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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
2007-P-00005
December 4, 2006
Why We Did This Review
This review was conducted to
evaluate the effectiveness of
the U.S. Environmental
Protection Agency's (EPA's)
(1) efforts to address the
regulation of hazardous waste
units granted interim status
under the Resource
Conservation and Recovery Act
(RCRA), and (2) information
management system
(RCRAInfo) in tracking permit
information for interim status
units.
Background
Under Subtitle C of RCRA,
hazardous waste facility units
that perform treatment, storage,
and disposal activities must
receive permits prior to
operation. When new
hazardous waste statutes or
regulations are implemented,
units that already exist may
continue operating in a
condition known as interim
status by notifying EPA of their
intent and supplying basic
information. Units may remain
in interim status until issuance
or denial of a permit.
For further information,
contact our Office of
Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2007/
20061204-2007-P-00005.pdf
Catalyst for Improving the Environment
EPA's Management of Interim Status Permitting Needs
Improvement to Ensure Continued Progress
What We Found
Interim status is a temporary designation, but some units have existed for as many
as 25 years without formal issuance or denial of a permit, or other regulatory
controls. Under the Government Performance and Results Act (GPRA), EPA has
a RCRA National Permitting Goal to ensure that all units at hazardous waste
facilities have "controls in place." EPA includes interim status units in this goal,
and the Agency's data indicate that it has made progress in ensuring controls are
in place at interim status units. As of 2005, EPA had attained the "controls in
place" designation for 89 percent of RCRA hazardous waste facilities.
However, EPA's continued progress may be compromised because (1) the
Agency has not sufficiently documented some changes to the baseline it uses to
measure progress; (2) EPA does not prioritize its National Permitting Goal
activities according to the potential risks posed by hazardous waste facilities or
units, including the amount of time a unit may have been operating without
required controls; (3) EPA does not monitor the creation of "new" interim status
units in its reporting and tracking system (RCRAInfo); and (4) RCRAInfo lacks
other system controls to protect data integrity and data quality, which may lead to
the loss of historical information needed to track permit status. Despite data
quality problems, RCRAInfo data are available for public use without appropriate
disclaimers.
What We Recommend
In order to ensure valid progress in achieving "controls in place" at interim status
units, we recommend that the Assistant Administrator for Solid Waste and
Emergency Response:
•	Implement a process to document changes to the GPRA National
Permitting Goal baseline.
•	Review State GPRA National Permitting Goal projections for 2008 and
2011 to identify opportunities for prioritizing facilities based on risk,
including time in interim status.
•	Oversee the designation of "new" interim status units in RCRAInfo.
•	Implement RCRAInfo system controls to ensure data integrity and
improve data quality.
•	Provide a disclaimer on data released publicly from RCRAInfo until data
quality controls are in place.
The Agency generally concurred with our recommendations.

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