The United States Environmental Protection Agency (USEPA) Hazardous Waste Generator Improvements Rule became effective in New Jersey on May 30, 2017. The rule requires SQG facilities to re-notify the USEPA, or their state environmental agency of their hazardous waste generator status every four years.
All Dealerships that qualify as a Small Quantity Generator (SQG) of hazardous waste must re-notify by September 1, 2021, and every four years thereafter. A SQG is a facility that generates more than 100 Kilograms (220 pounds) and less than 1,000 kilograms (2,200) of non-acute hazardous waste in any single calendar month. If a dealership is considered a SQG, hazardous waste training is required for the person in charge of disposal.
Some dealers generate and dispose of hazardous waste. Many don’t, particularly those dealerships that don’t have body shops. Typically, hazardous waste generated at dealerships consists of the solvent waste (used stoddard solvent, if citrus based cleaner is not used) from parts cleaners. Since stoddard solvent weighs approximately 6.5 lbs/gallon, if a dealer disposes of approximately 34 gallons or more in any month, they are a SQG.
Other hazardous waste at dealerships, if not recycled, may include spent battery core electrolytes, airbags, paints/thinners, and broken mercury-containing bulbs. These items are typically recycled and are not then counted towards a dealership’s hazardous waste disposal.
If a dealership does not want to be considered a SQG then they should consider the following actions:
- A switch from solvent to citrus cleaner in parts cleaners.
- Space disposal out to stay below 220 lbs. in a month.
- Keep records of all waste disposal, including recyclables.
The New Jersey Department of Environmental Protection (NJDEP) previously accepted paper Site Identification Forms (USEPA Form 8700-12) by mail, however, as of September 2019 paper submittals of Site Identification Forms are no longer accepted by NJDEP. Site Identification Forms will only be accepted by NJDEP when the forms are submitted electronically via the RCRAInfo system.
To re-notify, SQG facilities must electronically submit a Site Identification Form using the RCRAInfo online system managed by USEPA. Site Identification Forms are submitted using a service within RCRAInfo called myRCRAid. To use this service, a facility representative must first register for a RCRAInfo account and request myRCRAid access to the facility as a Certifier. There is no fee to register for a RCRAInfo account or use the myRCRAid service. Submittal of a complete Site Identification Form anytime within the four years before the due date will meet the re-notification requirement.
If a dealership has questions regarding hazardous waste in general, they can contact Scott Hubbard, Compliance Manager at Environmental Compliance Monitoring, Inc. at 908.874.0990.
If a dealership has questions regarding the re-notification, they can contact Michael Gage at the NJDEP via email (Michael.Gage@dep.nj.gov) or the NJDEP Hazardous Waste Compliance and Enforcement Field Offices:
- Northern Field Office: (973) 656-4470
- Central Field Office: (609) 943-3019
- Southern Field Office: (856) 614-3658
If a dealership is seeking additional information about re-notification, they can visit the following websites:
- USEPA Re-Notification Information: https://www.epa.gov/hwgenerators/re-notificationrequirement-small-quantity-generators
- USEPA RCRA Training Modules: https://www.epa.gov/rcra/resource-conservation-andrecovery-act-rcra-training-modules
- RCRAInfo Webpage: https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login
- NJDEP myRCRAid Information: https://www.nj.gov/dep/enforcement/docs/Opting%20In%20to%20myRCRAid.pdf
- NJDEP myRCRAid Registration Manual: https://www.nj.gov/dep/enforcement/docs/myRCRAid.pdf
- Contact NJDEP: https://www.nj.gov/cgi-bin/dep/contactdep.pl