Environmental Compliance Checklist

Total monthly hazardous waste generation determines VSQG, SQG, or LQG status, and the rules differ at each tier (accumulation limits, training, biennial reporting). Pull the last 12 months of manifests from the e-Manifest system and confirm the tier hasn't drifted.

Walk every SAA on the floor. Containers must be closed except when adding waste, labeled with "Hazardous Waste" and the accumulation start date, and held at the point of generation. The 55-gallon limit per SAA is a common citation — once exceeded, the 3-day clock to move to the central accumulation area starts.

SQG and LQG sites must inspect the 90/180-day accumulation area weekly and document each inspection. Pull the log; missing weeks are an easy citation. Confirm no drum is past its accumulation start date.

Pull all signed manifests from the EPA e-Manifest portal for the period and reconcile against the on-site shipment log. Confirm TSDF return copies received within 35 days of shipment; exceptions trigger an Exception Report to the EPA Regional Administrator.

Check lamp, battery, and electronics accumulation against 40 CFR 273. Used oil containers must be labeled "Used Oil" (not "Waste Oil") and stored in good condition with secondary containment if over threshold.

Review the most recent potential-to-emit calculation for VOC, HAPs, NOx, and PM. A facility approaching major source thresholds (typically 100/10/25 tpy depending on pollutant and area attainment) needs Title V; staying minor requires enforceable production caps.

Pull continuous emissions monitoring data and the most recent stack test for each regulated emission point. Confirm CEMS data availability meets the 95% threshold required by most permits, and that quarterly excess emission reports were submitted on time.

Walk each control device with maintenance. Verify pressure drop, temperature, and runtime against permit parametric monitoring requirements. Bypass dampers must be sealed or interlocked; broken seals are a frequent finding.

Reconcile solvent and coating purchase records against monthly VOC and HAP usage logs maintained for the rolling 12-month total. Permit caps are usually expressed as 12-month rolling — a single high month can break a cap that looks fine in any single audit window.

Title V deviations must be reported in the semiannual monitoring report and, if they qualify as excess emissions, on a faster cycle defined by the permit. Document the deviation, root cause, duration, and corrective action; coordinate with legal counsel before submission.

Pull the latest Discharge Monitoring Report data from NetDMR for each outfall. Compare measured pH, TSS, BOD, oil and grease, and any facility-specific parameters against permit limits. Sampling frequency missed even once is a reportable violation.

Confirm the Stormwater Pollution Prevention Plan reflects current site conditions — outdoor material storage, loading docks, scrap yards. Quarterly visual inspections and annual comprehensive inspections must be documented per the MSGP or state equivalent.

If aggregate aboveground oil storage exceeds 1,320 gallons, the SPCC plan must be PE-certified and reviewed every 5 years. Walk every bulk tank and drum storage area; confirm secondary containment is intact and drain valves are closed and locked.

Coordinate with the contract lab to pull samples per the permit-required analytical suite. Confirm chain of custody and hold times. Results above benchmark trigger corrective action under the MSGP.

If discharging to a publicly owned treatment works, confirm the local pretreatment permit limits for metals, pH, and prohibited discharges. Submit the periodic compliance report on the schedule the POTW requires; missed reports trigger Significant Industrial User violations.

EPCRA Tier II is due March 1; TRI Form R is due July 1. Confirm chemical inventory thresholds (10,000 lb general, 500 lb EHS) and TRI thresholds (25,000 lb manufactured/processed, 10,000 lb otherwise used) against this period's usage.

Walk through any open Notices of Violation, agreed orders, or settlement agreements with environmental counsel. Confirm milestone deadlines are tracked and corrective action effectiveness checks are scheduled before closure.

EHS Manager and Plant Manager sign off jointly. Note any open findings and the assigned owner with target close date. The signed packet goes into the document control system as the period of record for any future agency inspection.

Each out-of-compliance finding gets a corrective action request with named owner, root cause analysis (5-why or fishbone), containment action, and effectiveness verification criteria. CARs closed without effectiveness check tend to recur.

Reportable violations must be disclosed within the timeframe set by the regulation — Title V deviations on the semiannual cycle, NPDES exceedances within 24 hours for some parameters, RCRA spills under the LEPC/SERC framework. Loop in environmental counsel before any agency contact.

Schedule a follow-up audit 30-60 days after corrective action implementation to verify the issue has not recurred. Document the verification result against the closure criteria written into the CAR.