Attachment 5 Checklist for Permit Applications 7.25.24.docx

DOCX document 58 KB Posted

Attached to
T1368 Technical Support for Air Quality, NJDEP
Solicitation number
24DPP00948
Issued by
Mercer County, New Jersey

About this file

This document is an Administrative Completeness Checklist for review of Operating Permit Applications submitted to the New Jersey Department of Environmental Protection (NJDEP). The checklist covers requirements for both Initial Operating Permit Applications and Renewal Permit Applications, including facility profile information, equipment inventories, emission unit and batch process details, potential to emit calculations, and compliance plan documentation. The checklist also outlines NJEMS reporting requirements related to application receipt, assignment, and determination of administrative completeness.

The document provides guidance on eligibility for Seven-Day-Notice Changes, which allow certain facility modifications to be implemented without prior NJDEP approval. Criteria for Seven-Day-Notice Changes include no increase in allowable emissions, no new air contaminants, and no relaxation of monitoring/recordkeeping requirements. The checklist indicates the appropriate steps for processing eligible Seven-Day-Notice Changes in NJEMS.

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RADIUS Administrative Completeness Checklist Program Interest Number: __________

ATTACHMENT 5

CHECKLISTS FOR REVIEW OF OPERATING PERMIT APPLICATIONS

ADMINISTRATIVE COMPLETENESS CHECKLIST FOR INITIAL OPERATING PERMIT APPLICATIONS

Facility Name:

Location:

Program Interest Number:

Date Received:

Facility NJID Number:

Permit Activity #:

Administratively Complete?

Reviewed By:

Date:

YES:

Permit Evaluator

NO:

Approved By:

Date:

Supervisor

Notes, Comments, and Follow Up (If application is Incomplete, please explain here)

Notes to the Reviewer:

1. Verify that the Responsible Official is as defined in N.J.A.C. 7:27-1.4.

2. “R” in the checklist indicates item is REQUIRED for Administrative Completeness

3. “NR” in the checklist indicates item is not required for Administrative Completeness. If information is not provided in the application, permit writer must request this information during technical review.

6/30/15

Application

Field

Review Parameters

R/NR

Complete?Y/N/NA

Reviewer Comments

Facility Profile (General)

Location and Industry Information

Contact Information

Facility ID

Program Interest Number

R

Facility Name

Street Address and Mailing Address

Complete addresses including county

Primary SIC

NAICS

NAICS

Contact Type

Owner, Operator, On-Site Manager, Responsible Official, Fee Contact

Facility Profile (Permitting)

Questions 1-12

#4,5 and 7 are NR for AC

Non-Source Fugitive Emissions

FG NJID, Description of Activity Causing Emission, Location

Non-source fugitive emissions greater than emission thresholds must be included

Reasonable Estimates of Emissions

For each FG and for each air pollutant.

Insignificant Source Emissions

IS NJID, Source Description, Equipment Type, Location

Source may be grouped together into same types.

Estimates of Emissions

Estimated total emissions for each air pollutant. (individual estimates for each IS ID not required)

Equipment Inventory

Equip. NJID, Facility’s Designation, E Description, E Type, Certificate Number, Installation Date, Grandfathered, Last Modification Date, E Set ID(s)

Equipment Detail

Must be completed for each equipment

Control Device Inventory

CD NJID, Facility’s Designation, CD Description, CD Type, Installation Date, Grandfathered, Last modification Date, CD Set ID(s)

Grandfathered status is not applicable

CD Detail

Check for each CD

Emission Point Inventory

PT NJID, Facility’s Designation, PT Description, Configuration, Equivalent Diameter, Height, Distance to Property Line, Temperature, Volume, Discharge Directio, PT Set ID

Emission Unit Inventory

U NJID, Facility Designation, U Description

R

U Detail

Check for Each U

Emission Unit Operating Scenarios

UOS NJID, Facility’s Designation, and UOS Description, Operation Type, Significant Equipment, Control Device, Emission Point, SCC(s), Annual Operating Hours, VOC Range, Flow Rate, Temperature

Check for each OS

OS Detail

Check for each OS

Batch Process Inventory

BP NJID, Facility’s Designation, BP Description

BP Operating Scenario

BPOS NJID , Facility’s Designation, BPOS Description, BPOS Type

BPOS Steps

Step NJID , Facility’s Designation, Step Description, Operation Type, Significant Equipment, Control Device(s), Emission Point(s), SCC(s), Step Run Time, VOC Range, Flow, Temperature

Step Detail

Check for each Step

Subject Item Group

Group NJID, Facility Designation, Type, ID, OS, Step, Formal Reasons for Group/Cap, Conditions/Requirements

Potential to Emit

Subject Item: E

NR

Subject Item: FC

Check if tons per year for each applicable air contaminant are entered

Subject Item: U

Check if tons per year for each applicable air contaminant for each Emission Unit are entered in OS0 Summary

