EPA Regulations Compliance Checklist

Pull the engine family number and model-year label from each tractor and confirm it meets the applicable EPA HD On-Highway standard (2007, 2010, or GHG Phase 2). Flag any unit where the DPF, DEF system, or EGR has been tampered with — defeat devices are a separate Clean Air Act violation with five-figure-per-unit penalties.

Park the unit until the OEM aftertreatment is restored — DPF reinstalled, DEF dosing operational, EGR re-enabled, and CEL cleared. Document the repair work order and tech signoff; aftertreatment delete history follows the VIN.

For units operating in CA, NY, NJ, and other PSIP states, confirm current opacity test certificates are on file. Snap-acceleration test results above 40% (pre-1991) or 20% (1991+) require corrective action before the unit can run.

Confirm all bulk and retail diesel purchases meet the 15 ppm ULSD standard. If the carrier blends biodiesel above B5, verify the supplier is an EPA-registered renewable fuel producer and that BOLs reference the RFS RIN. Keep PTDs (product transfer documents) for two years.

Add the shell capacity of every container ≥55 gallons at the yard — bulk diesel, used-oil tanks, hydraulic fluid, DEF (DEF is exempt but document it), and aboveground portable totes. SPCC applies at 1,320 gallons aggregate or any single buried container >42,000 gallons.

Tier I qualified facilities: ≤10,000 gal aggregate and no single container >5,000 gal with no recent discharge history — self-certify. Tier II qualified: ≤10,000 gal aggregate, single containers up to 5,000 gal — self-certify with extended template. Anything above requires a PE-stamped plan.

Walk through every section of the plan: facility diagram, container inventory, secondary containment, transfer procedures, inspection schedules, and personnel training. Technical amendments are required within six months of a change in tank, piping, or operation; a full review is required every five years.

A licensed professional engineer must visit the yard, review containment, and stamp the plan. Budget 4–6 weeks lead time; PEs familiar with motor carrier facilities are limited in some regions.

Walk every bulk tank, used-oil tank, and fueling island. Containment must hold 110% of the largest tank, no cracks, no standing rainwater with sheen, drain valves locked closed. Document with date-stamped photos.

Train fuelers, shop techs, and yard staff on discharge procedures, the location of spill kits, and NRC notification (1-800-424-8802) for reportable quantities. Record attendance with names, dates, and signatures — 40 CFR 112.7(f) requires documentation.

Any shop tech servicing tractor or reefer MVAC systems needs Section 609 certification (MACS, ESCO, or equivalent). Pull current cards for every tech and confirm the shop has at least one Section 608 Type II tech for stationary refrigeration if the yard has walk-in coolers.

Reconcile R-134a, R-1234yf, and R-404A invoices against work orders. EPA requires three years of refrigerant purchase records. Watch for transition: reefer units built after model-year 2025 cannot use R-404A under the AIM Act phasedown.

Each recovery / recycling machine must be EPA-approved per SAE J2788, J2843, or J3030 depending on refrigerant. Tag and remove any non-compliant machines; venting refrigerant from a non-approved unit is the most common Section 609 violation.

Run the quarterly idle report out of Samsara, Motive, or Geotab. Flag drivers above the 25% idle threshold and any sleeper-berth idling in CA, MA, NJ, or other 5-minute-limit states. Save the report for the safety file.

CA CARB ATCM limits diesel truck idling to 5 minutes statewide. NJ, NY, MA, and the Port of NY/NJ have their own thresholds. Update the driver handbook page that lists per-state idle limits when lanes change.

Driver managers run one-on-ones with anyone over the 25% idle threshold. Cover APU use, bunk heater operation, and shore-power locations on regular lanes. Document the coaching in the driver file.

APUs, bunk heaters (Espar / Webasto), and battery HVAC systems pay back within 18–24 months at current fuel prices and reduce CSA exposure in idle-restricted jurisdictions. Confirm any APU added is CARB-verified if the unit will operate in California.

Sum monthly hazardous waste generation: parts washer solvent, contaminated absorbents, antifreeze, brake cleaner, paint waste. VSQG ≤100 kg/month, SQG 100–1,000 kg/month, LQG >1,000 kg/month. Status drives storage time limits and manifest requirements.

SQGs and LQGs need an EPA ID per site. Confirm the ID on file with the state environmental agency matches the EIN, address, and contact on the most recent manifest. Re-notify via Form 8700-12 within 30 days of any change.

LQGs file Form 8700-13 A/B by March 1 of even-numbered years for the prior odd year's waste. Use the state's RCRAInfo portal. Late filings draw a Notice of Violation and a base penalty of $1,500+ per occurrence.

Pull six months of pickup manifests from Safety-Kleen, Heritage-Crystal Clean, or your local hauler. Tanks must be labeled "Used Oil" per 40 CFR 279, kept closed except during transfer, and stored in containment. Mixing used oil with chlorinated solvent reclassifies the entire tank as hazardous waste.

Scrap tires and lead-acid batteries are universal waste in most states with their own manifest tracking. Confirm the hauler is a registered scrap-tire transporter and that battery cores have been logged for the core-charge refund.

Truck terminals fall under SIC 4212/4213 — covered by the EPA Multi-Sector General Permit (Sector P) or the equivalent state permit. Pull the current NOI confirmation; the 2021 MSGP renewed in 2026 so re-NOI may be needed depending on issue date.

If all fueling, maintenance, washing, and waste storage are under permanent roof, the facility may qualify for No Exposure Certification under 40 CFR 122.26(g). Walk the site with the checklist; outdoor parts washing or open used-oil tanks disqualifies.

File the Notice of Intent through EPA's NeT-MSGP portal (or the state portal if authorized). Authorization is effective 30 days after submission unless the agency objects. Save the NOI confirmation number.

The Stormwater Pollution Prevention Plan needs a site map showing outfalls, fueling, maintenance, and waste areas; pollutant sources; BMPs; and the response team. Re-stamp any time fueling, parking, or wash-bay locations change.

Sector P requires quarterly visual assessment of stormwater at each outfall during a qualifying storm event and benchmark sampling for TSS and other pollutants. Lab results above the benchmark trigger a Tier 1 / Tier 2 corrective action review.

Investigate the source of the exceedance, install additional BMPs (oil-water separator, covered fueling, improved housekeeping), document in the SWPPP, and resample. Tier 2 requires the corrective action to be implemented within 45 days of the result.

Manifests, SPCC plan, SWPPP, sampling results, refrigerant logs, and training rosters live in one binder (paper or digital). Five years minimum retention; PE-stamped SPCC and prior MSGP NOIs are kept for the life of the facility.