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:

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

Good faith efforts to comply (documented environmental management system)
Voluntary disclosure before inspection (can reduce penalty 75-100%)
History of compliance (no prior violations in 5 years)
Ability to pay (financial hardship documentation)
Environmental justice impact (proximity to disadvantaged communities increases scrutiny)
Cooperation during investigation
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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