Murphy DEP Proposes New Permit For Fossil Fuel Boilers – No Greenhouse Gas Limits or Efficiency Standards

DEP ignores industrial boiler CO2 emissions of the equivalent of over 7,500 cars

DEP proposal lacks data on total number of boilers or tons of CO2 emitted statewide

“If you think any of this wonkiness is going to deal with this dark psychic force of the collectivized hatred that this president is bringing up in this country, then I’m afraid that the Democrats are going to see some very dark days.”  ~~~ Marianne Williamson

I plead guilty to wonkiness, but sympathize with the sentiment of that quote.

Nonetheless, people need to know that the Murphy DEP once again has shown that they have no intention of regulating or reducing greenhouse gases emitted by fossil fuels.

The DEP just had another opportunity to do so, but instead proposed a new “General Operating Permit” (GOP – 009) for industrial oil and gas fueled boilers that has no CO2 emissions limitations or even monitoring and reporting requirements for greenhouse gas emissions.

While NJ State air pollution laws and DEP regulations define greenhouse gas emissions as air pollutants and require polluters to install “state of the art” (SOTA) pollution controls, the proposed “General Operating Permit 009”  has no standards for combustion efficiency or requirements to maintain and operate the boiler at optimum combustion efficiency.

In fact, in lieu of imposing strict NJ specific SOTA requirements, the proposed GOP defers to federal EPA requirements for:

Similarly, the GOP also lacks CO2 and methane emissions monitoring, reporting and record keeping requirements, so the DEP is flying blind and the public has no way to know about GHG emissions.

The DEP proposal provides no data that would allow the public to know how many of these industrial boilers there are, where they are located, or how much pollution they emit statewide.

The DEP proposal provided no analysis of greenhouse gas emissions or how they relate to the GHG emission reduction requirements of the Global Warming Response Act.

The DEP proposal provided no data on optimum or actual combustion efficiency from these kind of industrial boilers. Instead, the proposal defers to the manufacturers specifications.

The DEP proposal provided no engineering, combustion, or pollution control specifications or standards for what constitutes “state of the art” in pollution control.

Accordingly, the public has no way to meaningfully understand or comment on the proposal.

The proposed GOP-009 is open for public comment until September 18 (see this for how to submit comments).

A “General Permit” (GP) is a uniform permit that applies to and spells out standard requirements for an entire category of pollution sources. There are no public participation requirements for a GP, so you have no way to know about and no say in influencing DEP’s regulation of the air polluter down the street.

The GP mechanism was designed by DEP as a “streamlined” cheaper and quicker bureaucratic alternative to a far more rigorous “Individual Permit” issued to each individual facility or pollution source.

In this case, the DEP proposed GOP-009 that applies to industrial boilers fueled by oil or natural gas with a capacity from 10 million BTUs’/hour to 50 million BTU’s per hour.

This is an industrial size boiler, not something you’d have in the basement. Walk with me as we put the DEP technical jargon in a context you can understand and do a back of the envelope “worst case” sketch.

For context, a 50 million BTU/hour boiler would consume about 350 gallons of oil per hour (at 140,000 BTUs per gallon)

According to CO2 emission factors of the Energy Information Administration, fuel oil emits about 173 pound of CO2 per million BTUs. (By comparison, gasoline for your car has about 160 pounds of CO2 per million BTUs. )

At 50 million BTUs/hour, that translates into:

(173 lbs CO2/million BTUs x 50 MBTUs) X (24 hours/day) X (365 days/year) = 75,774,000 pounds/year

75,774,000 lbs/2000 lbs/ton  = 37,887 tons/year CO2.

THIS IS FOR JUST ONE BOILER. DEP provided no data on how many boilers there are in NJ.

For comparison, gasoline for your car emits about 19.6 pounds of CO2 per gallon. So, the industrial boiler emissions translate into about 3.87 MILLION gallons of gas per year.

Assuming a typical car travels 15,000 miles per year and gets 30 miles per gallon (500 gallons per year),  one 50 million BTU/hour boiler translates into the CO2 emissions of about 7,740 cars.

The DEP GP proposal does not identify how many of these boilers there are in NJ or how many hours a day they typically operate, so there is no way to translate these numbers into actual CO2 emissions.

The DEP GP does not indicate what the typical combustion efficiency these boilers operate at or what an optimum combustion efficiency is for these size boilers, so it is impossible to determine if the GP adequately regulates combustion efficiency in a way to minimize CO2 emissions.

Amazingly, the DEP GP defers to “the manufactures recommendations” when it comes to technical issues related to combustion efficiency – there are no standards or mandatory requirements for combustion efficiency or boiler maintenance and operation in the DEP GP.

There are no CO2 emissions monitoring, reporting, or record-keeping requirements in this DEP GP, so there is no way for DEP or the public to know how much CO2 they are actually emitting.

When the CO2 emissions by a single industrial polluter of the equivalent of over 7,500 cars are completely ignored, once again, we must note that the Murphy DEP is not serious about reducing greenhouse gas emissions.