U.S. EPA programs
EPA Compliance Consulting
Six core federal environmental programs — the Clean Air Act, Clean Water Act, RCRA, CERCLA, TSCA, and EPCRA — shape most environmental compliance work in the United States. Citadel EHS supports clients across all of them.
Federal EPA programs we cover
Most environmental compliance challenges involve more than one program. Tier II under EPCRA references HazCom chemicals from OSHA; CWA stormwater permits reference RCRA waste streams; PSM and RMP run in parallel for the same covered processes. Our consultants navigate the cross-references.
Clean Air Act (CAA)
Federal air pollution control framework. Sets NAAQS, requires permits for major and minor sources, and authorizes the NESHAP/MACT program for hazardous air pollutants.
- Title V Operating Permits for major sources
- New Source Review (NSR) including PSD and Nonattainment NSR
- NESHAP / MACT standards for hazardous air pollutants
- GHG Reporting Program under 40 CFR Part 98 (Subparts A through PP)
- Risk Management Program (RMP) under §112(r) for facilities with threshold quantities
- Compliance Assurance Monitoring (CAM) plans for major sources
Clean Water Act (CWA)
Federal framework for water quality, point-source discharges, oil spill prevention, and wetlands. Implemented through NPDES (mostly state-delegated) and Section 404 (Army Corps).
- NPDES permits — industrial, construction (CGP), and municipal stormwater (MS4)
- Spill Prevention, Control, and Countermeasure (SPCC) plans under 40 CFR 112
- Facility Response Plans (FRP) for substantial-harm facilities
- Pretreatment program compliance for industrial users
- Section 404 wetlands permitting via the U.S. Army Corps of Engineers
- Multi-sector general permits (MSGP) for industrial stormwater in federal-program states
RCRA (Hazardous Waste)
Federal hazardous waste management law. Defines generator status, regulates treatment, storage, and disposal facilities (TSDFs), and authorizes Corrective Action.
- Generator status determinations (VSQG / SQG / LQG)
- Hazardous waste characterization, manifesting, and recordkeeping
- Land Disposal Restrictions (LDR) and treatment standards
- Permit-by-rule, interim status, and Part B permitting for TSDFs
- Contingency planning and emergency procedures
- RCRA Corrective Action (Subpart S) for active and closed facilities
- Universal waste, used oil, and electronic waste programs
CERCLA / Superfund
Federal law governing cleanup of contaminated sites. Established the Superfund program, the National Priorities List (NPL), and PRP liability.
- Phase I Environmental Site Assessments to ASTM E1527-21
- Phase II ESAs and subsurface investigations
- All Appropriate Inquiries (AAI) under 40 CFR 312
- Brownfield revitalization and bona fide prospective purchaser (BFPP) protections
- PRP defense and cost allocation
- Remedial Investigation / Feasibility Study (RI/FS) coordination
- Vapor intrusion assessment and mitigation
TSCA (Toxic Substances Control Act)
Federal law regulating manufacture, import, and use of industrial chemicals. Significantly expanded under the 2016 Lautenberg amendments.
- Premanufacture Notice (PMN) and Significant New Use Rule (SNUR) compliance
- Chemical Data Reporting (CDR) every four years
- PCB management under 40 CFR 761
- Asbestos management in TSCA Title II (AHERA, ASHARA)
- Lead-based paint Renovation, Repair and Painting (RRP) under TSCA Title IV
- TSCA Section 8 reporting (PFAS reporting rule and related rulemaking)
EPCRA / SARA Title III
Emergency Planning and Community Right-to-Know Act. Drives Tier II reporting, Toxic Release Inventory (TRI), and emergency planning at facilities with hazardous chemicals.
- Tier II reports (annual chemical inventory) to State Emergency Response Commissions
- Toxic Release Inventory (TRI / Form R / Form A) annual reporting
- Section 302/303 emergency planning for Extremely Hazardous Substances (EHS&S) thresholds
- Section 304 release notifications
- Section 313 PFAS reporting expansion
- Coordination with Local Emergency Planning Committees (LEPCs)
EPA-focused services we provide
EPA compliance FAQs
Is my facility subject to EPA Tier II reporting?
Tier II reporting is required for any facility that has any extremely hazardous substance (EHS&S) at or above its threshold planning quantity (TPQ), or any hazardous chemical (under OSHA HazCom) above 10,000 pounds at any time during the reporting year. Many manufacturers, water treatment plants, hospitals, and data centers (diesel fuel for backup generators) trigger Tier II obligations. We run a screening analysis and prepare and file your Tier II report.
Do I need a Phase I ESA before buying commercial real estate?
If you want to qualify for CERCLA's bona fide prospective purchaser (BFPP) liability protection, yes — All Appropriate Inquiries must be completed before acquisition, which in practice means a Phase I ESA conducted to ASTM E1527-21 by a qualified environmental professional. Lenders often require it regardless. We conduct Phase I ESAs nationwide.
What's the difference between RCRA generator categories?
EPA defines three generator categories based on monthly hazardous waste generation: Very Small Quantity Generators (VSQG, ≤100 kg/month), Small Quantity Generators (SQG, 100–1,000 kg/month), and Large Quantity Generators (LQG, >1,000 kg/month, or ≥1 kg/month of acute hazardous waste). Each category has different storage time limits, manifesting requirements, and contingency planning obligations. Episodic events (one-time exceedances) have a separate pathway under the 2016 Generator Improvements Rule.
How do I report PFAS under TSCA Section 8(a)(7)?
EPA's PFAS reporting rule (40 CFR 705) requires manufacturers and importers of PFAS or PFAS-containing articles (going back to 2011) to report use and exposure information by the rule's submission window. This is significantly broader than typical TSCA reporting — it captures articles, byproducts, and impurities. We help identify reportable PFAS, gather records back to 2011, and submit through EPA's Central Data Exchange (CDX).
Does EPA enforce in state-delegated programs?
EPA delegates most major programs (NPDES, RCRA, hazardous waste) to authorized states, but retains federal enforcement authority and routinely conducts joint inspections or steps in when states don't act. For facilities in state-delegated programs, you typically deal with the state regulator day-to-day, but EPA can — and does — bring federal enforcement actions. We track both layers.
Related federal regulations
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From permitting to enforcement response, our consultants support federal environmental compliance across all U.S. operations.