11

N.J.A.C. 7:27-21N.J.A.C. 7:27-21Possible RevisionsPossible Revisions

ISG MeetingISG Meeting

September 14, 2010September 14, 2010

22

Reasons for RevisionReasons for Revision

To update rule to meet federal requirementsTo update rule to meet federal requirements To fix errors in the rule (major and minor To fix errors in the rule (major and minor

issues)issues) To make the data more usefulTo make the data more useful To update rule language/definitions to be more To update rule language/definitions to be more

consistent with the other Air rulesconsistent with the other Air rules

33

Revisions Already Proposed But Not Revisions Already Proposed But Not AdoptedAdopted

Requiring PM2.5 and ammonia to be reported Requiring PM2.5 and ammonia to be reported at source level, not facility levelat source level, not facility level Federal requirementFederal requirement

Requiring the 36 Toxic Air Pollutants (TAPs) Requiring the 36 Toxic Air Pollutants (TAPs) to be reported at source level, not facility level to be reported at source level, not facility level More useful for Department useMore useful for Department use Consistent with criteria pollutantsConsistent with criteria pollutants May be possible federal requirement in the futureMay be possible federal requirement in the future

44

Additional Revisions Being Additional Revisions Being ConsideredConsidered

Report PM condensible, PM10 filterable, and PM2.5 Report PM condensible, PM10 filterable, and PM2.5 filterablefilterable Required by EPA’s AERR for 2009 emissionsRequired by EPA’s AERR for 2009 emissions Would require RADIUS enhancement for AutocalcWould require RADIUS enhancement for Autocalc

Remove references to paper submittalRemove references to paper submittal Last paper submittal was more than 5 years agoLast paper submittal was more than 5 years ago Still keep paper submission for confidential dataStill keep paper submission for confidential data

Remove 1 month extensionRemove 1 month extension DEP has 12 months to report data to EPA instead of the 17 DEP has 12 months to report data to EPA instead of the 17

months before, per AERRmonths before, per AERR For 2009 ES, 46 request, only 5 approved (most of the For 2009 ES, 46 request, only 5 approved (most of the

denied because request was after May 1)denied because request was after May 1)

55

Additional Revisions Being Additional Revisions Being ConsideredConsidered

If reporting for TAPs is changed to source If reporting for TAPs is changed to source level, then the applicability could be changed level, then the applicability could be changed to source level, instead of facility level, to be to source level, instead of facility level, to be consistent to permittingconsistent to permitting

Delete references for before 2003, 2005Delete references for before 2003, 2005 Old referencesOld references

Delete the requirement of facility coordinatesDelete the requirement of facility coordinates GIS has most of them alreadyGIS has most of them already May require RADIUS enhancementMay require RADIUS enhancement

66

Update Language/Definitions To Be Update Language/Definitions To Be Consistent Other RulesConsistent Other Rules

Hours, days, and weeksHours, days, and weeks Quarterly throughputQuarterly throughput Winter seasonWinter season Change "Control apparatus" to "Control Device"Change "Control apparatus" to "Control Device" Add definitions for diesel fuel, including biodieselAdd definitions for diesel fuel, including biodiesel "Gasoline" include 10% Ethanol and perhaps E85 in "Gasoline" include 10% Ethanol and perhaps E85 in

that definitionthat definition Expand PM2.5 and PM10 definitions to specifically Expand PM2.5 and PM10 definitions to specifically

include condensiblesinclude condensibles TSPTSP

77

Update Language/Definitions To Be Update Language/Definitions To Be Consistent Other RulesConsistent Other Rules

For "Toxic Air Pollutant“, add the commonly used For "Toxic Air Pollutant“, add the commonly used term "TAP“term "TAP“

7:27-21.2(d) "... solely a retail gasoline dispensing 7:27-21.2(d) "... solely a retail gasoline dispensing facility is exempt ..."facility is exempt ..."

Include the DEP street address and street zip code for Include the DEP street address and street zip code for deliveries (FedEx, UPS, etc.)deliveries (FedEx, UPS, etc.)

Include language that emission statements match Include language that emission statements match permits with exceptionspermits with exceptions

Define "Predictive Emissions Monitoring“Define "Predictive Emissions Monitoring“ Clarify “applicable reporting threshold” and Clarify “applicable reporting threshold” and

“reporting threshold”“reporting threshold”

88

Update Language/Definitions To Be Update Language/Definitions To Be Consistent Other RulesConsistent Other Rules

Change Hydrochloric Acid to "Hydrochloric Change Hydrochloric Acid to "Hydrochloric Acid as Hydrogen Chloride" or just Hydrogen Acid as Hydrogen Chloride" or just Hydrogen ChlorideChloride

1,1,1-Trichloroethane - add (Methyl 1,1,1-Trichloroethane - add (Methyl Chloroform)Chloroform)

Polychlorinated biphenyls - add (PCB's)Polychlorinated biphenyls - add (PCB's) Polycyclic organic matter - add (POM)Polycyclic organic matter - add (POM) OthersOthers

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Questions/Comments and Next StepQuestions/Comments and Next Step Email comments and questions to Email comments and questions to

emis_statement@dep.stateemis_statement@dep.state by Dec. 1 by Dec. 1 Include any RADIUS enhancements that may be beneficial Include any RADIUS enhancements that may be beneficial

to Emission Statement reportingto Emission Statement reporting Have a compiled summary of comments and Have a compiled summary of comments and

questions and share at next ISG meetingquestions and share at next ISG meeting Will meet with management to go through list of Will meet with management to go through list of

changeschanges Share at future ISG meeting the “final” list prior to Share at future ISG meeting the “final” list prior to

rulemakingrulemaking Need for separate emission statement meeting or is Need for separate emission statement meeting or is

the ISG Meeting good enough as the platform for the ISG Meeting good enough as the platform for outreach?outreach?