by Michael L. Walker, PE, CEM, LEED-AP
Vice President, Energy and Environmental Services

Although this is not a hot take, we were reminded during a recent RCRA workshop that National Compliance Initiatives (NCI) established for 2020-2023 will remain on the EPA’s (and State’s) priority lists for 2021.  Given a change in the administration, the priority may be heightened.

Of particular interest for the workshop was the effort to improving air quality by reducing hazardous air emissions from hazardous waste facilities.  Now, before you go off and say, “this doesn’t apply to me,” let me remind you that a hazardous waste tank at a generator’s facility is subject to Part 264/265, Subpart S requirements and is on the EPA’s radar.  That means Subpart AA, BB, and CC programs need to be developed and implemented. Our own experience in the last year with one of our clients confirms EPA’s priority on reducing these hazardous emissions.

On a similar air emission focus, EPA’s priority list includes reducing excess emissions of harmful pollutants for stationary sources.  The focus will be on significant sources of emissions of volatile organic compounds (VOCs) and hazardous air pollutants (HAPs).  Title V permitted sources should note that they may on the list for an inspection.

A third NCI priority that is trickling through the EPA is reducing the risks of accidental releases from industrial and chemical facilities.  This relates to those facilities who have (or should have) a Risk Management Plan (RMP) under 40 CFR 68.130 [a.k.a. 112(r)].  State air quality agencies will continue to conduct their regular inspections of these RMP facilities, but it is now anticipated that EPA will also be conducting additional targeted inspections.  EI has substantial experience providing RMP consulting support to facilities being inspected or challenged by state and federal agencies.

EI’s environmental professionals are available to support clients with high quality regulatory consulting for these and other environmental compliance needs.  If you have specific needs, questions or concerns, please contact me at (919) 459-5245 or [email protected].