FAQ's for Changes to the Emission Statement Program
Q1: Can emission statement submittals be e-mailed to NJDEP?
A1:No. In order to remain compliant with EPA’s Federal Regulation Cross-Media Electronic Reporting Regulation (CROMERR), emission statements can no longer be submitted via e-mail. All future submittals can either only be sent by the US Postal Service/Private Carrier, on CD or diskette along with paper certification; or submitted through the NJDEP Online Services Portal.
Q2: What is this Certification Authorization Form referred to in the new version of RADIUS while using the ‘Submit’ function?
A2: Any major facility wishing to submit an mission statement through the NJDEP Online Services Portal must first have all certifiers of the emission statement, both Individual/s with Direct Knowledge AND Responsible Official/s complete, sign and return back to NJDEP the Certification Authorization Form. This form just allows the user to submit the emission statement through NJDEP Online. This form is NOT required for minor facilities submitting their emission statement through NJDEP Online.
Q3: Are smaller facilities (minor/non-Title V) subject to the expanded reporting requirements?
A3: Yes, expanded reporting of TAPs for the smaller facilities starts for CY 2005 emissions (due in May 2006). These smaller facilities would not have to report PM2.5, ammonia, methane or carbon dioxide.
Q4: If I am not currently subject to Emission Statement reporting, will the addition of new pollutants affect my applicability status?
A4: The only two pollutants that were added to the applicability table (that triggers the requirement for Emission Statement reporting) are PM2.5 and ammonia. A facility that is below the existing 100 tpy PTE reporting trigger for TSP and PM-10 is unlikely to have a PTE for PM2.5 at this level. The case for ammonia is similar in that any facility with a PTE of 100 tpy of ammonia would probably already be subject to Emission Statement reporting due to NOx or VOC emissions. No facility will become subject to Emission Statement reporting on the basis of TAP emissions.
Q5: Unlike the criteria emissions currently reported, I only have to report the emissions of the new pollutants as a facility-wide total. Is that correct?
A5: Not exactly. The greenhouse gases (carbon dioxide and methane), as well as the 36 TAPs may be reported as a facility-wide total. However, since PM2.5 and ammonia are essentially a subset of particulate matter, these emissions must be reported at the equipment level, the same as for TSP and PM-10. This level of PM2.5 and ammonia reporting detail is required by the USEPA.
Q6: Doesn't the new rule to include a specific exemption that limits reporting of PM2.5 and ammonia emissions to facility-wide totals, rather than on a piece of equipment basis?
A6: Yes, the rule text erroneously included this exemption and the Department is currently working to revise the text to be consistent with USEPA requirements. As discussed above, the Department is required to report PM2.5 and ammonia emissions to USEPA at the equipment level, the same as for TSP and PM10. Therefore, we ask all facilities to report PM2.5 and ammonia emissions for CY2003. Facility-wide reporting is allowed for GHG and Taps
Q7: Are there reporting thresholds?
A7: Facilities need only report a TAP if the potential to emit (PTE) that TAP exceeds the reporting thresholds that are contained in Table A, Appendix 1, of Subchapter 8. For example, the reporting threshold for formaldehyde is 400 lbs./yr.- therefore, the facility must report formaldehyde emissions if the facility-wide PTE for formaldehyde is in excess of 400 lbs./Yr. When estimating the facility-wide PTE to determine whether a TAP must be reported, you must include all processes and/or equipment at the facility even though some of these may individually be below the 400 lbs./Yr. reporting threshold.
Q8: Are there reporting thresholds for carbon dioxide, methane, PM2.5 and ammonia like there are for TAPs?
A8: No, there are no thresholds for these pollutants. Reporting of emissions of all pollutants are handled in the same manner as they were in the past (no thresholds). The exception is the reporting thresholds for TAPs
Q9: Are there any other changes or additions to Emission Statement reporting other than the addition of new pollutants?
A9: Yes, the amount of NOx emitted during the "ozone season" (May 1 to September 30) must now be reported in total tons, in addition to the current reporting of NOx emissions in lbs./ day during the "peak ozone season" (June 1 to August 31). While all of the pollutants were reported in the units of tons per year in the past, the emissions of carbon dioxide must be reported in thousands of tons, and TAPs emissions in pounds per year. This was done to reflect the relative magnitude of these emissions and to minimize errors that might result from introducing the use of exponential notation. Also, The owner or operator of any VOC stationary storage tank with a floating roof is required to report roof landing emissions in a separate operating scenario(s). If a separate operating scenario is not permitted, one must be created for the tank in question.
Q10: Are there additional fees associated with the reporting of the new pollutant list?
A10: Currently, no fees are required for the reporting of the expanded contaminant list. With respect to particulate matter, a fee is charged only for the greater of TSP, PM10 or PM2.5.
Q11: What version of RADIUS should emission statements be reported in?
A11: Beginning in February 2013, the latest version of RADIUS, (v.4.0), will be available for download from the Department’s website. The 2012 emission statement must be submitted using this latest version of RADIUS .