Abstract Description: Federal and state agencies have the authority to conduct environmental inspections of facilities with no notice. This can be a trying experience for an environmental professional; preparation is the key to having a smooth inspection. The Environmental Protection Agency has recently been conducting inspections of facilities to determine compliance with the Resource Conservation and Recovery Act (RCRA) at large quantity generators of hazardous waste. The RCRA regulations are voluminous and can be confusing. The regulations have substantial recordkeeping and training requirements; this makes it easy for the agency to identify any gaps in compliance. Additionally, meeting most of the requirements is not enough for the EPA; where some state agencies might make allowances for "good enough", EPA does not. The presenter recently participated in one of these inspections and will outline the types of questions the inspector asked, the records that were reviewed, and what needs to be done in advance to prepare for a full RCRA inspection. The enforcement process will also be discussed along with the tenor of the discussions held with EPA enforcement personnel as opposed to the inspector. This inspection resulted in a substantial penalty; the goal is to share the knowledge gained and help others avoid such an outcome.
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