The New York State Department of Environmental Conservation released the new 6 NYCRR Part 360 solid waste management regulations around this time last year, establishing new compliance requirements. Under the Part 360 regulations, many facilities must either file for a registration, re-register, or file for a new permit based on site specific operations.
Some solid waste facilities recently received a notice from the NYSDEC regarding their registration status and advising them that action is needed to comply with Part 360. We believe this is a final warning from the NYSDEC to get your facility re-registered to avoid violations!
Registrations were due by May 4, 2018 (Fill Transfer Stations have until 2019) and permits are due by May 4, 2019 for all facilities. If your facility fits the criteria for a registration, it is not too late to register to avoid future violations! Here are 5 tips to know when applying for a NYSDEC Part 360 registration:
1. COMPLETE THE FORM
In order to register your facility, you must begin by completing a 4-page form provided by the NYSDEC. Here you will fill out information regarding the basic operations of the facility, and you must choose from a prescribed list of what type facility you are looking to register.
2. SITE PLAN
A site plan must be drawn up showing the facility location and where the waste materials are/will be stored, facility structures (buildings, offices, etc.), equipment on site, facility entrance and exit, and dimensions. This can easily be completed by an engineer, and fortunately, Walden has a lot of experience in preparing site plans for Solid Waste Facilities and can apply this expertise to create a site plan for your facility.
3. SUPPLEMENTAL PLANS
Similar to the Part 360 permitting process, the NYSDEC may request several plans to be submitted along with the registration form. A Facility Manual may be requested along with a Waste Control Plan (WCP). In short, a WCP should demonstrate the facility’s plan to maintain and control all forms of waste traveling to and from the site as well as storing the waste on-site. The WCP is mainly required for sites dealing with brick, rock, concrete, soil, sand and gravel. Walden’s experts are currently working with many clients to prepare plans needed to meet the Part 360 requirements; reach out to us today to move forward with compliance.
4. OWNER’S STATEMENT
If you rent or lease your facility’s property, you must obtain a statement from the owner certifying that they are aware of the application for registration. Without this statement, the NYSDEC will not issue a registration.
5. ADDITIONAL REQUIREMENTS
We have touched upon a few requirements that apply when registering your Solid Waste Facility, however, there are many other documents that must be submitted along with the ones listed above.
- Closure Cost Estimate
- Record of Compliance
- List of exempt activities
- Certificate Under Seal of the Department of State
If you have any questions, or are overwhelmed by the process, please call Walden at 516-624-7200 for a free consultation today! We have many Solid Waste Experts on staff ready to help you achieve and stay in compliance with the NYSDEC’s Part 360 regulations. For more information, check out our Part 360 page here