Baron participated in a recent "Discharge Prevention Program: Compliance in New Jersey” course delivered by Rutgers as part of our ongoing relationship with the NJDEP. These courses provide the regulated community and consultants the opportunity to keep up to date with ever evolving environmental regulatory requirements.
Major facilities in NJ are required to submit and update Discharge Prevention Containment and Countermeasure (DPCC) plans and Discharge Cleanup and Removal (DCR) plans to the NJDEP. If you have storage capacity of 20,000 gallons or more of non-petroleum hazardous substances or in excess of 200,000 gallons of storage including petroleum substances in containers over 5 gallons, you are covered by these rules. The list of these Hazardous Substances includes hundreds of chemicals and waste streams from acetone to alcohols, to ethylene glycol, to zinc sulfate.
Topics covered by presenters from the NJDEP and Industry included:
Overview of Discharges of Petroleum and Other Hazardous Substances (DPHS) rules and related state/federal programs
Updates to DPCC and DCR plans
Requirements for discharge notification, response, and reporting
Environmentally sensitive areas protection plan updates
NJDEP procedures for annual audits and post-incident inspections
Overview of administrative requirements for remediation of contaminated sites and regulation impact on discharge prevention rules
Latest DroneTechnologies for remote mapping of sites.
An interesting part of the course was a review of legal decisions challenging elements of the requirements. One Judge’s decision included that:
The Definition of “discharge" is not linked to quantity released and the Department wants to be aware of all discharges (no de minimis amount).
The NJDEP needs broad language to protect the lands and waters of the State but for enforcement, the NJDEP needs to take a “common sense” approach to enforcement.
So, while spilling a little gasoline on your lawn as you fill a lawnmower technically is a “discharge”, and should be avoided, the NJDEP will not take action against you for not reporting it.
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