NJDEP Hazardous Waste Handler Seminar “Remediation Waste – Is RCRA Regulated”

On October 10, 2018, the NJDEP held a seminar covering, for the first time, the topic of Remediation Waste – Is RCRA Regulated. Michael Hastry, NJDEP Director, from the Compliance and Enforcement Division, opened the session explaining that as he has met with Directors in other states, they are seeing a similar uptick in RCRA violations related to handling of Remediation Wastes. As such they agreed that NJ would be a good place to trial training on this specific topic. Based on the feedback they expect that other states will implement similar training on this emerging issue.

The main theme of the training was that even though the waste materials are generated during a remediation project, it doesn’t change the fact that all the RCRA requirements still apply: from generation, through storage, transportation and ultimate disposition, whether on or off site. The presentation materials can be found at https://www.nj.gov/dep/enforcement/oct2018ppt.html and covered the following topics:

  • Hazardous Waste Determination and Counting (and impact on your Generator status)

  • EPA ID Numbers, Reporting and use of EPA form 8700-12

  • Waste Management specifically related to Remediation Wastes, including storage, labeling, etc.

  • Episodic Generation – use of this exemption from changes in Generator Status for one time events – like spill cleanups or remediation projects

  • General RCRA requirements – a good summary of ALL the RCRA requirements and a good reference to the Section numbers

  • Case Studies covering:

  • Alternative Treatment Standards for Contaminated Soils

  • Managing Imported Fill