Environmental Consulting
Waste Compliance Support
Trinity’s waste compliance support offers guidance for businesses to meet regulations in waste handling, storage, treatment, and disposal, ensuring regulatory adherence and environmental responsibility.
Trinity’s waste support services encompass a range of solutions aimed at efficient waste management. These services are tailored to minimize environmental impact and optimize resource utilization for businesses and communities.
Trinity’s services include but are not limited to:
- Waste Compliance Support
- General and Customized Hazardous Waste Training
- Hazardous Waste Reporting
- On call RCRA Assistance
- On-site Waste Review
- Labpacks and Segregation of Waste
- Manifest preparation and reviews
- Guidance with Department of Transportation (DOT) requirements
- Managing Changes
- Generator Status Transition
- Episodic Event Support
- Management of Change procedures for waste management
- Auditing Support
- Notice of Violation response, non-compliance allegations, and data request support
- RCRA Inspection Preparation
- Third-party hazardous waste compliance auditing
- Follow-up to third party audit findings
- Third Party Hazardous Waste Vendor Audits
- Unique RCRA Challenges and Requirements
- Hazardous Secondary Material Assessments and Legitimacy Evaluations
- Subpart AA, BB, CC Applicability Determinations
- LDAR Program Development
- Co-generation Evaluation
- Coproduct vs. byproduct considerations
- RCRA closure and post-closure activities and plans
- Treatment, Storage, and Disposal Facility (TSDF) support
How Else We Can Help
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TSDF Support
Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDFs)_sp-mobile.jpg?sfvrsn=20ee5cbc_1)
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Waste Compliance Overview
Generator Status
Generator status drives an entities legal obligation to comply with Federal and state hazardous waste regulations. The obligations are based on the amount of waste generated on a monthly basis and on the amount of hazardous waste accumulated on-site at any one time. As the amount of hazardous waste generated increases, the generator obligations increase. Accurate counting of waste and use of potential exemptions and exclusions allow companies to minimize their legal obligations.
Quantity Generated in a Calendar Month
| Generator Category | Monthly Generation of Hazardous Waste and Max. Accumulation | Acute HW | Acute HW Spill Residue |
|---|---|---|---|
| VSQG | ≤220 lbs and <2,200 lbs> | ≤2.2 lbs | ≤220 lbs |
| SQG | Max: 13,200 pounds and 2,200 lbs | ≤2.2 lbs | ≤220 lbs |
| LQG | No maximum accumulation and Any amount | Any amount | >220 lbs |
| LQG | Any amount and No Maximum accumulation | >2.2 lbs | Any amount |
|
Regulatory Compliance
Individual states have the power to adopt regulations that are more stringent than the Federal regulations, leading to confusion when companies have facilities in multiple states. A few states such as California, Massachusetts, Minnesota, etc. have different generator categories with different generation rates compared to the Federal categories shown in Table 1.
A minority of states will regulate VSQGs and SQGs more stringently than the Federal regulations. Most states adopt all Federal regulations while others adopt only some of the provisions. Some states require an annual hazardous waste activity report. There are even states that define “hazardous waste” more stringently than the federal regulations!
| Federal Generator Requirements | VSQG | SQG | LQG |
|---|---|---|---|
| Waste Characterization | Yes | Yes | Yes |
| EPA ID Number | No | Yes | Yes |
| Hazardous Waste Notifications | No | Yes | Yes |
| Personnel Training | No | Yes | Yes |
| Training Plan and Job Descriptions | No | No | Yes |
| Contingency Plan and Quick Reference Guide | No | No | Yes |
| Preparedness and Prevention Plan | No | Yes | Yes |
| RCRA Air Emissions | No | No | Yes |
| Manifests and Land Disposal Restrictions | No | Yes | Yes |
| Formal Waste Minimization Plan | No | No | Yes |
| Hazardous Waste Activity Report (Annual or Biennial) | No | No | Yes |
| Closure Plans | No | No | Yes |
State regulations may vary. |
Important Dates
- March 1 – LQGs submit biennial hazardous waste activity reports in even-numbered years
- Annually – LQGs must provide refresher training to personnel handling or managing hazardous waste
- Every four years – Small Quantity Generator Re-Notification
Making Changes
- Contact updates for EPA ID numbers are required within 30 days of the change in some states
- RCRA Contingency Plans revisions are required as soon as possible. Out of date RCRA Contingency Plans are a common violation.
Immediate Steps
- Identify and classify waste materials as non-hazardous, hazardous, acute hazardous waste, universal waste, used oil, etc.
- Apply for an EPA ID Number from your state agency, as required by state and Federal (SQG and LQG) regulations
- Count how much hazardous waste or acute hazardous waste is generated and accumulated each calendar month
- Comply with the requirements applicable to the respective waste generator classification (e.g., VSQG, SQG, LQG)
- Comply with any additional more stringent state waste regulations
Meet the Team
