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Upcoming Hazardous Waste Reporting and Right to Know Survey Deadlines

Posted on February 19th, 2020

Storage of liquid chemicals

Storage of liquid chemicals

Two reporting deadlines that apply to many industrial facilities and remediation sites are upcoming on March 1, 2020 – the Annual Community Right to Know (CRTK) Surveys and Biennial Hazardous Waste Reporting for Large Quantity Generators.

The CRTK Surveys are required to be submitted to NJDEP for facilities that have chemical inventory exceeding NJDEP reporting thresholds, which is typically a 500-pound threshold. CRTK regulations were enacted to increase community awareness of chemical hazards, support local planning activities, support pollution prevention initiatives and inform emergency responders of chemical use. The CRTK survey is submitted annually through the NJDEP Online system and includes facility contact information and a chemical inventory.

March 1, 2020 is also the deadline for Large Quantity Generators of hazardous waste to submit reporting on wastes generated in 2019. The following three criteria are used to determine if a Site is a Large Quantity Generator:

  1. Facility generates, in any calendar month (includes quantities imported by importer site) 1,000 kg/month (2,200 lb/month) or more of non‐acute hazardous waste; or
  2. Facility generates, in any calendar month, or accumulates at any time, more than 1 kg/month (2.2 lb/month) of acute hazardous waste; or
  3. Facility generates, in any calendar month or accumulates at any time, more than 100 kg/month (220 lb/month) of acute hazardous spill cleanup material.

In previous years, biennial reports were submitted via mail, however, the submission has moved to an online document that is prepared and submitted through the RCRA Info website. The submission includes site contact information and documentation of the hazardous wastes that were generated in calendar year 2019. This reporting is only required in even years for wastes shipped in odd numbered years. The facility may also change its hazardous waste generator status online through the RCRA Info portal if appropriate.

With less than two weeks remaining until the March 1, 2020 deadline, JMS has been working diligently to assist clients in meeting their reporting obligations. JMS is experienced in preparing these documents. Give us a call for assistance with your CRTK and hazardous waste reporting.

 

Michelle Bouwman

Senior Manager


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