Review of RCRA Inspection Report Practices 

 

 

Background

 As part of an activity related to the Foundries Initiative, the Office of Compliance, Compliance 

Assistance & Sector Programs Division (CASPD) requested RCRA inspection reports from a number 

of Regions. Over 80 inspection reports covering 69 facilities were received from Regions 1, 3, 4, 5, 

7, and 10. These inspection reports covered inspections conducted by the Regional staff, Regional 

and State staff together, and by staff of authorized States. In addition, CASPD obtained another 45 

inspection reports covering multi-media inspections conducted by NEIC primarily at chemical 

production facilities. 

 The primary activity associated with these reports was an analysis to determine common areas of 

non-compliance. However, the review also provided an opportunity to see how inspections are 

conducted and documented across the country and also provided useful insight into the diversity of 

styles and information included in inspection reports. Additionally, CASPD has had discussions with 

inspectors from Regions 6 and 10 and has reviewed documents from those regions, (such as Region 

10’s, “Report Contents: the 5W ’s,” http://www.epa.gov/region10/offices/oea/ieu/manual/inspct06.htm), 

along with other RCRA guidance documents, such as the Revised RCRA Inspection Manual (1998)

(http://www.epa.gov/compliance/resources/policies/civil/rcra/rcrarevinspman-rpt.pdf ). 

 

 These discussions and document reviews have provided the basis for some recommendations, 

summarized in this document, which may be useful for RCRA core inspections and for “best 

practices” regarding RCRA inspection reports. Also included is a “model” inspection report outline 

that lists all of the elements essential to a good inspection report. The information in this document is 

an augmented “distillation” from several existing sources including: the Revised RCRA Inspection 

Manual; RCRAInfo guidance concerning “evaluation”/inspection types; and ICIS requirements. The 

recommendations provided are to be used in addition to the memorandum from Michael Alushin, 

dated April 18, 2002, “Practices to Follow and Avoid When Conducting Compliance Inspections,” 

(http://intranet.epa.gov/oeca/oc/campd/inspector/referenc/inspectpractice.pdf ).

 

Examples of Good Report Qualities and “Best Practices” 

 From analysis of the RCRA Foundries and NEIC inspections, many excellent examples of 

desirable inspection report qualities emerged, including some inspection report “best practices.” For 

example, an important inspection report quality contained in some of the reports (which should be 

included in all reports) was the purpose of the inspection. Was it part of a national priority initiative; 

follow-up to a previous inspection; or due to a tip or complaint? Additionally, there were some 

practices observed that indicate a need for a more common understanding of terminology and areas 

where improvement could occur. Report quality varied even within a Region or between Regions 

and States. 

 Several reports also included excellent narrative descriptions. Positive attributes observed 

included: descriptions organized by facility/process/inspection area; detailed references to applicable 

regulatory areas (including specific regulatory language); thorough descriptions of waste issues, 
including locations, processes, and/or facility components, conditions present, container sizes and 

amounts; and excellent documentation such as photographs and photo logs which provided 

observation dates and times. 

 Inspection reports should be written so that a person unfamiliar with the facility can understand 

how the plant is organized; against what standards it was inspected; and what waste streams were 

identified, how they were determined, and how those streams are handled by the facility. The type of 

inspection and the type of facility (i.e., a brass foundry) should be identified and SIC or NAICs codes 

and RCRA permit numbers should be provided. If possible, sizes or amounts of pollutants that may 

be associated with potential noncompliance should be given. Providing this information makes it 

easier to determine measurable outcomes from inspections. The following is an actual example from 

the foundry inspection reports’ analysis of a summary that demonstrates how information related to 

amounts of pollutants can be included in the inspection report. 

 “There were a number of containers of hazardous waste at the facility that were not properly 

labeled. The following was observed: 

● In the paint booth bunker; one 55-gallon container of paint waste (D001). The container was 

approximately 1/3 full (see Photo 7 in Attachment 2). 

● Ninety day storage area; one full 30 gallon container of waste mineral spirits (D001; see 

Attachment 6) with an illegible label. 

● Outside the 90-day storage area there were two 50-gallon containers with “Hazardous Waste” on 

the label, but with no risk label and contents unknown. Facility was unsure of contents as the 

containers had been on site prior to facility ownership transfer. One was rusted through and leaking 

and appeared to be half full. Material appeared to be a mixture of paint waste and solvents. 

