Reducing Priority Chemicals & Pollutants in NJ

Information required in a P2 Plan must be reported in two parts. Part I consists of a comprehensive inventory of the use and release of hazardous substances and the generation of hazardous wastes and non-product output (NPO) for each source and production process at a priority industrial facility. Non-product output is defined by the New Jersey P2 Act as "all hazardous substances or hazardous wastes that are generated prior to storage, out-of-process recycling, treatment control or disposal, and that are not intended for use as a product.” Under the framework of the P2 Act, the result of an industrial process can always be classified as either product or non-product output.

Part II of a P2 Plan consists of a detailed analysis for targeted production processes and sources of available P2 options that may substantially reduce the use and generation of hazardous substances and those options that will be implemented during the five-year planning cycle. A targeted production process is any production process that significantly contributes to the use or release of hazardous substances or the generation of hazardous waste or NPO. A source is a point or location in a production process at which NPO is generated or released, and a targeted source is a source that significantly contributes to the generation of NPO. The list of hazardous substances regulated under the P2 Act is equivalent to the list of substances established by the U.S. Environmental Protection Agency (EPA) for reporting pursuant to Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313, also known as the Toxic Release Inventory (TRI) List.

In September 2005, the NJ DEP readopted the Pollution Prevention Program Rules and incorporated an amendment to these rules whereby industrial facilities must target for Part II P2 planning all sources or production processes that use or generate as NPO, persistent, bioaccumulative, toxic (PBT) substances above the applicable TRI reporting thresholds. The hope is that once facilities do their homework and find that P2 options are available, they will reduce the use and generation of PBTs.

This provision will be applicable to facilities when they are required to prepare their new five-year P2 Plans. The NJ DEP will be tracking the progress facilities are achieving in reducing the use and generation as NPO, of PBTs.