x°,EPA COMPLIANCE ADVISORY

OFFICE OF ENFORCEMENT
AND COMPLIANCE ASSURANCE

National Compliance Initiative: Creating Cleaner Air for Communities by Reducing Excess Emissions of Harmful

Pollutants from Stationary Sources

EPA Document # 315F22001	March 2023

Federal Facility Compliance Under EPA's National
Enforcement and Compliance Initiative to Create Cleaner

Air for Communities

>	This advisory notifies federal facilities with Clean Air Act (CAA) stationary sources that release volatile organic
compounds (VOCs), hazardous air pollutants (HAPs), and other criteria air pollutants, about U.S. EPA's National
Enforcement and Compliance Initiative (NECI) to reduce excess releases of these pollutants and help facilities with
compliance problems achieve or maintain compliance.

>	EPA is concentrating its efforts on significant sources of VOCs that have a substantial impact on air quality and may
adversely affect (1) an area's attainment of National Ambient Air Quality Standards (NAAQS) or (2) vulnerable or
overburdened populations.

>	EPA will reduce excess emissions of VOCs and HAPs by addressing significant violations to achieve measurable
pollutant reductions at federal and private sources to improve air quality.

>	EPA is working with states and other regulators to also address the environmental concerns and public health risks
that stem from excess VOC and HAP emissions in those localities.

>	View EPA's Creating Cleaner Air for Communities (CCAC) NECI: https://www.epa.gov/enforcement/national-
compliance-initiative-creatinq-cleaner-air-communities-reducinq-excess

Federal Facility Responsibilities Under the Clean Air Act

Section 118 of the CAA requires federal facilities to comply with federal, state, interstate, and local requirements to control
and abate air pollution. The CAA requires EPA to set NAAQS for criteria air pollutants that can be harmful to public health
and the environment. Federal facilities must comply with the nation's environmental laws, including the CAA and the
applicable National Emission Standards for Hazardous Air Pollutants (NESHAPs), New Source Performance Standards
(NSPS), and State, Federal, and Tribal Implementation Plans. Failure to comply with these regulations may cause excess
emissions that contribute to a violation of the NAAQS. Noncompliance with NESHAPs, NSPS, and other applicable
regulatory requirements may subject federal facilities to enforcement by EPA or the delegated state.

This NECI focuses on noncompliance resulting in excess emissions of either VOCs or HAPs. People living in communities
near significant sources of excess VOC or HAP emissions that adversely affect air quality or the attainment status of an
area may face significant risks to their health. HAPs are pollutants known or suspected to cause cancer or other serious
health effects through inhalation or ingestion. VOCs are a key component in the formation of ground-level ozone and
secondary organic aerosols, both of which may impact ecosystems and cause adverse health effects like respiratory
ailments.

In the United States, over 100 million people live in areas that do not meet current air quality standards. These conditions
may cause health problems and result in economic impacts due to lost work, school days, and productivity. EPA
estimates that 14 million people in just 60 urban areas of the United States have more than a 1 -in-10,000 lifetime risk of
developing cancer caused by air pollution. To address noncompliance that is threatening these communities, including
overburdened communities and people most vulnerable to the negative health and environmental impacts, this NECI
prioritizes efforts to reduce excess emissions from both federal and private sources that cut across industries.

How Does This Initiative Impact Federal Facilities?

This NECI is intended to ensure that all regulated entities, including federal facilities, comply with all CAA regulatory
requirements, including the applicable NESHAP, NSPS, and State, Federal, and Tribal Implementation Plans. If

Compliance Advisory	Page 1


-------
noncompliance is identified, EPA and other regulatory partners will use their enforcement authorities to return facilities to
compliance.

Federal agencies should ensure that their facilities are in compliance and do not release excess VOC or HAP emissions
that cause significant harm to the public, including overburdened communities with environmental justice concerns.
Because federal facilities and installations are often located near these vulnerable or underserved communities, federal
agencies should utilize the full range of compliance assurance tools, including those listed below, and other available
resources to monitor the release of VOC or HAP emissions. EPA is highlighting this priority area for federal facilities so
they may take the necessary steps to promptly address any noncompliance. Specifically, EPA recommends that federal
facilities with landfills, engines, boilers, spray booths, and other operations that are subject to NSPS and NESHAP
requirements and may be covered by this initiative review their compliance obligations.

How Do I Check the Status of Federal Facilities Subject to Emissions
Requirements?

Federal facilities with stationary sources that emit VOCs and HAPs must ensure that they are in compliance with all
environmental obligations, including recordkeeping, reporting, and monitoring requirements, and are encouraged to
assess their compliance status through the following resource:

>	Use EPA's Enforcement & Compliance History Online (ECHO) tool to access your detailed facility report. EPA
recommends that federal facilities review their compliance statuses in ECHO on a regular basis.

If your facility is identified in ECHO as being in noncompliance with the CAA, EPA recommends that you take prompt
corrective actions to address this noncompliance. If you believe the noncompliance designation is data error, EPA
recommends that you use the "Report Data Error" function in ECHO to report the error or work with your delegated
authority (either an authorized state or EPA) to resolve the issue.

EPA strongly recommends federal partners register for an ECHOGov account at https://echo.epa.gov/. This registration
will provide access to enhanced functions only available to ECHOGov users. To register for an ECHOGov account, you
will need to validate your government email by following these steps:

1)	From the ECHO main page click "Contact Us" in the upper right-hand corner.

2)	Select the "Help" drop down menu.

3)	Select "Get Access"

4)	Click "Register and Log in to ECHO Gov"

5)	Follow Registration steps. The registration form will ask users to provide an EPA point of contact. (See contact
information below.)

Helpful Resources

FedCenter

FedCenter.gov is the federal government's home for comprehensive environmental stewardship and compliance
assistance information for federal facility managers and their agencies. FedCenter can be found at: www.fedcenter.gov,
and is a collaboration of the U.S. EPA, U.S. Corps of Engineers, and numerous other federal agencies.

>	Compliance - Clean Air Act

>	Facility Regulatory Tour

>	Air Emission Sources

>	Information About Your Facility

EPA Websites

For more information on a variety of CAA requirements and resources, visit:

>	CCAC NECI website	> Aerospace Sector Regulatory Information

>	CAA and Federal Facilities	> NESHAP Compliance Monitoring

>	Controlling Air Pollution from Stationary Engines	> Air Pollutant Report Help

If you have any questions please reach out to Nikki Freyre (Frevre.Dominigue@epa.gov, 202-564-0433) or Chelsea Dixon
(Dixon.Chelsea@epa.gov, 202-564-2592), at the U.S. EPA Federal Facilities Enforcement Office (FFEO) in the Office of
Enforcement and Compliance Assurance.

Disclaimer

This Compliance Advisory addresses select provisions of EPA regulatory requirements using plain language. Nothing in this Compliance Advisory is
meant to replace or revise any EPA regulatory provision, any other part of the Code of Federal Regulations, the Federal Register, or the Clean Air Act.

Compliance Advisory

Page 2


-------