Waste Management Compliance Services

Since the 1976 enactment of the Resource Conservation and Recovery Act (RCRA), facilities that manage waste (hazardous and non-hazardous) have been subject to increasingly stringent regulations. In the 1990s, environmental regulations imposed stricter air emission limitations on waste combustion activities, including those involved with efforts to recover energy from the combustion of municipal solid waste and industrial nonhazardous waste. Furthermore, the introduction of several Clean Air Act (CAA) standards related to waste management under the National Emissions Standards for Hazardous Air Pollutants (NESHAPs) and New Source Performance Standards (NSPS) significantly increased the number of potentially applicable compliance requirements for projects involving alternative waste derived fuel. Despite these regulatory challenges, industry continues to pursue the benefits associated with viable alternative fuels along with sustainable environmental business practices.

Trinity’s unmatched air quality expertise combined with the insights of our waste management specialists give us the leading edge in providing permitting and ongoing waste management compliance services. Our experience in air and RCRA permitting for various source types includes cement kilns, incinerators, boilers, and municipal solid wasteto- energy facilities. In addition, Trinity participates in a number of professional trade organizations related to waste management.

Most recently, Trinity has assisted facilities in utilizing alternative waste derived fuels and alternative raw materials with streamlined and flexible air operating permit requirements. As a result, our clients benefit from measurable economic gains and increased operational flexibility.

Solid Waste

Solid waste can be either hazardous or nonhazardous. Non-hazardous solid waste is simply referred to as “solid waste.” Waste must first be defined as a solid waste before it can be defined as hazardous waste. The regulatory definition of solid waste, found in 40 CFR 261.2(a), encompasses the following: materials that are abandoned; materials that are recycled; materials that are inherently waste-like; and waste military munitions.

Facilities using fuels derived from materials that are deemed “solid waste” are typically subject to state or local regulations such as solid waste operating permits for the acceptance and/or precombustion processing of solid waste (including scrap tires). Trinity has assisted a number of clients that have sought to use waste derived fuels and alternative raw materials. Example waste derived fuels that have been considered a viable substitute for coal and other fossil fuels include: used oil, scrap tires, carbon black, shredded plastic, meat and bone meal, dried sewage sludge, and a variety of waste streams from the ethanol and biodiesel industry. Waste-toenergy facilities have also begun to utilize a greater variety of waste streams as fuel, including biomass, auto shredder residue, and municipal solid waste. Furthermore, standalone waste-to-energy facilities require solid waste permits to receive off-site waste and process the waste prior to combustion, in addition to air construction and operating permits associated with the facility’s air emissions.

Generators of solid waste must first determine if their waste streams meet the definition of hazardous waste in order to determine the applicable management requirements. In addition to waste and possible air compliance permitting, hazardous waste must be managed from “cradle to grave” and generators must maintain certain records and plans based on the amount of waste they generate or accumulate. Large quantity generators must maintain a site-specific emergency contingency plan, use shipping manifests and land disposal restriction forms, and prepare biannual hazardous waste activity reports. Trinity can help with identification of the waste streams and advise on available waste management options.

Hazardous Waste

Facilities that produce, store, or utilize hazardous waste as fuel, are subject to further regulations. The NESHAP for Hazardous Waste Combustors (also known as the HWC MACT) was finalized in 1999 and implemented emission limits for incinerators, cement kilns, and lightweight aggregate kilns (Phase I sources) that burn hazardous waste. In October 2005, new standards were released with a compliance deadline of 2008. These standards finalized new emission limits for Phase I sources (replacement standards) and introduced Phase II standards for hazardous waste boilers, process heaters, and hydrochloric acid production furnaces.

In addition to the NESHAP operating requirements, facilities that store hazardous waste on-site for more than 90 days, or accept hazardous waste from off-site sources must obtain a Part B RCRA permit. These permits expire after 10 years and a renewal application must be submitted 180 days prior to expiration.

Trinity waste management services include custom/onsite training on regulatory requirements, economic studies related to operational alternatives and permitting, and ongoing compliance support related to:

• Hazardous waste management (generation, treatment, storage, and disposal)
• Hazardous waste derived fuel permitting
• Non-hazardous waste derived fuel permitting
• Hazardous waste incineration permitting
• Municipal solid waste-to-energy permitting

Why Choose Trinity?

For over 30 years, Trinity Consultants has helped industrial facilities determine applicable environmental regulations and achieve compliance in the most efficient way possible. Our extensive industry experience enables us to effectively assist companies in complying with RCRA permitting requirements, air construction and operating permit requirements, emerging NESHAP and NSPS program requirements and implementation, and other requirements specific to waste management activities. For more information about Trinity’s service offerings for waste management, contact Arron Heinerikson at (913) 894-4500 or aheineri@trinityconsultants.com.