January 2019

We wish all our clients and associates a very happy and prosperous 2019.

Some important regulatory deadlines for 2019 applicable to most manufacturing facilities:

REQUIREMENT DUE DATE
OSHA Injury and Illness Log Summary (OSHA 300A). Facilities must post Form 300A for calendar year 2018 February 1, 21019
Community Right to Know Survey March 1, 2019
OSHA Injury Tracking Application (ITA). Facilities with more than 10 employees must electronically submit data from the 2018 OSHA 300A form March 2, 2019
Hazardous Waste Biennial Report Not required this year
Annual Batch Reports April 1, 2019
Air Emission Statement May 15, 2019
Toxic Release Inventory (TRI) July 1, 2019
New Jersey Release and Pollution Prevention Report July 1, 2019

Some important new developments in the New Jersey Site Remediation Program:

    1. Capping of Volatile Contaminants for the Impact to GW Pathway Guidance now available (August 30, 2018)

The New Jersey Department of Environmental Protection announced the availability of the Capping of Volatile Contaminants for the Impact to Ground Water Pathway Guidance (August 2018). This guidance details the conditions and requirements under which capping may be allowed on a site-specific basis. Previously, capping of inorganic and semi-volatile organic contaminants were permitted under certain circumstances, but this did not include VOCs, such as benzene, toluene, TCE and PCE.

  1. Public Notification Requirements are updated (December 21, 2018)

The major change requires public notification within 14 days prior to commencing initial field activities associated with the remedial investigation (previously remedial action). For cases that initiated the remedial investigation prior to August 6, 2018 but have not yet satisfied the public notification requirements, the 14-day public notification is now due. However, for these cases, the Department is allowing the person responsible for conducting the remediation to comply with the public notification rule requirements by June 30, 2019.

  1. Ecological Evaluation Technical Guidance has been updated (August 6, 2018)

December 2015

Holiday Greetings from Environmental Engineering Corporation:

This was another busy and productive year for Environmental Engineering Corporation. We wish all our clients and associates a very enjoyable holiday season and a happy and prosperous 2016.

Summer Internship:

If interested in a summer internship with Environmental Engineering Corporation in 2016, please email your resume to plamba@envengg.com.

NJDEP Advisory for Air Permit Holders:

NJDEP issued an advisory for air permit holders in November 2015. The complete advisory is available here:

http://www.nj.gov/dep/enforcement/advisories/2015-13.pdf

The common pitfalls of air permit holders per the advisory are provided below:

  1. Read and follow your permit.
  2. Modifications to permitted equipment must be pre-approved.
  3. Facility is responsible for renewing permit on time.
  4. Copies of permits must be kept at the site.
  5. Make sure all equipment requiring permit as per N.J.A.C. 7:27-8.2 are permitted.

NJ Site Remediation Program (SRP)/LSRP Update: 

  1. The deadline to complete the remedial investigation for cases that were granted a statutory two-year extension to the original May 7, 2014 deadline to complete the remedial investigation is less than six months away. A complete listing of cases that received and maintained the extension is available from Dataminer at http://datamine2.state.nj.us/DEP_OPRA/OpraMain/categories?category=Case+Tracking:
  2. The New Jersey Department of Environmental Protection announced that new interim ground water quality standards have been posted for 12 compounds. The list of compounds and interim ground water quality standards is available through the Division of Water Monitoring and Standards website (www.nj.gov/dep/wms/bears/gwqs_interim_criteria_table.htm).

News September 2015

 1. Office Relocation:

Environmental Engineering Corporation (EEC) moved to a new office in Chester, New Jersey on October 1, 2014. Our new contact information is as follow:

Address: 154 US Highway 206, Suite 7
Chester, NJ 07930-2015
Telephone: (908) 955-7445
(908) 955-7627
Facsimile: (908) 955-7628

Website: www.envengg.com

 

2. Revised OSHA Hazard Communication Standard deadlines:

New changes to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard are bringing the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS):

Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers
June 1, 2015

December 1, 2015

Compliance with all modified provisions of this final rule, except:

The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label

Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition Period to the effective completion dates noted above May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both Chemical manufacturers, importers, distributors, and employers

3. NJDEP Steps Up Inspection of Laboratories to Comply with Air Pollution Control Act:

Any laboratory in New Jersey that owns or operates equipment and/or source operation that has the potential to emit any Group 1 or Group 2 TXS (Toxic Substances), or a combination thereof, at a rate greater than 0.1 pounds per hour (45.4 grams per hour) is affected by this advisory.

Group 1 TXS means an air contaminant that is found on the list of Group 1 TXS at N.J.A.C. 7:27- 17.3, which is incorporated by reference herein, together with all amendments and supplements. As of June 12, 1998, the following is the complete list of Group 1 TXS: Benzene (Benzol), Carbon tetrachloride (Tetrachloromethane), Chloroform (Trichloromethane), Dioxane (1,4-Diethylene dioxide; 1,4-Dioxane), Ethylenimine (Aziridine), Ethylene dibromide (1,2-Dibromoethane), Ethylene dichloride (1,2-Dichloroethane), 1,1,2,2-Tetrachloroethane (Tetrachloroethane), Tetrachloroethylene (Perchloroethylene), 1,1,2-Trichloroethane (Vinyl trichloride), and Trichloroethylene (Trichlorethene).

Group 2 TXS means an air contaminant that is found on the list of Group 2 TXS at N.J.A.C. 7:27- 17.3, which is incorporated by reference herein, together with all amendments and supplements. As of June 12, 1998, the following is the complete list of Group 2 TXS: Methylene chloride (Dichloromethane), 1,1,1-Trichloroethane (Methyl chloroform).

4. NJ Site Remediation Program (SRP)/LSRP Update:

New Jersey Department of Environmental Protection (NJDEP) has updated following guidance documents in 2015:

Comingle Plume Technical Guidance (July 2015)

Fill Material Guidance (May 2015)

Ecological Evaluation Technical Guidance (February 2015)

SRP Fees for Fiscal Year 2016

NJDEP has also issued two quick reference guides for completing Remedial Action Permit applications for soil and ground water and four Analytical Technical Guidance Documents to assist in interpreting analytical data.

Additional details on these can be found at NJDEP website http://www.nj.gov/dep/srp/