protocols and report submittals • • • • Anticipate reductions in review/approval times Automate calculations for standard methods Dovetails into EPA initiatives for mandatory electronic reporting of results Second Training Session and Webinar held October 1, 2012 17 10/12/12