Consultants are a significant source of information for hazardous waste generators whether by providing information necessary for compliance, such as making hazardous waste determinations, offering employee hazardous waste training or setting up a short- term storage area; or by dealing directly with hazardous material spills or arranging for disposal of hazardous waste on behalf of their Vermont clients.
Unlike hazardous waste handlers (generators/transporters/TSDs), there currently are no regulations that specifically address the activities of consultants operating in Vermont. Because consultants can have a profound influence on the compliance of generators and other hazardous waste handlers, we are providing links to a variety of resources that consultants can utilize and refer their clients to.
The Vermont Hazardous Waste Management Regulations (VHWMR) - Vermont ‘s hazardous waste program is authorized by EPA to operate in lieu of the federal RCRA Subtitle C program. As an authorized state, Vermont maintains its own hazardous waste regulations that, while generally equivalent to the federal hazardous waste regulations, in many areas are either broader in scope (e.g., state-only regulated hazardous wastes) or more stringent (e.g., Vermont requires daily rather than weekly inspections of short-term storage areas) than the federal regulations. It therefore is critical that consultants who are familiar with the federal RCRA hazardous waste regulations verify the accuracy of any information offered to Vermont clients since the VHWMR differ from the federal regulations in many areas.
Online – An EPA database of regulatory interpretations, guidance
documents, and policy letters. These policy letters are specific to EPA regulations, but may be applicable to Vermont's hazardous waste regulations.
Manifest and Taxes Page - If you are assisting generators in completing manifests or signing manifests as "offeror" for generators, this page will provide information to assist you in properly completing manifests and avoiding common manifest errors. This page also includes information on the hazardous waste tax.
Do I need to get an EPA number? See the EPA ID Number and Site ID Form FAQ
Vermont Hazardous Waste Handler Site ID Form
Temporary ID Number Form
Hazardous Waste Determination Fact Sheet - Any waste generated by a Vermont business must be evaluated to determine if it is hazardous waste. This fact sheet walks generators through the hazardous waste determination process as specified in Subchapter 2 of the VHWMR.
Identification of Unknowns Guidance - Consultants are often contracted to assist generators or property owner in identifying waste of unknown origin or content. This guidance provides the process for identification of unknowns. - Coming soon...
Hazardous Materials Spill Response Fact Sheet - This fact sheet applies to any Vermont business or municipality that handles hazardous materials (including hazardous waste, petroleum products, or CERCLA hazardous substances*), and consequently may need to respond to a release of hazardous material (spill) to the environment. It summarizes the spill response requirements included under Section 7-105 in the VHWMR and describes response procedures for spills that occur at fixed facilities and during transportation.
Investigation and Remediation of Contaminated Properties Proceedures (IROCP)- The “petroleum-contaminated soils” exemption (see VHWMR 7-203(p)) relies on compliance with this procedure. The IROCP also addresses many other issues related to the remediation of contaminated properties.
Policy and guidance on “Contained-in” determinations for materials contaminated with listed hazardous waste - Coming soon...
Hazardous Waste Generator Closure:
A small or large quantity generator who no longer generates or manages hazardous waste at a site must, within 90 days of cessation of hazardous waste activities, close the site. To ensure that all hazardous wastes have been properly managed when a business closes, the revised VHWMR require that “large quantity generators” and “small quantity generators” submit a “Pre-closure Notification” form at least 90 days prior to the commencement of closure activities. A copy of this form is available on-line at: http://www.anr.state.vt.us/dec/wastediv/rcra/documents/Preclosurenotificationform.pdf The Pre-Closure Notification form requires basic information about the generator’s site of operations, a contact person for that site, the types of waste generated by the business that is closing, underground storage tanks (if applicable), and any spills of hazardous materials or hazardous waste that may have occurred at the site. Based on the information provided in the form, Vermont’s Hazardous Waste Program will determine if a more detailed closure plan is necessary to ensure clean closure. The requirements for “generator closure” are included under section 7-309(c) of the VHWMR.
Where can I find data?
Waste Management Interactive Database (WMID)
This tool provide the public to access to up-to-date environmental information on property specific information concerning contaminated groundwater sites, hazardous materials spills, and regulated underground storage tanks facilities located in Vermont
Agency of Natural Resources Natural Resource Atlas
A web-based, digital map of Vermont's natural resources and environmental oversight.
EPA's Enforcement and Compliance History Online (ECHO)
ECHO provides fast, integrated searches of EPA and state data for 800,000+ regulated facilities and integrates inspection, violation, and enforcement for the Clean Water Act, Clean Air Act, and hazardous waste laws. ECHO also includes Safe Drinking Water Act data, Toxics Release Inventory data, National Emissions Inventory data, and Water Quality Data.
The Environfacts Multisystem Search integrates information from a variety of databases and includes latitude and longitude information. Each of these databases contains information about facilities that are required to report activity to a state or federal system. Using this form, you can retrieve information about hazardous waste (including the Biennial Report), toxic and air releases, Superfund sites, and water discharge permits. Facility information and a map of its location is provided.