Does NJDEP Permit Compliance Hibernate during Winter?
As the temperatures drop and winter weather conditions continue throughout New Jersey, companies must consider the effect that the winter season will have on their NJDEP permit compliance. While most regulatory bodies have relaxed certain policies and deadlines due to the pandemic, the NJDEP has not relaxed the requirement for permit compliance for equipment and processes that may be greatly affected by the freezing weather.
The following are some of the major concerns that NJDEP has during the winter season:
Underground Storage Tanks
Underground storage tanks (USTs) are a known risk in any real estate transaction, but the challenges they present can become more complex during the winter months. The freezing weather can wreak havoc on USTs and affect its components such as electrical wiring and pipelines, thus compromising its overall performance and safety.
During the frigid temperatures, the water inside the UST’s electrical components can quickly freeze, which can negatively impact the proper functioning of the leak detectors, sensors, and submersible pumps. Similarly, the ground movement caused by the freeze/thaw cycles can make the older pipes to be more prone to cracking, breaking, or failure at the joint during the winter.
Businesses must have these tanks adequately maintained, inspected, monitored, and repaired when necessary to comply with the Underground Storage Tank Compliance Act. To ensure that the UST can stay functional and safe during the winter season, facilities must hire an NJDEP permit consultant to review the site, verify that they have the proper documentation, routine inspections, and maintain the tanks according to the NJDEP standards.
Emergency Generators
Power outages are a common occurrence across the Garden State during winter. As such, many businesses, hospitals, and factories have installed emergency generators to ensure on-demand, reliable energy during power interruptions. However, before any facility can start using commercial-grade generators, they must first obtain permits from the NJDEP.
According to the Air Permit Applicability Determination For Emergency Generators Guidance Document, an NJDEP air permit must be obtained if the maximum (100% load or power rating) fuel consumption of the emergency generator in any one (1) hour is greater than the values listed below for each fuel type:
- Natural Gas – greater than 980 ft3 /hour (based on heat value of 1,020 Btu/ft3)
- Propane (LP) – greater than 397 ft3 /hour (based on heat value of 2,516 Btu/ft3)
- #2 Fuel Oil – greater than 7.04 gallons /hour (based on heat value of 142,000 Btu/gal)
For example, suppose the fuel consumption rate of a natural gas emergency generator set running at maximum load is 1,200 ft3/hour. In that case, it exceeds the limit for Natural Gas listed above (980 ft3/hour). This means that the business or facility must obtain an NJDEP air permit for such a generator before utilizing it.
To ease the burden of obtaining NJDEP permit compliance for emergency generators, businesses in New Jersey must have the expertise of an Air Permit Consultant that can guide them throughout the process. Doing so will help them save time and money and avoid the hefty penalties and even legal charges due to non-compliance.
Snow Removal and Disposal
Effective and timely removal and disposal of snow are imperative to keep the business premises accessible and safe throughout the winter season. The NJDEP’s Snow Removal Guidelines detail how New Jersey facilities should remove and dispose of snow within their premises, including the selection, preparation, and maintenance of the disposal site.
Disposal sites must be inspected by a qualified individual, ideally by an NJDEP permit compliance expert with a background in professional engineering, to ensure that it fits the requirements specified by the NJDEP in the Snow Removal Guidelines.
The guidelines also explained in detail how to manage discharge resulting from snow melting operations:
1) All discharges resulting from snow melting operations must comply with the lawful requirements of federal agencies, municipalities, counties, and other local agencies regarding any discharges to storm drain systems, conveyances, or other water courses under their jurisdiction.
2) If the discharge is to a storm sewer or combined sewer system (CSS), the owner/operator of the mechanical snow melter must, before discharge, notify and obtain approval from the owner of the conveyance system of the date, approximate time, location, and duration of the discharge(s). The guidance included in this document does not reduce the existing authority of the owner of a storm sewer or CSS or other local agency from prohibiting or placing additional conditions on the discharge.
3) If the discharge is to a CSS, the snow melter must not be operated or be allowed to discharge during wet weather events. Further, the discharge to a CSS must be upstream of the wet weather regulator or other diversion points.
4) Direct discharges of melted snow into water bodies are prohibited. A filter bag or similar filtration device must be used to remove suspended solids and debris. This device should be used and maintained following the manufacturer’s specifications. Solids collected in a mechanical snow melter must be disposed of properly.
5) The discharge and associated runoff should be routed so that it does not cause any erosion.
6) The discharge shall not result in flooding of neighboring property, streets, gutters, or storm sewers.
7) The discharge must be diverted from building foundations or other areas that may be damaged from ground settling or swelling.
8) The discharge must be visibly clear and not contain floating or solid materials.
9) A visible sheen must not be evident in the discharge.
10) The addition of cleaning materials or chemicals (such as deicers) during snow melting activities is strictly prohibited.
After a snowstorm, businesses must also clear any blockage of snow or debris on top of storm drain catch basins. By doing so, localized flooding can be prevented, helping the business ensure its accessibility.
Conclusion
With an NJDEP Permit Air Permit Consultant, businesses in New Jersey will be able to avoid disruption to their operations as they obtain the right permits for their equipment and processes on time.
Furthermore, they can provide on-site training so that all the facility’s key personnel thoroughly understand the specific day-to-day actions they need to do to adhere to compliance standards. Therefore, the time and money saved can be used to improve the more crucial aspects of growing the business, such as its research and development department or its marketing strategy.
To help commercial building owners and facility managers in NJ achieve NJDEP permit compliance as efficiently as possible, Lockatong Engineering assists in obtaining NJDEP Permit Compliance. Contact us to learn more about our environmental consulting and evaluation services today.
