Case Study

Services – Compliance & Permitting

Foley, Inc., Piscataway, New Jersey – Environmental Compliance Assessment

JMS has worked with Foley, Incorporated (Foley) since 1990 to address all of their corporate environmental needs. Foley operates four divisions at their Piscataway location: Machinery, On-Highway, Rents, and Power Systems. The Machinery Division performs repairs, maintenance and painting services on construction equipment. The On-Highway Division repairs and maintains on-highway vehicles. The Rents Division leases machinery and construction equipment. The Power Systems Division sells and maintains commercial, industrial, and marine engines. A detailed knowledge of Foley’s operations is necessary to ensure that they are compliant with State and Federal regulatory requirements.

JMS provides to Foley an annual environmental compliance assessment, which identifies areas within the company which can be improved from an environmental prospective. The compliance assessment includes a review of Foley’s operations to confirm that all existing air permit requirements (inspection, recordkeeping, reporting) are being met. Historically, Foley’s emissions triggered annual reporting through the Emission Statement process and JMS prepared these annual statements on behalf of Foley. Due to operational changes implemented at Foley the facility is now below reporting thresholds.

JMS completed preconstruction permit and operating certificate (PCP/OC) applications for a number of processes and equipment over the last 30 years. This includes both individual permits as well as general permits. Historically, JMS prepared the permit applications and modifications utilizing the standard reporting forms; however, with the implementation of the Radius Air Permitting software, JMS has switched all of Foley’s applicable air permitting submittals to the new electronic, paperless format.

Most recently, JMS assisted Foley with addressing a notice of violation (NOV), which was issued by the NJDEP for fourteen (14) emergency generators that Foley maintains for rental purposes. The NJDEP stated that since the generators were significant pieces of equipment, Foley had the obligation to obtain permits for the generators. JMS subsequently completed a comprehensive review of the current regulations to confirm that Foley did not require a permit since they do not install or operate the generators. Therefore, the permitting obligation remains with the party renting and operating the generators. After coordinating a meeting with the Assistant Commissioner of NJDEP along with the heads of the Air Compliance and Enforcement and Air Permitting, the NJDEP subsequently rescinded the NOV after making a determination that Foley was incorrectly identified as the party required to obtain the required air permits.

The most recent air permitting project for Foley was assisting with resolving the emergency generator NOV. The total cost of this project was approximately $6,500 and it was completed in 2010. The most recent air permitting project was the preparation of General Permits for the operation of four (4) open-topped parts cleaners and a new 3.5 MM BTU rooftop mounted HVAC unit. The total cost of this project was approximately $1,200 and it was completed in 2009.

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