2023 End of the Year Environmental Checklist

The end of 2023 is almost here, and it is time to check in on all your environmental programs. We at Trinity Consultants understand that the end of the calendar year can be stressful and bring a lot of last-minute environmental compliance issues to your attention. Similarly, it can be very easy to get lost in the Holiday shuffle and not know where to start for 2024. Luckily for you, Trinity Consultants is here to help. We have compiled the following checklist to help get you acclimated for closing out 2023 and diving into 2024 organized and confident!

Air Quality Compliance & Air Permits

1. Are air permit tracking records up-to-date and filed for easy access? Easily accessible and complete files help inspections go smoothly. Additionally, air permit records will be key inputs for calendar year 2023 reports due in early 2024.
2. Are records accurate and does the equipment list in the permit match the equipment installed? Inspections often find installed equipment not covered by permits, which can lead to a notice of violation. It helps to have labels with the emission unit IDs or emission point IDs as they appear in the permit on the associated units or stacks.
3. Will permitting be required for any new sources or modifications to existing sources in 2024? If yes, it is time to start planning the permitting process, especially if you expect that air dispersion modeling may be required.
4. Have new construction permits or construction permit modifications been incorporated into the operating permit? It is a recommended to proactively update your operating permits as changes to your facility happen.
5. Is the deadline to renew your operating permit in 2024? If so, it is time to start planning the renewal process.
6. Do you have an air emissions inventory due next year and/or a change in Responsible Official since your last report? It is time to have the new Responsible Official set up in your state’s emissions inventory system and delegate preparation authority to avoid delays during reporting season. New preparers should setup their accounts too.

Ozone Depleting Substances (ODS)

1. Are your leak-rate calculations updated, and have any follow-up verification tests properly documented? If leak reporting is required, the deadline is March 1.
2. Do you have the current license information for your refrigerant technicians? Now is a good time to confirm the technicians maintained their license and completed the required training.

Risk Management Programs (RMP)

1. Is the contact information correct in the filed RMP? Ensure you have the current and active Points of Contact (POCs) listed in the RMP.
2. Have you coordinated emergency response activities for the covered chemicals with your local responders?
3. Do I need to plan for any Process Hazard Analyses, Compliance Audits, or RMP renewals that are due in 2024? These can often be overlooked and pop-up at the wrong time when environmental personnel may have other priorities.
4. Do I need to update the RMP for a change that requires a revised Process Hazard Analysis (PHA) or hazard review?
5. Any significant maintenance/mechanical integrity inspections that you need to plan for in 2024? These can be time consuming, so it is necessary to ensure adequate planning and scheduling ahead of time.

Stormwater Pollution Prevention Plan (SWPPP)

1. Has an annual review of the SWPPP been completed to ensure information is correct? Periodically review the plan to ensure its accuracy to avoid data gaps or incorrect information.
2. Have any SWPPP contacts changed, and if so, has the plan been updated? Ensure that you have the current and active POCs listed in the plan.
3. Have SWPPP best management practices been completed and documented? It is recommended to create an internal tracking tool for managing BMPs and their completion.
4. If sampling is required by the permit, has it been completed? It is important to ensure that any sampling meets all applicable benchmarks or effluent limits. Additionally, review if your facility had any corrective action (i.e., AIM) triggering events.
5. Have all routine inspections and visual assessments been completed? Take a moment to confirm the inspection files (electronic or hard copy) are complete. Ensure that inspection records are easily accessible and include all information required by the SWPPP.
6. Has annual training been completed? Confirm documentation of training is filed and readily accessible.
7. When does the facility’s stormwater permit expire? Do you need to start planning for the permit renewal?
8. Are any construction projects planned that could trigger the need to obtain a construction stormwater permit (one acre or more of disturbance)? Confirm plans are in place to obtain the required permit.

