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Changes Coming to PADEP’s Hazardous Waste Facility Inspection Guidance
The Pennsylvania Department of Environmental Protection (PADEP) is developing significant revisions to a 20-year-old document guiding how PADEP conducts inspections of hazardous waste facilities in the Commonwealth. PADEP’s intent in updating technical guidance no. 251-3120-001, entitled Performing Hazardous Waste Facility Inspections, is to create a formalized and standardized framework for implementing these inspections across all PADEP regions.
A discussion draft of the proposed revisions was circulated at the September 2025 Solid Waste Advisory Committee meeting. The draft revisions add definitions, establish four types of inspections and the expected content of each, increase inspection frequencies for hazardous waste generators and permitted treatment, storage, and disposal facilities (TSDFs), incorporate review of online data systems, and encourage inspectors to note issues that remain undetermined. The four types of inspections, which evaluate compliance with Resource Conservation and Recovery Act (RCRA) hazardous waste regulatory requirements, include:
- Compliance Evaluation Inspections (CEI) – The primary on-site evaluation of all RCRA regulations applicable to a facility. A CEI, which is usually unannounced, includes inspecting all areas of the facility and may involve environmental sampling.
- Follow-up Inspections – A partial inspection, also typically unannounced and conducted either on-site or otherwise, to verify compliance with enforcement stemming from a previous inspection or to review previously noted deficiencies.
- Administrative File Reviews – A detailed evaluation at PADEP of non-financial facility records.
- Groundwater Monitoring Evaluations – A detailed groundwater inspection by a PADEP hydrogeologist, required at all permitted or interim status RCRA TSDFs. A groundwater monitoring evaluation is completed using the federal Environmental Protection Agency’s Groundwater Monitoring Evaluation Guidance.
A wide range of compliance areas may be evaluated during these inspections. These may include, for example, preparation and recordkeeping for hazardous waste manifests, consistency with generator requirements (e.g., hazardous waste identification; management and labeling of containers in central and satellite accumulation areas; RCRA personnel training; and preparedness, prevention and emergency procedures), compliance with conditions for applicable RCRA exclusions or exemptions, and satisfaction of conditions in any hazardous waste permits. PADEP inspectors follow standardized checklists to perform facility inspections. The checklists are specific to generator facilities and TSDFs, and list specific requirements with citations to Pennsylvania and federal regulatory provisions.
Notably, the proposed revisions to the guidance document will increase the frequency of facility inspections. For hazardous waste generator facilities, PADEP intends to inspect each large quantity generator (LQG) and pharmaceutical reverse distributor every five years, with particular emphasis on LQG facilities located in environmental justice areas. Five percent of small quantity generator and very small quantity generator facilities will be inspected annually. With respect to permitted TSDFs, the agency will aim to inspect these facilities every quarter, including a full CEI in one quarter and more limited inspections in the other three quarters (or less frequently if no violations are identified during the CEI).
PADEP anticipates publishing the proposed revised guidance in the Pennsylvania Bulletin on February 14 for public comment. If you would like to discuss this guidance or other hazardous waste issues, please contact MGKF’s Rodd Bender at 484-430-2317.
