Baron Environmental Associates attended the New Jersey Department of Environmental Protection (NJDEP) Hazardous Waste (HW) Handler Seminar on October 13, 2016 at the New Jersey State Police Building in Hamilton, NJ. The purpose of these meetings are to inform facilities that handle hazardous waste of relevant program overviews, updates, and compliance techniques from the view of inspectors. The speakers included Bureau Chiefs, Section Chiefs, and Environmental Specialists from NJDEP. The following descriptions highlight the most relevant topics from the meeting:
Update on Current DEP Issues
An electronic hazardous waste manifest is expected to be released in Fall 2017. The E-Manifest program would make it so facilities would not need to submit biennial reports because the new reporting system would already incorporate all the details that would be within the report. However, for now biennial reports are still required.
Stormwater Compliance – An Inspectors Viewpoint
When an inspector is onsite, he or she will request the Stormwater Pollution Prevention Plan (SPPP) and specifically review the site plan to make sure they appear up to date. The inspector will also investigate BMPs to ensure they are functioning properly and are maintained. NJDEP has a BMP manual available here (http://www.njstormwater.org/bmp_manual2.htm) that can be a guide for BMP requirements in conjunction with N.J.A.C. 7:8.
Overview of the NJDEP Compliance & Enforcement Webpage
The Compliance and Enforcement Webpage contains many links that can be valuable when anticipating what occurs during an inspection and how to prepare for one. On the main page there are helpful links such as compliance advisories that indicate any alerts or updates to be aware of, as well as a training link where training resources on several programs are available.
Solid Waste Compliance – An Inspectors Viewpoint
Inspectors review the following topics before a visit, permits, site plan, rules & regulations, previous inspection reports, enforcement actions, and google images of the site. When inspectors first get to the site, some may park off site to get a better look at the facility and observe any odors, dust, noise, or litter that may exist. While they are on site, inspectors will request solid waste records. Depending on the inspector, the facility will most likely be given ample time (the time it takes for a site walk through to occur, usually about an hour) to look for the records. During the visit, the inspector is concerned with ensuring the permit and site plan are up to date and that the permit is being followed by the facility.
EPA Rules Update
The Hazardous Waste Generator Improvements Rule has updates expected soon. Nicotine gum is currently an acutely hazardous waste in facilities and a change is expected to negate this rule. Small Quantity Generators (SQG) will soon be required to submit a re-notification every two years, similar to a biannual report for Large Quantity Generators (LQG). For episodic generation, it is expected that an EPA ID number will not be required for those facilities generating waste that would otherwise be classified as SQG or Conditionally Exempt Small Quantity Generators (CESQG). By December 2016, the EPA is expected to finalize the reorganization of generator regulations (40 CFR 262).
An Overview of the Licensed Site Remediation Program
Response Action Outcomes (RAOs) issued by LSRP’s continue to increase with around 1,900 cases in 2015. RAOs are for contaminated sites that have been determined to be remediated by an LSRP. From October 2015 to April 2016 147 NOVs for Site Remediation Reform Act (SRRA) violations have been issued. Remedial Investigation reports, reports for assessing site characteristics and status, for all sites identified before May 1999 were due by May 7, 2016. Only 83% of all those sites given the 2016 extension were submitted.
Pesticide Compliance – An Inspectors Viewpoint
To apply pesticides, all businesses and facilities must hire a commercial pesticide applicator that is licensed to apply pesticides. However, a homeowner can apply pesticides without a license on their own personal property.