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Frank Steitz

Air Quality Permitting Program

10/12/2012

AQ PERMITTING UPDATE

10/12/12

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

10/12/12

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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

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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

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TRACKING CHANGES IN AIR PERMITSApproved

Modified

List of Changes

Marked-Up

10/12/12

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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

10/12/12