In June, the U.S. Environmental Protection Agency issued an enforcement alert that highlights recent enforcement activities related to its National Compliance Initiative focus on air emissions regulated under the federal Resource Conservation and Recovery Act, or RCRA.
The National Compliance Initiative serves to identify the EPA's leading priorities for national enforcement — and indeed, it is believed that the agency has numeric targets for inspections and investigations for RCRA air emissions compliance requirements.
Facilities that generate, treat, store or dispose of hazardous waste must be aware of these requirements, and the potential enforcement implications of the EPA's initiative. But the agency's enforcement strategies have changed during the COVID-19 pandemic, as have the operations — and air emissions — of many facilities.