OS Scenario

Check if lb/hr are entered for each applicable air contaminant in each Operating Scenario (other than OS0 Summary) of every Emission Unit

Subject Item: BP

Check if tons per year for each applicable air contaminant for each Batch Process are entered in OS0 Summary

Check if lb/batch for each applicable air contaminant for each Operating Scenario are entered in ST0 Summary

Check if lb/batch and lb/step for each applicable air contaminant for each Operating Scenario are entered for each individual Step

Compliance Plan

Subject Item: BP, CD, E, FC, FG, IS, GR, U

NR**

** The Operating Permit Section does not require that the IOP application include compliance plans. However the permit writer and the supervisor must make sure the following items are provided/addressed in the application:

1. Equipment inventory must identify all sources at the facility including those covered by general permits.

2. Each piece of equipment must have at least one operating scenario associated with it.

3. Any equipment can be placed only under one emission unit.

4. Separate operating scenarios must be included for start-up, shutdown and maintenance. Malfunction scenarios are not permitted.

5. Emissions from start-up, shutdown and maintenance must be accounted for in the annual emission limits.

6. a Site plan with E, CD and PT locations

7. Block diagram for each emission unit and batch process.

8. All emissions calculations and supporting documentation.

9. Banked emissions information if applicable.

10. All RACT/SOTA/PSD/Sub 18/MACT/NSPS/NESHAPS applicability determinations.

11. Certifications

12. Compliance status and compliance schedules

13. CAM Plan

RENEWAL PERMIT ADMINISTRATIVE COMPLETENESS CHECKLIST

Facility Name:

Location:

BOP PI:

Activity:

Yes
No
NA

DASHBOARD REQUIREMENTS: Open Activity Tracking in NJEMS and verify that a “Completed Date” for the following Tasks has been entered:

1. Receive app. and record receipt date.

2. Acknowledge receipt of application.

3. Assign application to supervisor.

4. Assign application to evaluator.

In addition, verify that a Permit Document Set has been created and that NJEMS Permit Activity Summary has been updated showing the correct modification type. Click for Procedure.

2a

Was the application marked as “confidential”? (Not required for administrative completeness).

2b

Has the public copy of the application been received? Applicable if 2a is YES (Not required for administrative completeness).

Section 1: Did the Facility Profile match the Facility Profile (General) in the approved Operating Permit? Change “Responsible Party” to “Responsible Official” in NJEMS as applicable. ? (Not required for administrative completeness).

Section 2: Did the Responsible Official certify the application?

Section 3: Did the application contain 7-Day Notice Changes (both old and new)?

Did the application contain changes to the Insignificant Source Operations?

Section 4: Did the application contain a “Summary of the results from Testing and Monitoring” form?

Section 5: Did the application contain any non-compliance issues or compliance schedules?

Section 6: Did the application contain the pollution prevention reporting forms?

Facility Wide Trends

Changes to NOx Emissions for Emission Units

Changes to VOC Emissions for Emission Units

Changes to HAP Emissions for Emission Units

Changes to Insignificant Source Emissions

Changes to Non-Source Fugitive Estimated Emissions

Emissions on Pound per Unit of Product Basis

Five-Year Trends (Optional)

9a
Did the applicant address health risk assessment for all applicable HAPs (not required for administrative completeness).
10
Email a copy of all metals analysis reports, submitted by the facility, to Joel Leon. Sample Email (click on blue underlined).
11
Did the application contain any new sources? Separate Minor and Significant Modifications applications can be submitted with the renewal application. (Not required for administrative comp.).

Continue on Page 2…

12
Check CAM. Refer to 40CFR 64 for applicability. Guidance is also available at eFinder / Websites/Rules / CAM Guidance. (Not required for administrative completeness).

ACID RAIN FACILITIES ONLY - (Not required for administrative completeness).

Has the facility completed Section 1 - Acid Rain Program in the renewal forms.

14
Was the application submitted “timely” (12 months prior to expiration of approved operating permit).
15
If “Administrative Complete”, issue a “Administrative Completeness - With Application Shield” letter.
16
DASHBOARD REQUIREMENT: If additional administrative information is required, add the following Tasks in Activity Tracking:

1. *Request administrative information.

2. *Receive administrative information.

3. Enter a “Completed Date” for both Tasks.

DASHBOARD REQUIREMENT: If the application has been determined to be administratively complete and timely.

1. Open Activity Tracking and enter a “Completed Date” for the Task “Determine administrative completeness”.

2. Update Activity Tracking under General for Application Shield Status. Click here for the procedure.

3. Issue an “Administrative Completeness - With Application Shield” letter.

DASHBOARD REQUIREMENT: If the application has been determined to be administratively complete but NOT timely.

