July 15, 2019

National Compliance Initiatives Bring New Focus

The FY2020–2023 national compliance initiatives (NCIs) have been released by EPA’s Office of Enforcement and Compliance Assurance (OECA). Every few years, EPA reviews and updates its NCIs to help federal and state regulators focus on areas of widespread noncompliance or areas that otherwise need extra attention for protection of human health and the environment. To assist federal, state, and tribal personnel in implementing these NCIs, OECA is developing implementation frameworks consisting of compliance assistance, self-audits, and various enforcement actions. For FY2020–2023, there are seven NCIs that align with the agency’s strategic plan:

Creating cleaner air for communities by reducing excess emissions of harmful pollutants from stationary sources,
Reducing hazardous air emissions from hazardous waste facilities,
Stopping aftermarket defeat devices for vehicles and engines,
Reducing significant noncompliance with national pollutant discharge elimination system permits,
Reducing noncompliance with drinking water standards at community water systems,
Reducing risks of accidental releases at industrial and chemical facilities, and
Reducing childhood exposure to lead.

For the RCRA-focused among us, reducing air emissions from hazardous waste facilities means Subparts AA, BB, and CC compliance, which was also an NCI from FY2016–2019. These subparts, found in Parts 264 and 265, require large quantity generators and TSD facilities to reduce organic air emissions from hazardous waste management units. Last year, EPA released a compliance advisory to assist the regulated community in understanding its air emissions compliance requirements. You can get the compliance advisory and our summary from our website.

McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.

Disclaimer

Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.