● In the galvanizing room; one 3x8x5 foot tank about 2/3 full of zinc ammonia chloride solution. No 

labels were affixed. This waste is being evaporated before addition of clay-like material and is then 

shipped off as hazardous waste.” 

 This example could be further strengthened to develop an even more supportable enforcement 

case by adding additional information. For example: 

● “Paint booth bunker 1A (Photo 1) contained three 55-gallon drums of paint waste (D001, F003; 

see Attachment 1 for the facility's hazardous waste determination). One of the drums (Photos 2, 3 

and 4) was not labeled with the words "hazardous waste", the contents of the container or with the 

initial date of accumulation. The unlabeled drum was approximately 1/3 full. 

● The ninety day storage area at the south end of Building F1 (See facility map Attachment 2) 

contained one full 30 gallon container of waste mineral spirits (D001; see Attachment 3 for the 

facility's hazardous waste determination). The container had an illegible label (Photo 9). 

● Outside the ninety day storage area at the south end of Building F1 there were two 55-gallon 

containers labeled “Hazardous Waste” (Photo 12). According to Mr. Ted Smith, Environmental 

Manager, and Ms. Jane Rogers, F1 Operator, the exact contents of the drums were unknown. 

Mr. Smith stated that the drums were generated during start up of the tar still unit several years ago 

(see Process Description Attachment 11) and the decision was made to dispose of them this week. 

The facility has collected samples of each of these drums and sent them off-site for testing. The work 

order and lab receipt are included as Attachment 7. The facility asked the lab to run only TCLP 

benzene on the waste, however, based upon the inputs to the unit (Attachment 11); the compliance 

inspector believes the facility should run TCLP VOC's and TCLP RCRA 8 metals for a complete 

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hazardous waste determination. The facility agreed to run these additional tests and will share the 

results with the region. The black drum seen in Photo 12 was rusted and appeared to be leaking 

(Photo 13). The stained area was on concrete and covered approximately 8 square feet (Photo 14). 

The facility overpacked the drum and used absorbent to remove the spilled material (Photo 15). The 

spent absorbent was placed into the overpacked drum and will be disposed following hazardous 

waste determination. The facility labeled the drums ‘Tar Still waste - pending analysis’ with today's 

date during the inspection.” 

 In addition, inspection reports should document that all required procedures (such as presenting 

credentials) have been followed. All persons present during the inspection should be identified, to the 

extent possible. Most inspection reports did this. Using a cover sheet containing this information is 

especially helpful. Reports should also contain references to attachments used to substantiate the report’s 

findings (such as photos, manifests, parts of hazardous waste determination/analysis.) Including a list of 

these attachments in the report is also useful. 

 Guidance concerning requirements for inspection reports may be found in the Revised RCRA 

Inspection Manual (http://www.epa.gov/compliance/resources/policies/civil/rcra/rcrarevinspman-rpt.pdf ). 

Additional information may be found in Region 10’s Investigations & Engineering Unit’s “(Inspection) 

Report Contents: The 5W’s” (http://www.epa.gov/region10/offices/oea/ieu/manual/inspct06.htm ). 

 

Areas Needing Improvement

 The analysis also highlighted some areas where improvement could be attained. For example, 

there is a need for consistent terminology regarding inspection (evaluation) types. Some reports used 

the wrong acronym to designate the inspection type, or identified the inspection as one type when it 

was really another. Terminology has recently been revised for input into RCRAInfo, so inspection 

reports should use the acronym for inspection (evaluation) type and its corresponding definition that 

is consistent with the latest version of RCRAInfo. (See “Inspection Evaluation Type” table.) 

 Additionally, not all inspection reports contained the essential information needed to justify 

enforcement action/inaction. For example, some reports do not state the purpose of the inspection; 

such as it was conducted as part of a national priority focus, or was conducted in response to a tip and 

complaint. Inspection reports should contain at least the information required to be entered into 

RCRAInfo (and ICIS for Federal inspections). Also, inspection reports should include all the 

necessary information from which to determine whether a violation has been committed, but should 

not actually state that a violation has occurred. Simply stating the facts, such as “containers are not 

labeled,” or “a Contingency Plan is missing essential elements,” allows this determination to be 

made. Stating the regulatory language or referencing the regulatory citation of the requirements

should be done; again, without drawing a conclusion. For example: “All containers of hazardous 

waste must be stored as required by 40 CFR 262.34(d)(2) [see 40 CFR 265.173(a)]. Five absorbent 

pads (12 by 12 inches, each) used as rags were found in a bucket with no lid in the quality control 

laboratory. These pads are shipped off as hazardous waste because they cannot be landfilled.” 

