Within the New Jersey Department of Environmental Protection (NJDEP) Discharge Prevention Program, there is a requirement for facilities in New Jersey that store 20,000 gallons or more of hazardous substances (excluding petroleum products) or 200,000 gallons or more of hazardous substances (including petroleum products) to create and implement Discharge Prevention Containment and Countermeasure (DPCC) and Discharge Cleanup and Removal (DCR) plans. The NJDEP inspectors and engineers from within the Discharge Prevention Program regularly visit applicable DPCC facilities to ensure the site is operating according to their DPCC and DCR plan.
Did you know that completing three simple DPCC tasks could lower your risk of a DPCC violation by 50%? According to enforcement officials at NJDEP, 55% of DPCC violations come from just three categories out of dozens of possible compliance issues.
The most common three DPCC violations include:
• Tank integrity testing
• Visual facility inspections
These and other statistics were shared during the Discharge Prevention Program: Compliance in New Jersey workshop taught by Rutgers, Office of Continuing Professional Education Program on May 10 at the New Brunswick, NJ campus. Baron Environmental participated in this workshop, and we are pleased to share the relevant details.
The purpose of the workshop was to provide guidance on updates to current DPCC and DCR plans. Individuals in industry stand to benefit from this in-depth course taught by NJDEP and Environmental Protection Agency (EPA) personnel themselves – whether you are learning DPCC compliance for the first time or you are experienced and want to ensure that your facility is adequately prepared against hazards and regulatory fines.
In addition to discussing DPCC and DCR plan updates; the workshop also included an outline of annual DPCC audits conducted by the NJDEP and a review of discharge notifications that are required to be reported to the NJDEP in some instances. NJDEP inspectors gave insight on what they are looking for during a facility walk- around and gave guidance on when facilities are required to report discharges and to whom the discharges should be reported. As part of the DPCC and DCR plans there are additional requirements to writing the plan; the plan must include three maps, the General Site Plan, the Drainage & Land Use Map, and the Topographical Map showing Environmentally Sensitive Areas (ESAs). The DPCC plan must include a contract with an Emergency Response Organization that acts as the clean up contractor to be present during a discharge and to mitigate impact to the environment. A representative from Langan Engineering summarized the ESA mapping requirements and delivered a brief overview of how these maps can be created in the Geographical Information System (GIS). While Clean Harbors, presented how they can be utilized during an Emergency Response.
An environmental lawyer also presented summaries of cases where the validity of certain DPCC regulations were challenged by facilities and a representative from Langan Engineering provided details about site remediation in New Jersey as well as guidance and performance monitoring rule updates we can expect in 2017.
Representatives from the EPA also gave a brief overview of the Spill Prevention, Control & Countermeasure (SPCC) Regulation as well as examining a case study where a facility was not adequately prepared when a spill occurred.
If you are interested in other topics, Rutgers offers a series of continuing education courses on a variety of other environmental and safety programs. A complete list of Rutgers environmental training courses can be found below:
If you are looking for help with regulatory compliance, Baron Environmental Associates also offers many environmental and safety services that can help you manage your facility’s burdensome regulatory requirements. If you have any questions about the Discharge Prevention Program: Compliance in New Jersey workshop or would like to discuss some of your facility’s environmental and safety requirements, please contact our office at 908-508-9000 or email anyone in our staff here.