Environmental Compliance Review

Total kilograms generated month-by-month over the trailing 12 months determines VSQG / SQG / LQG status. Sites that drift from SQG to LQG (1,000 kg/mo) inherit contingency planning, biennial reporting, and weekly inspection requirements they often miss for a quarter or more.

Walk every SAA at the point of generation. Containers must be closed except when adding waste, marked with the words "Hazardous Waste" plus contents, and capped at 55 gallons (or 1 quart for acute hazardous waste) before the 3-day move-out clock starts.

Every drum in the central accumulation area carries a visible accumulation start date. LQGs have 90 days; SQGs have 180 (or 270 if shipping over 200 miles). Anything past the limit triggers TSD-level permitting requirements retroactively.

Pull the quarter's manifests from EPA's e-Manifest system and confirm each has a signed TSDF copy back within 35 days. Missing returns trigger an exception report obligation.

Export all permit deviations and excess emission events for the quarter. Title V semiannual monitoring reports are due within 30 days of the reporting period close — late filings are routine NOV territory.

Continuous Emission Monitoring Systems require daily calibration drift checks and quarterly cylinder gas audits. 40 CFR Part 75 expects 95% valid data; gaps below that obligate substitution data and explanation in the report.

Roll up the rolling 12-month total for VOC, single HAP, and aggregate HAP. Compare to the synthetic minor or major source thresholds in the Title V permit. Note any cap that's at or above 80% of the limit so the next quarter's planning accounts for it.

Pull the CMMS history for every control device tied to a permit condition. A skipped PM on a baghouse is the most common root cause for a particulate exceedance — the deviation gets blamed on the device, but the gap is in the maintenance program.

The Multi-Sector General Permit requires quarterly visual assessments and benchmark monitoring at each outfall. Sampling must happen within the first 30 minutes of a measurable storm event after at least 72 hours of dry weather.

Pull the quarter's lab reports and run them against daily max, monthly average, and weekly average limits in the NPDES permit. NetDMR submissions are due by the 28th of the month following the monitoring period.

40 CFR 112 requires monthly visual inspection of every aboveground oil container ≥55 gallons and the containment around it. Look for cracks in the dike, drain valve position (closed and locked), and rainwater accumulation that needs documented release.

If you discharge to a POTW under a categorical pretreatment standard or local industrial user permit, confirm sampling frequency, parameters, and the semiannual self-monitoring report match the IU permit conditions.

Pull the receiving log of new chemicals added in the quarter and verify each has a current SDS in the binder or HazCom system. New solvent introductions without an SDS update is a frequent OSHA HazCom finding.

Hazardous chemicals stored at or above 10,000 lb (or 500 lb / TPQ for Extremely Hazardous Substances) at any point in the calendar year trigger Tier II. The annual report is due March 1 to the SERC, LEPC, and local fire department.

SIC/NAICS-covered facilities with 10+ FTEs that manufacture or process 25,000 lb or otherwise use 10,000 lb of a listed toxic chemical must file Form R by July 1. PFAS additions and lower thresholds for chemicals of special concern catch sites that have filed for years.

Walk the floor and check every secondary container — squeeze bottles, decanted solvents, parts-washer reservoirs. Each needs product identifier and GHS pictograms or words conveying the same hazard information per 1910.1200(f)(6).

Compare quarterly KPI actuals (energy intensity, waste-to-landfill diversion, water use per unit produced) against the targets set in the management review. Drift of 10% or more should already have a corrective action open.

Open NCRs from the prior ISO 14001 surveillance or internal audit need a verified effectiveness check before closure — a single corrected record is not enough; sustained conformance over the next audit cycle is the bar.

Bundle Title V semiannual, NetDMR, RCRA exception reports, and any state-specific air or water reports. Keep the submission confirmations attached for the document control file.

Roll up upcoming expirations for RCRA, HazCom, DOT hazmat, and SPCC training. Schedule sessions before expirations rather than after — DOT 49 CFR 172.704 has zero grace period for hazmat employees.