National Pollutant Discharge Elimination System (NPDES) – Wastewater

1. When does the facility’s wastewater permit(s) expire? It may be time to start planning for the permit renewal. Be sure to review any direct discharge NPDES permits and indirect discharge permits (i.e., POTW permits).
2. If sampling is required by the permit, has it been completed? Ensure that the sampling results do not exceed any applicable effluent limits, review any potential noncompliance issues that triggered any exceedances, and double check your facility flowmeter(s), as they may require calibration.
3. Were all discharge monitoring reports (DMRs) or other required reports submitted?
4. Have all certified operators maintained their license and training requirements?
5. Has an annual review of the Slug Control Plan been completed to ensure information is up to date?

Spill Prevention Control and Countermeasure (SPCC) Plan

1. Has the annual discharge prevention briefing been completed? Be sure to include documentation of the training event in your internal records.
2. Have the inspections required by the SPCC Plan been completed? Standard STI–SP001 requires an annual visual inspection in addition to the monthly visual inspections for aboveground storage vessels indicated as following the standard in the SPCC plan. Ensure that all formal integrity inspections have been completed. Inspection records must be maintained and readily available at the frequency specified at the frequency specified in the SPCC plan.
3. Have secondary containment dike drainage records been maintained and accurately completed?
4. Have there been changes to the facility that require technical or non-technical amendments to the SPCC Plan? If your facility has a 5-year review coming up, it is time to start planning the review process.

Facility Response Plan (FRP)

1. Have the required PREP drills been completed? Ensure they have been completed and maintain an internal log documenting their completion.
2. Has annual response training been completed? This is easy to overlook. Be sure to maintain an internal log documenting that the training has been completed.
3. Have you reviewed EPA’s Area Contingency Plan and the National Oil and Hazardous Substances Pollution Contingency Plan to ensure no updates are needed to ensure consistency with these national plans?

Resource Conservation and Recovery Act (RCRA) – Hazardous Waste

1. Are you on top of keeping your Waste Manifests organized? Ensure that the manifests are legible, easy to read, and in a centralized location that they are easy to access. Also, ensure that the waste codes listed are accurate and accurately represent the waste at your facility. In addition, signed land disposal restriction (LDR) forms shall be attached to hazardous waste manifests.
2. Are actual waste quantities in line with your waste generator status (VSQG, SQG, LQG)? It is imperative to track actual hazardous waste generation on a monthly basis to ensure you can justify your generator status.
3. LQGs, do you have the resources in place to effectively complete your Biennial Haz Waste Report due March 1, 2024? You will want to ensure you have a complete and accurate set of waste manifests for 2023 and are familiar with EPA’s RCRAInfo Online Portal.
4. SQGs and VSQGs, does your facility have any episodic generation events planned for early 2024? If so, this can be a useful tool to maintaining your generator status. Be sure to familiarize yourself with the notification process required for these events. Please note, certain states have not adopted this rule yet.
5. Do you have documented waste determinations? Are they up to date? Occasionally, you may need to reconduct analytical sampling on waste streams to provide current justification for your waste determinations.
6. Has all hazardous waste and universal waste been shipped offsite based on the applicable accumulation time limit? Be sure to include airtight hazardous waste labeling on your containers in central accumulation areas denoting the name of waste and start date/time of when the waste began to accumulate, or the date container is filled or removed from the satellite accumulation point.
7. Do employees have the correct training? All employees who sign manifests must have current DOT training. Additionally, employees who handle hazardous waste must have annual RCRA training. Document these training events internally.
8. For SQGs and LQGs, have weekly inspections been completed for the entire calendar year? Any noticeable gaps in these inspections must be noted and handled as soon as possible to avoid noncompliance issues and maintain records of inspection logs. Ensure that the inspection requirements are met for hazardous waste storage tanks and incinerators authorized under your RCRA Permit.
9. Has an annual review of the RCRA Contingency Plan been completed to ensure information is correct? The plan may need to be revised to account for new waste streams, changes to SAAs and CAAs, facility emergency contacts etc. Furthermore, the revised plan may need to be resubmitted to local emergency response agencies.

Toxic Substance Control Act (TSCA)

1. Am I ready for the TSCA Chemical Data Report due in 2024? This report is due every four years, so start planning now if your facility’s report is due in 2024.

If you have any questions about the above checklist, please reach out to one of our local experts at your nearest Trinity office!