Is your facility operating air emission sources under the old paper permits issued prior to 1998? The New Jersey Department of Environmental Protection (NJDEP) is beginning to review these air permits closely to ascertain the accuracy of the information that was approved over 20 years ago. These old permits may be missing compliance plans, might not reflect an accurate equipment inventory, and might not accurately reflect the current operations (since there may have been changes to the facility operations over the years that were not reflected in the air permits by means of a permit modification).
NJDEP is currently reviewing the non-expired permits and adjusting the equipment inventories in the New Jersey Environmental Management System (NJEMS) to ensure proper invoicing. Additionally, the Department is reviewing the emission source inventory to determine if a general permit is applicable. If a general permit is available for that emission source category, they are notifying the facility to apply for the general permit (instead of renewing the preconstruction permit). In addition, for facilities with expired permits, the Department is notifying Compliance and Enforcement for a review of the permit inventory and a subsequent inspection of the facility operations.
If you have old PCPs, we recommend that you begin a review of emission sources covered in those permits to ensure that all significant sources onsite are correctly permitted. After this review, apply for general permits (if/where applicable), apply for new PCPs or modify the existing PCPs, and/or request cancellation of permits for those emission sources that are no longer onsite.
Trinity can help you perform a review of your old preconstruction permits and help develop a strategy for compliance. If you have any questions regarding this or any other air permitting/compliance topic, please feel free to reach us at (609) 318-5500 or via email.