Is Your Air Permit Strategy Ready for NJDEP’s New SOTA Standards?
New Jersey’s air quality has greatly improved in recent years and this is due to the state’s committed pollution reduction efforts. The 2023 New Jersey Air Quality Report shows proof of this, highlighting consistent downward trends in concentrations of key pollutants since 1965.
However, despite this development, there are still days when air quality fails to meet the standards. Smog and fine particle emissions continue to pose health risks, especially in industrial areas and overburdened communities.
In efforts to maintain the downward trend of pollution levels, the New Jersey Department of Environmental Protection (NJDEP) introduced new State-of-the-Art (SOTA) standards to tighten emission limits for industrial engines in December 2023. Two recent updates are the stricter regulation of compression ignition reciprocating internal combustion engines (CI RICE) and spark ignition reciprocating internal combustion engines (SI RICE). The NJDEP SOTA manuals can be found at https://dep.nj.gov/boss/state-of-the-art/
Overview of the New SOTA Standards
The SOTA manuals serve as guidelines for meeting the latest air pollution control standards set by the New Jersey Department of Environmental Protection (NJDEP). Their primary purposes are:
- Promoting the use of up-to-date emissions control methods
- Setting stricter limits on pollutants
- Providing NJDEP compliance guidance
- Updating standards based on technological advancements
For covered entities, this raises various critical concerns.
- Do their existing engines comply with the new rules, or will they need expensive upgrades?
- How will this change their NJDEP permit complianceand reporting?
Manufacturers and facilities operating these engines must fully grasp the new standards to secure or renew their air permits. Navigating these updates can be complex, but working with a NJ air permit consultant can help them avoid costly missteps.
Key Updates: CI RICE Manual
A Compression Ignition Reciprocating Internal Combustion Engine (CI RICE) generates power by compressing air and fuel until it ignites. These engines are typically diesel-fueled and are often used in industrial settings because of their efficiency, durability, and high-power output. The SOTA performance levels apply to CI RICE which have a rating of 198 bhp or more and that are not classified as Emergency Stationary RICE or Black Start Engine, in accordance with EPA 40 CFR Part 60 Subpart ZZZZ.
If a facility operates any of the following equipment, it likely falls under CI RICE SOTA regulations:
- diesel-powered generators
- industrial compressors, pumps, and material-handling machines
- municipal and utility pumps
- agricultural or construction irrigation pumps, excavators, and bulldozers
1. New Emission Caps
The latest NJDEP SOTA standard for CI RICE introduces new emission caps for nitrogen oxides (NOx), carbon monoxide (CO), total supsended particulate matter (TSP), volatile organic compounds (VOCs) expressed as Nonmethane Hydrocarbons (NMHC) and Ammonia Slip (NH3). The new emission limits are lowered to align with federal and state air quality goals.
The emission caps vary based on several key factors, including engine size, power output, and compliance pathway. Each pollutant also has different limits depending on its environmental and health impact. CO and NOx have the strictest reduction targets, as they significantly contribute to air pollution and regulatory noncompliance.
2. Improved Control Technologies
Facilities operating CI RICE engines can meet the stricter limits by installing advanced emissions control technologies like:
- Oxidation Catalysts– convert CO and unburned hydrocarbons into less harmful gases.
- Selective Catalytic Reduction (SCR) Systems– reduce NOx emissions by using a urea-based solution that turns harmful gases into nitrogen and water.
- Diesel Particulate Filters– capture and remove fine particulate matter from engine exhaust.
3. Monitoring & Reporting Requirements
The new SOTA manual implements stricter monitoring protocols for covered facilities. Key monitoring requirements include:
- Emissions Testing
The new SOTA requires facilities to conduct periodic stack testing every five years to verify that pollutant levels remain within the new limits. These tests must be performed following approved methodologies and schedules as specified by the NJDEP.
Continuous emission monitoring (CEM) and CEM system installation may also be necessary for larger engines or those with higher emissions.
- Operational Data Logging
Engine run-time, load conditions, fuel consumption, and maintenance activities must be recorded and maintained for regulatory review.
- Recordkeeping and Retention
Facilities must store emissions and operational data for a specified period. These records must be accessible for NJDEP inspections.
