Recently on December 17, 2020, the New Jersey Department of Environmental Protection’s Compliance and Enforcement Program (NJDEP) issued a Compliance Advisory Alert entitled “Small Quantity Generators Must Re-Notify by September 1, 2021 and Every Four Years Thereafter”. This is a new requirement for Small Quantity Generators (SQGs), first becoming effective on May 30, 2017, upon adoption of the federal “Hazardous Waste Generator Improvements Rule” in New Jersey. Please note, while this advisory alert was issued by the NJDEP, the re-notification requirement is a Federal USEPA requirement that applies to all SQGs throughout the United States and its territories. In the past, an SQG was required to notify only when their status as a hazardous waste generator changed.
Generally, depending on specific exemptions, a SQG is defined as generating between 100 kg. and 1,000 kg. per month of non-acutely hazardous waste; 1 kg. or less of acutely hazardous waste; and 100 kg. or less of cleanup residue from acutely hazardous waste (40 CFR 252.13 for further detail).
Re-Notification forms are due by September 1st,2021 and every 4 years thereafter. Depending on your State’s specific hazardous waste program, your re-notification can be submitted electronically or by using EPA Site Identification Form 8700-12. In New Jersey re-notification forms are submitted electronically using EPA’s RCRAInfo system, specifically “myRCRAid”. A link to this system can be found at: https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login.
NJDEP has produced a handy guide to using “myRCRAid” at: https://www.nj.gov/dep/enforcement/docs/myRCRAid.pdf
For a copy of NJDEP’s recent compliance advisory, please see: https://www.nj.gov/dep/enforcement/advisories/2020-19.pdf
Personnel at enviroCOP are available to assist you with your hazardous waste compliance concerns. Please contact us at: https://www.envirocop.com/contact-us or by calling: (609-304-9662