EPA’s Office of Inspector General (OIG) has launched an investigation to determine whether EPA is inspecting hazardous waste treatment, storage and disposal facilities (TSDFs) in compliance with the law.

According to a memorandum announcing the effort, OIG will specifically seek to determine whether EPA is inspecting TSDFs as frequently as required by the law. RCRA Section 3007(e) requires EPA to inspect commercial TSDFs at least every two years. TSDFs owned or operated by federal or state agencies are to be inspected at least annually, pursuant to RCRA Sections 3007(c) and (d), respectively.

There can be little doubt that OIG launched the review in response to claims that EPA is not satisfying its inspection requirements. It is likely that EPA will respond, in part, to the OIG investigation by claiming its inspections include various manners of reviews (records reviews, financial assurance reviews, and others) and are not limited to the traditional, on-site review.

OIG stated that it will complete the effort by the end of EPA's 2015 fiscal year.