openclaw/1kalin/afrexai-epa-compliance

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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