Types of Hazardous Waste Inspections
There are six different types of inspections used to monitor compliance with RCRA.
The compliance evaluation inspection (CEI) is an on-site evaluation of a hazardous waste handler's compliance with RCRA regulations and permit standards. The purpose of the CEI is to gather information necessary to determine compliance and support enforcement actions.
The inspection may include:
- a characterization of the handler's activities
- identification of the types of hazardous wastes managed on-site
- a record review of reports
- documents, and on-site plans
- the identification of any units that generate, treat, store, or dispose of hazardous waste
EPA sometimes finds it necessary to inspect a facility in order to collect samples for laboratory analysis. These sampling inspections are very resource-intensive because they require advanced planning for the sampling scheme and laboratory analysis. A sampling inspection may be conducted in conjunction with a CEI or any other inspection.
During the comprehensive groundwater monitoring evaluation (CME), enforcement officials evaluate the adequacy of the design and operation of a facility's groundwater monitoring system. This
evaluation should be completed by a hydrogeologist.
- a review of the owner and operator's characterization of the hydrogeology underlying the hazardous waste management units
- monitoring well placement, depth, and spacing
- well design and construction
The CME is used to determine whether a facility implementing detection monitoring should instead be using compliance or assessment monitoring. CMEs at compliance or assessment monitoring facilities include a detailed examination of the assessment monitoring plan and implementation of the plan.
The case development inspection (CDI) is an intensive investigation that is conducted to gather sufficient information to support an enforcement action. The CDI can be used to collect supplemental data to support a forthcoming enforcement action identified through a CEI, a CME, or a record review.
The operation and maintenance inspection (OMI) occurs periodically, evaluating whether a groundwater monitoring system is continuing to function as designed. The OMI focuses on the condition of the wells and their associated sampling devices. The findings from an OMI will indicate whether case development is warranted or will serve to focus future CMEs.
In addition to authorizing EPA to conduct inspections, Section 3007 allows the Agency to request specific information from "...any person who generates, stores, treats, transports, disposes of, or otherwise handles or has handled hazardous wastes." This means EPA may request information from past generators as well as those parties who may not have been subject to the RCRA regulations, but who have actually handled hazardous waste.
Normally the public has access to the information obtained under Section 3007 authority. The facility owner and operator may, however, claim records or other information gathered by EPA as confidential business information by submitting the information with a cover sheet stamped "confidential," "trade secret," or "proprietary information" (Section 3007(b)). EPA will then determine whether or not the material is confidential.
In addition to obtaining information for enforcement proceedings,EPA may use Section 3007 authority to gather data to assist in the development of regulations and to track program progress and accomplishments.