The New Jersey Department of Environmental Protection (NJDEP) held its Industrial Stakeholders Group (ISG) meeting on June 6, 2025. During the meeting, NJDEP provided updates on the following topics:
- Emergency Generator Guidance Update
- Drycleaner GP Update
The following sections provide a summary of each of the topics discussed:
Emergency Generator Guidance Update
NJDEP has published guidance regarding the inclusion of hazardous air pollutant (HAP) emissions and diesel particulate matter (DPM) from emergency generators in the potential-to-emit (PTE) section of air permit applications and health risk assessments. There are updates to this memo which will be posted soon on NJDEP’s website. The update states that HAP and DPM emissions listed in the PTE section of an air permit application should be included in a health risk assessment, including risk screening, refined risk, and facility-wide risk if any one of the following is met:
- The facility is subject to the Environmental Justice (EJ) Rule
- The total maximum rated heat input for all emergency generators at the facility is
- 100 MMBtu/hr or greater where the emergency generators combust distillate fuels only
- 70 MMBtu/hr or greater where the emergency generators combust gaseous fuels or a combination of distillate and gaseous fuels.
Emergency generators that are subject to this requirement must be significant pieces of equipment per N.J.A.C. 7:27-8 and/or N.J.A.C. 7:27-22, meet the definition of “emergency generator” per N.J.A.C. 7:27-19.1, and operate consistent with the provisions of N.J.A.C. 7:27-19.2(d).
Drycleaner GP Update
Information regarding the general permit for dry cleaners was reiterated in this ISG meeting.
On December 18, 2024, the United States Environmental Protection Agency (USEPA) issued “
Perchloroethylene (PCE); Regulation Under the Toxic Substances Control Act (TSCA)”. This regulatory action aims to phase out consumer, commercial, and dry-cleaning use of PCE over a 10-year time frame. Use of PCE for dry cleaning and spot cleaning will be phased out in stages beginning with prohibition of PCE use in machines acquired after June 16, 2025, followed by prohibition of PCE use in 3rd generation machines, ending with prohibition of all manufacture, processing, distribution, and/or use of PCE after December 19, 2034.
Currently NJDEP offers a general permit (GP-12A) for perchloroethylene (PCE) drycleaning equipment. There are approximately 170 GP-012A permits issued in New Jersey right now and approximately ninety-five (95) preconstruction permits for dry cleaning equipment using PCE. After June 16, 2025, no new GP-012A (this general permit will be discontinued from the portal) or preconstruction permits will be issued for dry cleaning equipment using PCE. Current permits for 3rd generation dry cleaning equipment will be automatically terminated on December 20, 2027. Finally, current permits for 4th generation dry cleaning equipment will be automatically terminated on December 19, 2034. In summary:
Phase 1: Prohibition of industrial and/or commercial use of PCE in dry cleaning machines acquired after June 16, 2025. New permit applications for dry cleaning equipment using PCE will not be accepted by NJDEP.
Phase 2: Prohibition of industrial and/or commercial use of PCE in dry cleaning and related spot cleaning in 3rd generation machines. All permits for 3rd generation machines using PCE will be automatically terminated, and the operation of these units must cease.
Phase 3: Prohibition of the manufacturing (including importing), processing, distribution in commerce, or industrial and/or commercial use of PCE for dry cleaning and spot cleaning. All permits for 4th generation machines using PCE will be terminated.
Open Discussion
The ISG meeting ended with an open discussion. The following topics were discussed:
Environmental Justice (EJ)
Currently, there are not a lot of updates/changes with regard to EJ. The Air and Solid waste departments are currently handling all of the existing EJ applications. NJDEP will be revamping the EJ webpage likely at the end of the month. The new webpage should be cleaner, more succinct, and separate the rule/law form the NJDEP published guidance. If a facility has questions about EJ applicability or the EJ process, they can reach out to
Jillian Alexander.
Demand Response Permitting
The NJDEP emphasized that if an emergency generator is permitted as an emergency generator through a general permit or a preconstruction permit, that generator cannot participate in demand response. In order to operate in demand response, you must apply for a preconstruction permit and ensure that the correct conditions are in the permit to allow for demand response operation. These generators are subject to more stringent emission limits. More information on this matter can be found in
NJDEP’s Compliance Advisory published on May 23, 2016.
Technical Manual 1005
The NJDEP is currently updating Technical Manual 1005 (Guidelines for Continuous Emissions Monitoring Systems [CEMS], Continuous Opacity Monitoring Systems [COMS], Periodic Monitoring Procedures [PMPs] and Annual Combustion Adjustments [ACAs]). The revised manual is anticipated to be released later this year.
Should you or your facility have any questions pertaining to any of the above topics, please contact Trinity Consultants’
Princeton Office at
609.318.5500.