 Another area where improvement is desired is in providing information concerning the amounts 

and types of pollutants addressed or discovered that may be associated with non-compliance. 

Increasingly, we must demonstrate our successes in terms of things which can be measured. 

Identifying the amounts of wastes or pollutants that are related to noncompliance, or identifying 

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reductions that occur because of our activities is extremely important for demonstrating how our 

actions benefit the public and protect the environment. Therefore, identification of wastes and/or 

pollutants potentially reduced by our actions or involved in potential noncompliance is an essential 

component of a thorough inspection report. 

 The pages following the Recommendations section contain information that may provide 

assistance in determining what information should be contained in the inspection report in general 

and also for particular types of RCRA facilities. Included are: a “Model” RCRA Inspection Report 

Outline; a list of “Recommended Areas of Inspection Focus for Specific Types of RCRA Entities;” 

and a list of Inspection (Evaluation) Types to assist with determining the inspection type that is 

consistent with RCRAInfo and ICIS terminology. 

Recommendations

 In addition to the requirements delineated in the Revised RCRA Inspection Manual and the April 

2002 “Practices to Follow and Avoid When Conducting Compliance Inspections” memorandum, the 

following are recommendations based on our analysis and review. 

Regions should: 

• Review their processes and those of states to ensure quality inspections and inspection reports. 

This addresses one of the elements of the State Review Framework. 

• Develop a template or use an existing one that meets all the essential elements of the “Model” 

Inspection Report Outline, and any other needs of the program. 

• Develop a Standard Operating Procedure (SOP) or adjust the inspection SOP if necessary, to meet 

program needs, including periodic review of inspection reports or approval of inspection reports 

by manager. 

 

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“MODEL” RCRA INSPECTION REPORT OUTLINE 

Report Heading Inspection of .... (Region X Inspection of Acme Bulletin Board Company, for example). 

Date/Time(s) of 

Inspection 

Day, year and time for the inspection. 

Type & Purpose of 

Inspection 

What type of inspection was it? (i.e. Case Development Inspection, Compliance 

Evaluation Inspection, etc.) 

What was the purpose of the inspection? (Why was inspection conducted?) For 

example, "Inspection was part of x priority and was conducted to determine 

compliance with generator standards;" or, "Inspection was the result of a 'tip and 

complaint.'" 

Facility Information Region. Facility name, address, telephone number. Name of Facility 

Representative(s), including title (position) and telephone number. Type of facility 

(including SIC or NAICS code and RCRA Identification number). 

Inspection Participants Names and affiliations of all members of inspection team and facility participants. 

Opening Conference To whom were credentials shown; who was present (names, titles or positions), what 

was discussed; specific arrangements; entry granted or denied. 

Facility Description What was the facility like, including processes, RCRA-related activities, wastes 

generated, treated, stored, etc. 

Site History Compliance history and history of facility site location to extent known or ascertainable. 

Inspection Narrative Description of the field inspection events and observations. Where did you go? What 

did you see/do? What records were reviewed, copied, taken? Where were records kept 

and who was in charge of them? What selection method was used to select records 

reviewed? Which records were used? Were samples taken? Of what? Were there 

splits? Were photos taken to document the conditions observed? [If documentation is 

provided elsewhere (attachments, for example), it should be referenced here.] 

Compliance 

Concerns/Deficiencies 

Regulatory citation; nature of problem; size and quantities of areas concerned (for 

example, "5 fifty gallon drums."). Do not use the word "violation," or draw 

enforcement conclusions, but do state what problems were observed and how this 

relates to regulatory requirements. For example: "40 CFR 262.34(a)(3) requires that 

containers of hazardous waste that are accumulated on-site be marked with the words 

"hazardous waste. At the time of the inspection the hazardous waste storage area 

contained five "super sacks" (holding approximately 10 cubic yards each) of baghouse 

dust from the electric arc furnace. The baghouse dust from the electric arc furnace 

has tested characteristically hazardous for cadmium and/or chromium. None of these 

sacks were labeled "hazardous waste," or marked with the accumulation start date." 

