What is it and who is affected?
NJDEP issued an update on August 22, 2018 discussing a change to pre-NJEMS air permits (permits beginning with PCP96 or PCP97). The NJDEP is actively working on fixing an issue which will result in revised renewal invoices that may now be higher.
The reason the NJDEP is issuing an enforcement change to these permit types is because these specific permits no longer contain all the applicable requirements, and the current renewal invoices that have been sent out for expired/expiring permits are not correct and may actually be much higher. Prior to 1998, facilities used paper forms to complete air permit applications. The DEP started the NJEMS (New Jersey Environmental Management System) and the RADIUS system in order to allow electronic submitting of air permit applications. Later the pre-NJEMS permits were made within the NJEMS for facilities, which ended up only listing one piece of equipment and no compliance plan.
Steps NJDEP is taking to resolve this issue:
-For these permit types, the equipment list will be corrected to show the actual number listed on the paper permits.
-Revised renewal invoices – which will correct future renewal invoices and fees
How can PTP help and what should you do?
If your facility has an expired pre-NJEMS permit or an active air permit application, we can help keep or put your facility back into compliance. Your renewal invoice (as stated by the NJDEP) will be adjusted accordingly. If your facility is only listed with one piece of equipment and there are more, your new invoices will reflect the new amounts, which will be much higher. We can also evaluate and let you know if your facility qualifies for a General Permit, which is a simplified and less expensive permit option.
Remember, if your permit is expired or if your permitted source(s) were modified and not reported, then you are out of compliance and should IMMEDIATELY call us for help. Failure to keep in compliance could result in enforcement actions and penalty assessments from the NJDEP. The DEP currently maintains approximately 5,000 pre-NJEMS permits, of which 800 are expired.