1. Open Activity Tracking and enter a “Completed Date” for the Task “Determine administrative completeness”.

2. Update Activity Tracking under General for Application Shield Status. Click here for the procedure.

3. Issue an “Administrative Completeness - Without Application Shield” letter.

Calculate fees ($125 x ______ POE = ________) and send an email to Heidi Jonesto assess calculated fees (No fee required if renewal application was received before 7/2/2002). Sample Email.

Evaluator

Date

Supervisor

SIGNIFICANT MODIFICATION ADMINISTRATIVE COMPLETENESS CHECKLIST

Permit Writer:

The following NJEMS reporting requirements must be completed

DASHBOARD REQUIREMENTS: Verify that the “Completed Date” has been entered for the following Tasks in Activity Tracking:

1. Receive application.

2. Acknowledge receipt of application.

3. Assign application to supervisor

4. Assign application to evaluator.

In addition, verify that a Permit Document Set has been created and NJEMS Permit Activity Summary has been updated showing the correct modification type. Click for Procedure.

Yes
No

If additional administrative information is requested, the tracking clock in NJEMS can be “stopped’ using the Stop-the-Clock procedure. Open Activity Tracking and add two rows (*Request administrative information and Receive administrative information). Enter a “Completed Date” for the Task “*Request administrative information” (changes to Administrative information requested).

When the administrative information is received, open Activity Tracking and enter a “Completed Date” for the Task “*Receive administrative information” (changes to Administrative information received).

If the application has been determined to be administratively complete using the following checklist: Open Activity Tracking and enter a “Completed Date” for the Task “Determine administrative completeness”.

Significant Modification applications should include the following to be considered administratively complete

Facility Profile with only updated information.

Yes
No
NA

Description of the proposed change.

Any new applicable requirements (State and Federal) which will apply if the change occurs.

Potential to Emit for New Non-Source Fugitive emissions

For New Insignificant Sources

The type of source, estimate of total emissions from ALL insignificant sources for each criteria pollutant and a list of applicable requirements that apply to the insignificant source.

For Each New Significant Source

Brief description of source operations.

Identification of the stack or chimney (Emission Point Inventory)

Identification of the production process

General description of production process in sufficient detail to determine which applicable requirements apply

Product(s) or intermediate products(s) used

Continue on Page 2…

Emission Unit/Batch Process Inventory and Detail screens filled out. . For new sources both screens must be filled out completely. For modified sources, only modified information is required.

Yes
No
NA

Each proposed operating scenario shall include:

1. Description of each proposed operating scenario.

2. The specific source operations that are to be included in the proposed operating scenarios.

3. For combustion sources, type of fuel and maximum annual quantity to be used.

4. The product(s) that will be produced under the proposed operating scenarios.

5. Operating parameters that have an impact on emissions.

Demonstrate compliance with the applicable requirements of N.J.A.C. 7:27-18 for applications that include an emission increase.

Emission Information for Each New Source

Potential to Emit for each air contaminant including non-captured emissions in tons per year and any other unit (e.g. lb/hr) required to verify compliance with any applicable requirement.

Yes
No
NA

Type and quantity each fuel to be used annually.

Raw materials to be used and either the maximum rate of production rate and maximum annual hours of operation or maximum batch size and the maximum number of batches per year.

Control Device Inventory and detail screens filled out. For new sources both screens must be filled out completely. For modified sources, only modified or missing information is required.

Identification and description of all monitoring devices or activities to be used to verify compliance with applicable requirements.

Additional emissions information or emissions-related information needed to verify whether any potentially applicable requirements apply

Any other information required by an applicable requirement.

Calculations upon which the emissions were based.

A proposed compliance plan meeting the requirements of N.J.A.C. 7:27-22.9

Certification by a responsible official, consistent with N.J.A.C. 7:27-1.39.

Any additional information that is reasonably necessary to enable the Department to determine whether the applicant has satisfied the requirements of N.J.A.C. 7:27-22 for the issuance of a permit.

The following applies only to a PSD Affected Source

Increase in emission rates (TPY) of NSR regulated pollutants in case of a major modification. PSD applicability analysis and BACT Analysis.

Ambient Air quality impact analysis including NAAQS compliance, PSD increments and Class I impacts.

Ambient Monitoring - meteorological and pollutants (consult Alan Dresser of BTS, if required).

Additional impact analysis (Growth analysis, visibility impacts and Class I air quality related values).

Yes
No
NA

Permit Writer

MINOR MODIFICATION ADMINISTRATIVE COMPLETENESS CHECKLIST

Permit Writer:

The following NJEMS reporting requirements must be completed

DASHBOARD REQUIREMENTS: Verify that the “Completed Date” has been entered for the following Tasks in Activity Tracking:

5. Receive application.

6. Acknowledge receipt of application

7. Assign application to supervisor

8. Assign application to evaluator.

In addition, verify that a Permit Document Set has been created.

