Executive Summary

Introduction

The purpose of this audit was to determine whether National Aeronautics and Space Administration (NASA) Lewis Research Center (LeRC) properly managed the hazardous waste leaving its facilities. Specifically, we assessed whether LeRC had controls in place to achieve compliance with hazardous waste regulations and whether the controls were adequate. Environmental Protection Agency (EPA) and Department of Transportation regulations govern the disposal of hazardous waste due to its danger to human health and the environment. LeRC is responsible and liable for the hazardous waste until disposal; therefore, proper identification and physical control over LeRC-generated waste is important. The key document used to track the waste throughout the disposal process is the EPA hazardous waste manifest form, which the EPA requires the generator (LeRC) to certify.

Results of Audit

LeRC's hazardous waste manifest process was generally compliant with the environmental, transportation, and LeRC regulations and requirements tested. However, internal control weaknesses existed in four areas essential to ensuring full regulatory compliance and minimizing LeRC's liability when disposing of hazardous waste. First, a 24-hour emergency response telephone number was not included or clearly visible on all hazardous waste manifest forms. Second, the hazardous waste manifest files maintained by the support service contractor did not contain documentation to support compliance with regulations, and the manifests were not accurate. Third, manifests were not being adequately controlled to ensure review and signature by authorized personnel. Lastly, required training by environmental office civil servant and contract staff was not completed. Additionally, the Environmental Management Office's support service contractor was not always implementing a compliant hazardous waste management program as required by the contract. This report contains recommendations that will help the Center ensure regulatory compliance and the effective management of the hazardous waste manifest process.