Actions Taken By 

Facility Related to 

Deficiencies 

For example: verified compliance with previously issued enforcement action; corrected 

recordkeeping deficiencies; completed a notification or report; corrected monitoring 

deficiencies; requested a permit application; implemented new or improved 

management practices or procedures; improved pollutant identification (e.g. labeling, 

manifesting, storage, etc); reduced pollution (e.g. use reduction, industrial process 

change, emissions or discharge change, etc.) (Specify the pollutant(s) and amounts 

reduced) 

Compliance Assistance Although not required, if assistance materials are provided, state what was provided 

and whether it was general or site-specific. 

Attachments List and describe all documentation including photographs, drawings, receipts, notices, 

etc. 

Date and Signature Make sure the report is signed and dated. 

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 RECOMMENDED AREAS OF INSPECTION FOCUS FOR SPECIFIC TYPES OF RCRA ENTITIES 

FOR GENERATORS

General Standards For 

Generators

Parts 262.10 – 262.12. 

 Describe compliance with these standards. 

The Manifest Parts 262.20 – 262.23. Establish existence of manifest records; 

assess adequacy with respect to regulatory requirements. 

Pre-Transport Requirements Parts 262.30 – 262.34 . Review packaging, labeling, marking and 

placarding procedures for compliance with the regulations; establish 

compliance with accumulation time restrictions. 

Recordkeeping and 

Reporting 

Parts 262.40 – 262.43. Establish existence of annual reports and 

additional reports. 

Special Conditions Parts 262.50 – 262.51. Inspect for reports of international shipments 

of waste, and proper notification of the Administrator. 

Standards for Universal 

Waste Management 

Part 273. Inspect for proper management of universal waste 

including: batteries, not covered elsewhere; recalled pesticides; 

mercury-containing equipment; and hazardous waste lamps. 

Standard for the 

Management of Used Oil 

Part 279. Inspect for compliance with used oil standards including: 

standards for used oil generators; standards for used oil collection 

centers and aggregation points; standards for used oil transporter and 

transfer facilities; standards for used oil processors and re-refiners; 

restrictions on burning for energy recovery; used oil fuel marketing; 

and use as a dust suppressant. 

FOR TRANSPORTERS

General Parts 263.10 – 263.12. Ensure that the transporter has obtained an 

EPA ID number and only stores waste at transfer facilities fewer 

than 10 days 

Manifest System and 

Recordkeeping 

Parts 263.20 – 263.22. Establish existence of manifest records and 

compliance with manifest procedures. 

Hazardous Waste 

Discharges 

Parts 263.30 – 263.31. Ensure that transporter is aware of 

responsibilities under these sections. Check to see if any discharge 

reports have been made to the Department of Transportation as 

required by these regulations. 

FOR TSDFs

General Facility Standards Parts 264/5.10 – 264/5.18. Describe compliance with standards. 

Preparedness & Prevention Parts 264/5.30 – 264/5.37. Check for required equipment and 

arrangements with local authorities. 

Contingency Plan & 

Emergency Procedures 

Parts 264/5.50 – 264/5. 56. Check records and procedures for 

conformance with requirements of this section. 

Manifest System, 

Recordkeeping, & Reporting 

Parts 264/5.70 – 264/5.77. Establish existence of manifest records, 

operating record, annual report, and unmanifested waste report. 

Assess conformance with regulatory requirements.. 

Groundwater Monitoring Parts 264/5.90 - 264.99 or 265.94. Examine ground-water 

monitoring plan and review results of sampling analysis 

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Corrective Action Program Parts 264.100 – 101. Review status of corrective action program) 

Closure and Post Closure Parts 264/5.110 - 264/5.120 (Review closure and post-closure 

plans for adequacy with respect to regulatory requirements 

Facility Specific Standards Parts 264/5.170 - 264.603 or 265.445 and Parts 264/5.1100 - 

1102. Depending upon the type of facility being inspected, 

establish compliance with the appropriate regulatory standard. 

Permit Conditions For permitted facilities, review violations of specific permit 

conditions or schedules of compliance. 

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 Inspection (Evaluation) Type* 

Acronym Description Definition 

CAC Corrective 

Action 

Compliance 

Evaluation 

An evaluation of a site’s compliance with the corrective action 

requirements of a permit or an order. When a CAC is conducted as part 

of another inspection type (CEI, GME, etc.) a separate entry for a CAC 

should be made for the CAC component. 

