Office of Inspector General
U.S. Environmental Protection Agency
At a Glance
22-E-0009
December 1, 2021
Why We Did This Evaluation
The Office of Inspector General
conducted this evaluation to
determine the ability of
authorized state Resource
Conservation and Recovery Act
hazardous waste programs to
continue operations during the
coronavirus pandemic—that is,
the SARS-CoV-2 virus and
resultant COVID-19 disease.
Under the Act, states and
territories may be authorized to
implement the federal hazardous
waste program under
U.S. Environmental Protection
Agency regional oversight. The
EPA has authorized 48 states
and two territories to implement
the program.
States received EPA guidance to
assist in maintaining adequate
regulatory oversight during the
pandemic. Issues addressed
included holding virtual public
meetings, adjusting state
inspection commitments, and
conducting off-site compliance
monitoring activities.
This evaluation supports an EPA
mission-related effort:
•	Partnering with states and other
stakeholders.
This evaluation addresses a top
EPA management challenge:
•	Maintaining operations during
pandemic responses.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
Authorized State Hazardous Waste Program
Inspections and Operations Were Impacted During
Coronavirus Pandemic
The coronavirus
pandemic impacted
RCRA state program
operations and resulted
in fewer inspections.
What We Found
Authorized state Resource Conservation and
Recovery Act programs have continued
operations, such as inspections and public
meetings, during the pandemic. However, the
number of inspections from March 2020 through
February 2021 for RCRA treatment, storage, and
disposal facilities, known as TSDFs, decreased by 34 percent and for large
quantity generators, or LQGs, decreased by 47 percent when compared to the
prior year. The number of violations found per inspection also decreased. After
a sharp initial reduction in TSDF inspections in April 2020, states neared normal
inspection rates by July 2020, but the number of inspections decreased again in
October 2020 and remained below historical levels through February 2021.
LQG inspections followed a similar pattern except that the decrease in
inspections was more significant from October 2020 through February 2021.
Decreases in inspections during the pandemic may have been due to remote
work difficulties and travel restrictions. RCRA inspections by authorized state
programs provide a deterrent effect that protects human health and the
environment.
State RCRA programs experienced difficulties in March 2020. We surveyed
four regional directors concerning eight authorized states and found that all
eight states were initially not completely telework ready but were able to
overcome barriers so that all staff could work remotely. Two states initially had
difficulties in meeting their grant commitments, such as inspections. The EPA
worked with these states to renegotiate their commitments. Further, seven of
the eight states implemented changes, consistent with flexibilities in EPA
guidance, to hold virtual meetings with the regulated community and the public.
Recommendations and Planned Agency Corrective Actions
We made five recommendations based on issues identified in this report,
including that the Agency review data and develop plans to optimize the ability
of authorized state RCRA programs to respond to future pandemic events and
disasters. The Agency agreed with all five recommendations.
Recommendations 2, 3, and 4 are resolved with corrective actions pending.
The planned corrective actions for Recommendations 1 and 5 did not meet the
intent of our recommendations, which remain unresolved.
Noteworthy Achievement
The EPA issued multiple guidance documents during the pandemic providing
authorized state programs with flexibilities for enforcement and compliance
actions and using virtual alternatives to public meetings.

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