Waste and Resource Conservation and Recovery Act
Defensible waste decisions, grounded in the process.
ACP connects the generating process, waste composition, collection equipment, management practices, and records to the hazardous-waste requirements that actually apply.
Compliance audits
Start where the waste is generated and managed.
A Resource Conservation and Recovery Act compliance audit connects process knowledge to the containers, tanks, piping, labels, inspections, manifests, plans, and records visible in the field.
- Generator-category and accumulation-area review
- Waste determination and profile reconciliation
- Tank, container, Subpart BB, and Subpart CC field assessment
- Prioritized corrective actions and implementation support
Direct answer
What makes a hazardous-waste determination defensible?
A defensible determination explains where the waste originates, what enters the stream, how the material is managed, which exclusions or exemptions were considered, and what knowledge or analytical data supports the conclusion. A profile alone is not a substitute for that documented reasoning.
ACP starts with the actual operation, available records, equipment, chemicals, waste streams, permits, and work practices. The result is a clear position, documented reasoning, and an implementation plan proportionate to the real risk.
Typical deliverables
What ACP can provide
- Waste-stream assessments and written determinations
- Generator-category and accumulation-area evaluations
- Tank, container, and ancillary-equipment compliance reviews
- Subpart BB and Subpart CC applicability and monitoring support
- Wastewater treatment unit and elementary neutralization unit evaluations
- Inspection, training, contingency-plan, and recordkeeping tools
When to call
Situations that benefit from focused support
- A new process or waste collection system is being designed or started
- Waste characterization does not match process knowledge
- A tank, lift station, or container system needs review
- An exclusion or exemption must be documented
- Inspection or monitoring records are incomplete
- A facility is responding to a regulator or audit finding
Plans & written programs
Requirements translated into tools people can use.
Written programs should describe what the facility actually does, assign ownership, and make routine inspections and decisions repeatable.
- Contingency plans and emergency procedures
- Hazardous-waste inspection and accumulation procedures
- Waste determination and characterization procedures
- Subpart BB and Subpart CC monitoring programs
- Used-oil, universal-waste, and recycling procedures
Start with the situation
Need a defensible answer?
Just ask.
Send the facts and ACP will provide a direct assessment of how we can help and what should happen next.