Key Updates: SI RICE Manual
A Spark Ignition Reciprocating Internal Combustion Engine (SI RICE) generates power by igniting a fuel-air mixture using a spark plug. SI RICE primarily uses natural gas, propane, or gasoline. The SOTA performance levels apply to SI RICE which have a rating of 157 bhp or more and that are not classified as Emergency Stationary RICE or Black Start Engine, in accordance with EPA 40 CFR Part 60 Subpart ZZZZ.
If a facility operates any of the following, they likely have an SI RICE and must comply with NJDEP’s new regulations:
- natural gas-fired generators
- cogeneration (CHP) systems
- gas-fueled industrial equipment
- landfill and biogas engines
- irrigation and agricultural pumps
1. Lower Emission Limits
SI RICE operates with a different combustion process than compression ignition (CI) engines, so it has distinct pollutant profiles and regulatory thresholds. Since SI engines typically produce higher NOx, VOCs, and CO, its SOTA standards impose even lower emission limits for these pollutants. Methane and Hazardous Air Pollutants (HAPs) such as Formaldehyde emissions are also a concern for these engines, so the updated SOTA introduces specific thresholds to curb the impact of these potent greenhouse gas.
2. Mandatory Emission Control Technologies
To meet these stricter standards, facilities may need to install:
- Three-Way Catalysts (TWCs) –Helps reduce NOₓ, CO, and VOC emissions.
- Non-Selective Catalytic Reduction (NSCR) –converts pollutants into harmless gases.
- Oxidation Catalysts– convert CO and unburned hydrocarbons into less harmful gases.
- Selective Catalytic Reduction (SCR) Systems– reduce NOx emissions by using a urea-based solution that turns harmful gases into nitrogen and water.
In addition, facilities must adopt operational strategies to further reduce emissions. For example, they can switch to cleaner fuels like pipeline-quality natural gas to reduce emissions at the source. Regular engine tuning and upgrades are also essential to maintaining engine efficiency and meeting the stricter limits.
3. Enhanced Monitoring and Reporting
SI RICE units now require more frequent inspections of all emission control devices to maintain their effectiveness in reducing pollutants. Facilities may also be required to submit detailed emissions reports at shorter intervals (quarterly and semi-annual), reflecting ongoing compliance efforts and corrective actions taken if limits are exceeded.
The new SOTA requires facilities to conduct periodic stack testing every five years to verify that pollutant levels remain within the new limits. These tests must be performed following approved methodologies and schedules as specified by the NJDEP.
Record-keeping obligations of affected facilities are also stricter, covering data for engine load, fuel quality, and runtime.
What the Update Means for Affected Facilities
Because of the update, some facilities may no longer comply with NJDEP’s stricter emission limits. Older engines that do not meet the new standards might require upgrades, retrofits, or replacement if a permit revision or renewal is required.
To address this, facilities should first review their existing equipment so they can assess compliance gaps and develop an action plan to meet NJDEP’s updated standards. This can be achieved with the help of an NJDEP air permit consultant.
In particular, a consultant can help with:
- Compliance Assessment:A qualified professional can help evaluate existing CI RICE and SI RICE engines to determine if they meet the new emission limits or need upgrades.
- Permit Application or Renewal:They can handle the complex NJDEP air permit process, whether applying for the first time or making a renewal.
- Emissions Testing and Reporting: An air permit consultant NJcan guide facilities through testing procedures, record-keeping, and regulatory reporting to avoid penalties.
- Technology and Upgrade Recommendations:With assistance from an experienced professional, facilities can apply cost-effective solutions.
Work with a Permit Consultant in New Jersey
Navigating air permit regulations can be complex, but you do not have to do it alone. Lockatong Engineering can be your trusted partner for navigating New Jersey’s constantly changing environmental regulations.
We have helped hospitals, manufacturers, and industrial facilities secure air permits, navigate NJDEP inspections, and resolve complex compliance. With a team of professional environmental engineers, we do not only interpret regulations; we apply real-world expertise so facilities meet and maintain air quality standards.
Reach us at https://www.lockatong.com/contact-us/ for engine assessment, air permit application, or assistance with compliance upgrades.
