Environmental Compliance Manager

Assess, track, and maintain environmental regulatory compliance across EPA, state agencies, and industry-specific requirements. Built for manufacturing, construction, energy, logistics, and any business with environmental obligations.

What It Does

When given facility details, operations type, or specific environmental concerns, this skill:

1. Regulatory Mapping — Identifies which EPA programs apply (Clean Air Act, Clean Water Act, RCRA, CERCLA, EPCRA, TSCA) plus state-level requirements
2. Permit Tracking — Catalogs required permits (air emissions, stormwater NPDES, hazardous waste generator, SPCC plans) with renewal dates and compliance deadlines
3. Inspection Readiness — Generates pre-inspection checklists based on facility type, common citation areas, and recent enforcement trends
4. Reporting Calendar — Maps all mandatory reporting deadlines: TRI Form R, Tier II, DMRs, biennial hazardous waste reports, GHG reporting, air emissions inventories
5. Violation Risk Assessment — Scores current compliance posture against common violation categories with estimated penalty exposure
6. Corrective Action Plans — Generates remediation steps for identified gaps with priority ranking by penalty risk

Regulatory Coverage

Federal Programs

Program	Statute	Key Requirements	Penalty Range
Clean Air Act (CAA)	42 USC §7401	Title V permits, NESHAP, NSPS, PSD/NSR	$25,000-$75,000/day
Clean Water Act (CWA)	33 USC §1251	NPDES permits, stormwater, pretreatment	$25,000-$64,618/day
RCRA	42 USC §6901	Hazardous waste ID, storage, disposal, manifests	$37,500-$70,117/day
CERCLA (Superfund)	42 USC §9601	Reporting, cleanup liability, cost recovery	Strict liability, no cap
EPCRA	42 USC §11001	TRI reporting, Tier II, emergency planning	$25,000-$75,000/violation
TSCA	15 USC §2601	Chemical inventory, new chemical review, PFAS	$25,000-$50,000/day

State Programs

• Delegated authority states (most EPA programs)
• State-specific: California (CEQA, Prop 65, CARB), Texas (TCEQ), New York (DEC), Florida (DEP)
• Multi-state operations: identify overlapping requirements

Facility Classification Matrix

By Generator Status (RCRA)

Category	Quantity	Requirements
Very Small (VSQG)	<220 lbs/month	Basic labeling, no time limit, no manifest
Small (SQG)	220-2,200 lbs/month	270-day storage, manifests, contingency plan
Large (LQG)	>2,200 lbs/month	90-day storage, full contingency, biennial report

By Emissions Source (CAA)

Category	Threshold	Requirements
Minor Source	Below major thresholds	State permit, basic recordkeeping
Synthetic Minor	Accepted limits below major	Federally enforceable limits, monitoring
Major Source	>100 tpy any HAP, >10/25 HAP	Title V permit, MACT/NESHAP, annual compliance cert

Inspection Readiness Checklist

Universal (All Facilities)

• Environmental policy posted and current
• Permits displayed/accessible (air, water, waste)
• Training records for environmental staff (within 12 months)
• Spill prevention plan current and reviewed annually
• Emergency contact list posted at all chemical storage areas
• Container labeling correct (contents, hazard, accumulation start date)
• Secondary containment intact, no cracks or standing liquid
• Storm drains labeled "No Dumping — Drains to [water body]"
• Waste manifests filed and accessible (3-year minimum, 5-year recommended)
• Air monitoring/emissions records current

Hazardous Waste Specific

• EPA ID number current and posted
• Satellite accumulation areas compliant (<55 gal/1 quart acutely hazardous)
• Weekly inspections of storage areas documented
• Contingency plan updated within last year
• Land disposal restriction notifications on file
• Used oil storage clearly labeled, no mixing with hazardous waste

Stormwater Specific

• SWPPP current and on-site
• Quarterly visual inspections documented
• Benchmark monitoring results within limits
• BMPs maintained (silt fences, drain covers, berms)
• No Exposure Certification current (if applicable)

Reporting Calendar Template

Report	Frequency	Deadline	Agency	Applies If
TRI Form R	Annual	July 1	EPA	>10 employees + threshold chemicals
Tier II	Annual	March 1	SERC/LEPC	Any OSHA threshold chemical on-site
Biennial Hazardous Waste	Every 2 years	March 1 (even years)	EPA/State	LQG status
Title V Compliance Cert	Annual	Per permit	State	Major source
DMR (Discharge Monitoring)	Monthly/Quarterly	Per permit	EPA/State	NPDES permit holder
GHG Reporting	Annual	March 31	EPA	>25,000 MT CO2e/year
Air Emissions Inventory	Annual/Biennial	Per state	State	Air permit holders
SPCC Plan Review	Every 5 years	Rolling	EPA	>1,320 gal aboveground or >42,000 gal underground oil

Violation Risk Scoring

Rate each area 1-5 (1=fully compliant, 5=critical gap):

Category	Weight	Score	Weighted
Permit currency	20%	_	_
Waste management	20%	_	_
Reporting timeliness	15%	_	_
Recordkeeping	15%	_	_
Training	10%	_	_
Spill prevention	10%	_	_
Air emissions	10%	_	_
Total	100%		_/5.0

Risk Tiers:

• 1.0-2.0: Low risk — maintain current program
• 2.1-3.0: Moderate — address gaps within 90 days
• 3.1-4.0: High — immediate corrective action, consider voluntary disclosure
• 4.1-5.0: Critical — retain environmental counsel, self-audit before next inspection

Penalty Mitigation Factors

EPA considers these when calculating fines:

1. Good faith efforts to comply (documented environmental management system)
2. Voluntary disclosure before inspection (can reduce penalty 75-100%)
3. History of compliance (no prior violations in 5 years)
4. Ability to pay (financial hardship documentation)
5. Environmental justice impact (proximity to disadvantaged communities increases scrutiny)
6. Cooperation during investigation
7. Supplemental Environmental Projects (SEPs) — can offset 50-80% of penalty

Usage

Provide:

• Facility type and location (state matters for delegated programs)
• Operations description (manufacturing processes, chemicals used, waste generated)
• Current permits and their expiration dates
• Last inspection date and any outstanding violations
• Number of employees and annual revenue (for penalty context)

The skill maps your regulatory universe, scores your compliance posture, and generates a prioritized action plan with deadlines.

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