Practical Compliance Support for Regulated Waste, Hazardous Materials, and Environmental Response

Souder, Miller & Associates (SMA) provides Resource Conservation and Recovery Act (RCRA) compliance support, hazardous and unknown substance characterization, environmental response oversight, and waste management services for public, private, federal, and tribal clients throughout New Mexico, west Texas, southeast Utah, and southern Colorado.

Our environmental professionals help clients identify, evaluate, classify, manage, document, and report regulated materials in accordance with the RCRA, applicable state programs, and local and tribal requirements. Whether supporting a single unknown container, a recurring waste stream, a corrective action site, or a multi-facility compliance program, SMA provides responsive, practical, and defensible solutions that help clients maintain compliance and move projects forward.

Hazardous and Unknown Substance Testing and Characterization

Managing hazardous and unknown materials requires accurate data, appropriate sampling methods, and documentation that can withstand regulatory review. SMA assists clients with the testing and characterization of solid and liquid materials to determine whether a material is hazardous, non-hazardous, reusable, treatable, or suitable for disposal.

Services include:

  • Sampling and characterization of solid and liquid materials
  • RCRA hazardous waste determinations
  • Waste stream evaluation and regulatory classification
  • Physical and chemical characterization to support treatment, disposal, reuse, or remediation decisions
  • Documentation for internal compliance records, agency review, and project files
  • Coordination with accredited laboratories and approved analytical methods

Typical testing may include RCRA characteristic testing for ignitability, corrosivity, reactivity, and toxicity; TCLP analysis and other leaching procedures; metals, organics, hydrocarbons, and other constituents of concern; and additional analyses required by federal, state, tribal, or project-specific requirements.

RCRA Waste Management

SMA supports regulated waste management from initial identification through final treatment, storage, disposal, and documentation. Our team helps clients implement practical "cradle-to-grave" waste management procedures that address regulatory requirements while considering project schedules, cost, risk, and operational needs.

SMA can assist with:

  • Waste identification and characterization
  • Waste profiling and disposal coordination
  • Generator status evaluation and compliance support
  • Manifesting, labeling, storage, and recordkeeping procedures
  • Treatment, storage, and disposal facility coordination
  • Corrective action and closure support
  • Cost-effective management of hydrocarbon-impacted soil and water
  • Compliance with federal, state, local, and tribal requirements

Regulatory Reporting and Documentation

Clear, organized documentation is essential for maintaining compliance and responding to agency inquiries, audits, and internal management needs. SMA prepares practical, regulator-friendly reports that help facility managers, project teams, and owners understand obligations and support informed decisions.

Documentation services include:

  • Hazardous waste determination reports
  • Sampling and analytical summaries
  • Waste characterization reports
  • State-specific and tribal land compliance documentation
  • Data interpretation and regulatory applicability evaluations
  • Agency submittal support
  • Audit support and compliance recordkeeping
  • Training related to regulatory reporting and documentation

Emergency Spill Response Oversight

SMA provides technical and regulatory oversight for spill and release incidents involving petroleum products, hazardous substances, industrial materials, and unknown wastes. Our role may include regulatory guidance, sampling strategy, documentation, communication support, and oversight of response contractors without requiring direct response fieldwork by SMA personnel.

SMA supports incidents involving transportation corridors, industrial facilities, mining operations, oil and gas facilities, public infrastructure, and remote sites across the region.

Services include:

  • Regulatory reporting and notification support
  • Coordination with EPA, NRC, state agencies, tribal authorities, and local responders
  • Sampling plan development and field oversight
  • Soil, surface water, and groundwater impact assessment
  • Waste classification and disposal coordination
  • Compliance support under RCRA, Clean Water Act, SPCC, and related programs
  • Documentation for agency files, insurance review, and owner records

RCRA Compliance Support by Professional Engineers

Some RCRA compliance programs require certifications, inspections, or technical evaluations by licensed Professional Engineers. SMA has Professional Engineers on staff who can support RCRA-related compliance needs, including technical review, certification, and documentation where required.

Professional engineering support may include:

  • Hazardous waste tank system evaluations
  • Structural integrity assessments for new and existing systems
  • New tank installation inspections and pre-service evaluations
  • Containment building design and operating standard certification
  • Closure and post-closure certification support
  • RCRA permit application technical support
  • Part B permit application review and certification of technical data
  • Integrated Contingency Plan / "One Plan" support
  • SPCC Plan preparation, certification, and implementation support
  • NPDES permitting, sampling, and monitoring support related to facility compliance
  • Sarbanes-Oxley (SOX) compliance for environmental liabilities

Brownfield and Corrective Action Support

SMA helps communities, developers, facility owners, and public agencies evaluate and redevelop contaminated or underutilized properties. Our environmental team supports Brownfield redevelopment, corrective action, site characterization, and risk-based decision-making so that properties can be returned to productive use.

Services may include:

Environmental and Hazardous Materials Training

SMA provides job-specific training programs to help clients maintain compliance, improve employee awareness, and reduce risk. Training can be tailored to facility operations, field crews, managers, environmental staff, or compliance personnel.

Training topics may include:

  • RCRA waste identification, handling, manifesting, recordkeeping, and emergency procedures
  • DOT HAZMAT transportation and security awareness
  • HAZWOPER training for hazardous operations and response
  • SPCC Plan implementation and spill prevention procedures
  • Waste screening training for landfills, including identification and management of prohibited or hazardous materials and household hazardous waste

Training may be provided in instructor-led or online formats depending on client needs and regulatory requirements.

Regional Experience Across the Four Corners and Surrounding Areas

SMA provides RCRA compliance and environmental support throughout New Mexico, eastern Arizona, west Texas, southeast Utah, and southern Colorado, including work on tribal land and in remote or operationally complex areas. Our regional presence helps clients address federal requirements while navigating state-specific programs, local expectations, and tribal jurisdictional considerations.

Our team understands that regulatory requirements and agency expectations can vary by location. SMA works with clients to develop compliance strategies that are technically sound, clearly documented, and practical for facility operations, construction projects, emergency response, and long-term environmental management.

Integrated Environmental, Engineering, and Geomatics Support

RCRA compliance often overlaps with broader environmental, civil, surveying, and infrastructure needs. SMA's multidisciplinary team can support related project requirements, including environmental site assessments, soil and groundwater investigation, remediation planning, stormwater compliance, SPCC planning, NPDES support, GIS mapping, surveying, and civil engineering.

This integrated approach allows SMA to help clients evaluate the full project picture—from initial material characterization or spill response through regulatory reporting, corrective action, redevelopment, or facility improvement.

Practical, Defensible Solutions

From unknown material testing to complex waste management programs, SMA provides clear guidance, reliable data, and practical solutions for regulated materials and environmental compliance. Our goal is to help clients minimize risk, meet regulatory obligations, control costs, and make informed decisions with confidence.

If your facility, project, or community needs RCRA compliance support, hazardous material characterization, spill response oversight, or environmental training, SMA is ready to help. Contact us today: RCRASupport@soudermiller.com