Ensuring RCRA Compliance at Industrial and Disposal Facilities

Under the Resource Conservation and Recovery Act, the U.S. Environmental Protection Agency regulates a wide variety of industrial facilities to control hazardous waste from the "cradle-to-grave," including hazardous waste generation, transportation, treatment, storage, and disposal. Regulated facilities include treatment, storage, and disposal facilities; mining and mineral processing operations; chemical manufacturing facilities; oil and gas facilities; petroleum refineries; auto recyclers; and landfills. EPA’s Office of Enforcement and Compliance Assurance needs support for RCRA compliance evaluation inspections at locations across the United States to ensure that regulated facilities are in compliance with RCRA requirements.

ERG has provided RCRA inspection support to OECA on an ongoing basis for more than two decades, with a focus on process streams and RCRA wastes (including waste characterization, generation, storage, and offsite transfer). ERG-led sampling and inspection teams develop planning documents for on-site inspections and sampling, and they prepare for inspections by reviewing existing facility case files, facility permits, and monitoring data. During inspections, our teams meticulously reviews the facility’s sampling and analysis plans, quality assurance project plans, and health and safety plans. They also evaluate facility financial data to assess the adequacy of current funds for addressing long-term environmental closure costs. Our teams develop reports with the level of quality and documentation required to withstand the technical and legal scrutiny associated with enforcement programs. To date, we have conducted RCRA compliance evaluation inspections of more than 300 facilities and supported many of EPA’s largest and most important RCRA cases and initiatives.