Baron Environmental Associates takes part in regular Air & Waste Management Association (AWMA) meetings. These meetings seek to update the public about new trends regarding regulations and enforcement in New Jersey. The AWMA/NJDEP Annual Regulatory Update was held on November 18, 2016. Attendees included personnel from NJDEP as well as other professionals from New Jersey consulting firms and industries. Below is a description of the most relevant topics from the meeting.
Trends in LSRP Management
New Jersey municipalities have started municipal ticketing to increase compliance with regulatory deadlines under site remediation. The NJDEP now works with local compliance officers to issue fines. In the past six months, DEP has issued 52 of these municipal ticket notices of violation for a total of at least $150,000. These tickets can lead to court summons.
Trends in Inspections & Enforcement
NJDEP has shortened the time it takes to resolve enforcement actions. The average length to close an enforcement action in the past has been three years. Now, NJDEP is trying to shorten this time frame by quickening the pace that it negotiates with inspectees. Inspectors will now negotiate with inspectees immediately after inspection on site in order to hasten communications. Furthermore, NJDEP also encourages inspectees to use NJDEP’s new online system to pay penalties instead of the previous and more difficult mail option.
Trends in Hazardous Waste/RCRA
NJDEP is making a series of impactful changes to RCRA. The changes were made this past October and will go into effect in April of 2017. The state is removing the hazardous waste generator status “conditionally exempt small quantity generator” (CESQG) and is going to replace it with “very small quantity generator” (VSQG) and new sets of requirements. NJDEP is also going to make it easier for sites to change their waste generator status, since it is such a common issue in New Jersey. A full EPA release for these changes can be found here: https://www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements#rule-summary