Yes
No

DASHBOARD REQUIREMENT: If the application has been determined to be administratively complete using the following checklist:

Open Activity Tracking and enter a “Completed Date” for the Task “Determine administrative completeness”.

Minor Modification applications should include the following to be considered administratively complete
Yes
No
NA

Facility Profile with only updated information.

Description of the proposed change.

Any new applicable requirements (State and Federal) which will apply if the change occurs.

The proposed sections of the draft operating permit reflecting the proposed change.

Potential to Emit for New Non-Source Fugitive emissions.

For New Insignificant Sources

The type of source, estimate of total emissions from ALL insignificant sources for each criteria pollutant and a list of applicable requirements that apply to the insignificant source.

For Each New Significant Source

Brief description of source operations.

Identification of the stack or chimney (Emission Point Inventory).

Identification of the production process.

General description of production process in sufficient detail to determine which applicable requirements apply.

Product(s) or intermediate products(s) used.

Emission Unit/Batch Process Inventory and Detail screens filled out. . For new sources both screens must be filled out completely. For modified sources, only modified information is required.

Each proposed operating scenario shall include:

6. Description of each proposed operating scenario.

7. The specific source operations that are to be included in the proposed operating scenarios.

8. For combustion sources, type of fuel and maximum annual quantity to be used.

9. The product(s) that will e produced under the proposed operating scenarios.

10. Operating parameters that have an impact on emissions.

Demonstrate compliance with the applicable requirements of N.J.A.C. 7:27-18.

Emission Information for Each New Source

Potential to Emit for each air contaminant including non-captured emissions in tons per year and any other unit (e.g. lb/hr) required to verify compliance with any applicable requirement. Include the allowable and estimated actual emissions before and after the change.

Type and quantity each fuel to be used annually.

Raw materials to be used and either the maximum rate of production rate and maximum annual hours of operation or maximum batch size and the maximum number of batches per year.

Control Device Inventory and detail screens filled out. For new sources both screens must be filled out completely. For modified sources, only modified or missing information is required.

Identification and description of all monitoring devices or activities to be used to verify compliance with applicable requirements.

Additional emissions information or emissions-related information needed to verify whether any potentially applicable requirements apply

Any other information required by an applicable requirement.

Calculations upon which the emissions were based.

A proposed compliance plan meeting the requirements of N.J.A.C. 7:27-22.9

Certification by a responsible official, consistent with N.J.A.C. 7:27-1.39.

Any additional information that is reasonably necessary to enable the Department to determine whether the applicant has satisfied the requirements of N.J.A.C. 7:27-22 for the issuance of a permit.

Permit Writer

PRE-REVIEW CHECKLIST FOR SEVEN-DAY-NOTICE CHANGES

Does not increase allowable emissions.

Does not cause emissions of a new contaminant.

Does not constitute a “modification” per Title I of the CAA (NSPS, NESHAP, MACT, etc.).

Does not relax monitoring, recordkeeping, reporting requirements.

See N.J.A.C. 7:27-22.22 for details. A permittee may make a sevendaynotice change seven days after the NJDEP’s receipt of the notice of the change if the proposed change does not increase actual emissions, does not cause the emission of a new air contaminant, does not violate an applicable requirement, does not relax a monitoring, recordkeeping, or reporting requirements, and does not constitute a minor modification or significant modification. Examples of such changes include reconfiguration of an operating scenario or a change in the production process.

Facility Name:

Date Received:

Program Interest Number:

Activity Number:

Checklist

Review Parameter

Yes

No

Reviewer’s Comments

Provided a description of the planned change and a statement of the reason the change is being made.

Provided the date or schedule for when the change will be made or a description of the types of circumstances under which the change would be made.

Provided the specific subject item and applicable requirement reference numbers that will be changed.

Provided the change in the quantity or rate of actual emissions as a result of the change.

Provided certification of the notice in accordance with N.J.A.C. 7:271.39.

Complete/Eligible?

YES:

File the notice as an attachment to the operating permit and update the Revision History table in NJEMS. Update the Activity Tracker in NJEMS. DO NOT CREATE OR BRING FORWARD A NEW PERMIT DOCUMENT SET (PDS) for seven-day notice changes. If a facility specifically request a revised PDS containing the seven-day notice changes, ask the facility to submit a minor modification application instead of a seven-day notice change.

NO:

If incomplete, call the facility requesting additional information. If ineligible, notify the permittee the change is not eligible for processing as a sevendaynotice change. Update the Activity Tracker in NJEMS.

NJEMS Permit Activity Summary and Activity Tracker has been updated showing the correct modification type. Click for Procedure.

6/30/15 Page 3 of 14

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