CDI Case 

Development 

Inspection 

A CDI is an on-site inspection conducted for the sole purpose of 

gathering additional information that supports the evidence (i.e. 

samples, on-site records review, interview, etc.) for a potential or 

pending enforcement case. A CDI is performed only after an initial 

evaluation has resulted in observation of potential violations. 

CEI Compliance 

Evaluation 

Inspection 

A CEI evaluation is primarily an on-site evaluation of the compliance 

status of the site with regard to all applicable RCRA Regulations and 

Permits (with the exception of groundwater monitoring and financial 

assurance requirements.) Although portions of a CEI evaluation may 

routinely be conducted in an office setting, such “office” evaluations are 

considered an integral part of a CEI in terms of completing an 

evaluation. The overall evaluation of a site’s compliance status may 

take place over multiple days necessitating multiple site visits and 

activities. The entire set of activities associated with the effort are 

considered a single CEI. 

The major function of a CEI is an overall review if the site’s 

performance. The inspection includes an on-site examination of records 

and other documents maintained by the site an evaluation of the site’s 

compliance with all applicable requirements and adequate sampling, 

where necessary. Where appropriate, it includes groundwater 

monitoring assessment outlines or plans, closure/post-closure plans, 

contingency plan reviews, waste analysis plan reviews, and 

preparedness and prevention plan reviews. Specifically excluded from 

the CEI type of evaluation are financial assurance requirements and 

inspections of groundwater monitoring systems. A review of financial 

assurance requirements is most often conducted by “agency experts,” 

and appropriately recorded as a Financial Record Review (FRR) 

evaluation. Inspections of groundwater monitoring system are recorded 

as either GME or OAM. 

CSE Compliance 

Schedule 

Evaluation 

An evaluation conducted to verify compliance with an enforceable 

compliance schedule associated with a formal enforcement action. 

When a CSE is conducted as part of another inspection type (CEI, 

GME, etc.), a notation should be made. 

FCI Focused 

Compliance 

An FCI is an on-site inspection that addresses only a specific portion or 

subpart of the RCRA or authorized State regulations/programs. For 

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example, a Subpart CC, BIF, or Universal Waste Rule inspection. 

Nationally defined Focus Areas are used with this evaluation type. 

FRR Financial 

Record 

Review 

An extensive and detailed review of a site’s compliance with Financial 

Responsibility requirements. These are conducted in the Agency office, 

and not on-site. 

FUI Follow-up 

Inspection 

A partial on-site inspection conducted to verify the status of violations 

cited during a previous evaluation. This type of inspection is only used 

if a more extensive inspection is not conducted – for example, 

inspections following up to formal/informal actions where no 

enforceable compliance schedule has been established. 

GME Groundwater 

Monitoring 

Evaluation 

A detailed evaluation of the adequacy of a site’s groundwater 

monitoring system as per EPA’s final RCRA Compliance Groundwater 

Monitoring Evaluation Guidance Document. An evaluation of the 

groundwater system design should be conducted by a hydro-geologist 

and include a review of the owner/operator’s characterization of the 

hydro-geology beneath hazardous waste management units, monitoring 

well placement and depth/ spacing, and well design and construction. 

An integral part of the GME is the review of the operation of the 

groundwater monitoring system through evaluation of the 

owner/operator’s sampling and analysis plan and implementation. 

Splits and/or sampling should be conducted as a check of groundwater 

quality at any wells that may have indicated releases to support 

enforcement or corrective action. GME’s should include: a detailed 

investigation of the engineering features and effectiveness of the 

groundwater monitoring system; a detailed review of the site’s 

groundwater sampling and analysis plan; recalculation of statistics at 

detection monitoring facilities to ensure that the site should not be in 

assessment; detailed examination of the site’s assessment monitoring 

plan & field implementation; re-evaluation of groundwater flow 

direction; and a substantial amount of sampling. 

OAM Operation & 

Maintenance 

Inspection 

A periodic inspection of how well a groundwater monitoring system 

continues to function once it is considered well designed. The 

inspection focuses on the condition of well and sampling devices. 

Evaluation of well recovery notes, turbidity of water, total depth, depth 

to water, etc. should be made and compared to historic data. Sampling 

devices should be tested and, if necessary, pulled and visually inspected. 

The findings of an O&M inspection will indicate whether case 

development is warranted and/or will serve to focus future GME’s. 

* In accordance with RCRAInfo Guidance. 

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