AQ Permitting Update

1. AQ Permitting Update Frank Steitz Air Quality Permitting Program 10/12/2012

2. 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)

3. 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

4. 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

5. 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

6. BAP Transformation Efforts (Completed) • Streamlining of Compliance Plans – on going • Templates for Federal Rules • Other Templates • Better Permits • Accurate • Complete • User-friendly

7. 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

8. 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

9. 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. 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

11. 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

12. 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

13. 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

14. 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

15. 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)

16. Tracking Changes in Air Permits Approved Modified Marked-Up List of Changes

17. 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