Do the NJDEP Underground Storage Tank Regulations Apply to You?

An industrial facility with an Underground Storage Tank (UST) can be subject to the New Jersey Department of Environmental Protection’s (NJDEP) Underground Storage Tank regulations set forth at N.J.A.C. 7:14B. By definition a UST is any one or combination of tanks as set forth in N.J.A.C. 7:14B-1.4, including appurtenant pipes, lines, fixtures, and other related equipment, used to contain an accumulation of hazardous substances, the volume of which, including the volume of the appurtenant pipes, lines, fixtures, and other related equipment, is 10 percent or more beneath the surface of the ground. Unless one of the exemptions within N.J.A.C. 7:14B-1.4 applies, any facility that operates an US

Is It Legal to Puncture Aerosol Cans in NJ?

Many personnel in the EHS field are frequently asked if aerosol cans can be punctured and emptied prior to disposal, and the answer to this question has changed several times over the past three decades. The answer is not always clear, plus requirements vary state-by-state. In 2018, the Unites States Environmental Protection Agency (USEPA) proposed a draft rule for public comment to broaden the definition of Universal Waste to include all full, or partially filled, aerosol cans. While it may become a final rule in the future, it is not currently in effect. Currently, in New Jersey, if the aerosol can contains a propellent with a material other than an oil-based finish, then it must be mana

NJDEP Office of Dispute Resolution

Are you headed to court with the NJDEP or think you might be? Are there any alternatives? Perhaps - Per the NJDEP website, the Department of Environmental Protection (DEP) has established the Office of Dispute Resolution to provide a forum other than the administrative and trial courts for resolution of disagreements between the regulated community and the DEP. This forum aims to serve a dual purpose: not only to reduce lengthy legal proceedings that can be costly for all involved, but also to establish more meaningful and effective lines of communication between environmental regulators and the regulated community. Their mission is to ensure fair and efficient management and settlement of

Hazardous Waste Tank Requirements for Generators

Do you have a hazardous waste tank at your facility? Do you comply with the applicable RCRA requirements? Hazardous waste tanks must meet four subparts of the RCRA rule: J, AA, BB, and CC. It is important to understand that the requirements of these subparts are separate from the leak detection rules under the USEPA NESHAP air program, and both must be assessed. Baron recently participated at a joint DEP/EPA Region 2 New Jersey site inspection that focused on these RCRA Subparts. Below is a brief review of the requirements. Subpart J – 40 CFR 264.190-200 Subpart J requires lined or sealed secondary containment systems since standard concrete or asphalt are considered porous. Tank testing

The Regional Greenhouse Gas Initiative (RGGI) is back in New Jersey.

The Regional Greenhouse Gas Initiative is part of Governor Murphy's goal to achieve 100% clean energy by 2050. The Governor sees that shifting to clean and renewable energy sources reduces greenhouse gas emissions that are already causing climate impacts in New Jersey, particularly in economically disadvantaged communities. On June 17, 2019, the NJDEP adopted its rules related to rejoining RGGI. The two rules govern New Jersey’s reentry into the RGGI auction and distribution of the RGGI auction proceeds. The NJDEP is adopting new rules and amendments to establish the New Jersey Carbon Dioxide (CO2) Budget Trading Program, which is designed to reduce anthropogenic emissions of carbon dioxide

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776 Mountain Blvd, Watchung, NJ 07069

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