Compare Facility Operations Against Permit Limits

---
name: compare-facility-operations-against-permit-limits
task_id: environmental-esg/compare-facility-operations-against-permit-limits
description: Guides compliance gap analysis of facility operations against permit limits by organizing findings by regulated medium using actual monitoring data and records rather than characterizing compliance at a general level.
activates_for: [planner, solver, checker]
---

# Skill: Compare Facility Operations against Permit Limits — Compliance Gap Analysis Memorandum

## 2. Failure modes the skill is correcting

- Treats compliance as a general status label instead of comparing each actual measurement, log entry, and operating record against the specific permit term that governs it
- Misses operating changes, start-ups, shutdowns, throughput shifts, equipment swaps, or bypass events that can trigger new permit obligations or prior-approval requirements
- Analyzes air, water, waste, and other regulated media in isolation and misses cross-media effects from the same operational event or control choice
- Ignores agency letters, notices, schedules, or response commitments that can add duties beyond the baseline permit text
- Summarizes gaps without tying each one to the governing limit, the supporting source record, and the operational or enforcement consequence
- Uses vague risk language without a uniform severity scale or a clear reason for the rating
- States legal conclusions without identifying the controlling permit term, regulation, or other authority supporting the conclusion

## 3. Legal frameworks / domain conventions that apply

- Air permits: emission limits, operating limits, monitoring, recordkeeping, deviation reporting, and permit modification or applicability review requirements
- Water discharge permits: effluent limits by outfall or discharge point, monitoring and sampling requirements, stormwater terms, mixing assumptions where applicable, and reporting obligations
- Hazardous waste rules: generator category, accumulation time, labeling, inspections, manifesting, and land disposal or storage-related record obligations
- Leak detection, fugitive emissions, and repair programs: inspection cadence, response deadlines, documentation, and re-monitoring requirements under the applicable air rules
- Oil storage and spill prevention controls: inspection, secondary containment, amendment, and response obligations where the facility has qualifying storage
- Agency correspondence and enforcement instruments: notices of violation, warning letters, compliance orders, stipulated schedules, and response deadlines may create independent obligations
- Apply the governing permit language first, then the referenced regulation, then any agency correspondence that modifies or supplements the baseline duty

## 4. Analytical scaffolds

- Start by inventorying every regulated medium and every governing source document, then separate the analysis by medium so each limit is tested against the correct record set
- For each medium, identify: the governing permit condition or rule, the specific parameter or operational duty, the actual data or log entry, the comparison result, and the downstream compliance effect
- Use a uniform severity scale defined once at the top of the memorandum, such as Critical / High / Medium / Low, and apply it consistently to each gap
- For each identified issue, close the analysis in three moves: state the scale of the deviation using the source record; cross-reference any interacting permit term, schedule, or other document; and explain the legal, operational, or enforcement consequence
- Where more than one discharge point, emissions unit, waste stream, sampling period, or operating scenario exists, enumerate them before analysis and address each one separately rather than using a representative sample
- Test whether changes in production, equipment, process chemistry, control settings, or waste routing altered permit applicability, triggered notification duties, or changed the compliance baseline
- For air issues, compare the actual operating record against emission, monitoring, and maintenance obligations; check whether deviations were reported as required; and assess whether a process change required prior approval
- For water issues, compare each monitoring result to the applicable limit or benchmark by parameter and location; assess sample timing, missing data, and reporting completeness; and note any notice history
- For waste issues, verify the generator category against actual generation quantities and accumulation practices; check manifests, labeling, inspection logs, and shipment timing
- For correspondence and enforcement items, extract each affirmative obligation, deadline, response requirement, or corrective action commitment and test current status against that duty
- Assess penalty and enforcement exposure by reference to duration, magnitude, recurrence, and compliance history, not by fixed conclusions detached from the records
- Cite the controlling permit term, regulation, or agency directive for each legal proposition relied on; do not state a compliance conclusion without naming the authority that supports it

## 5. Vertical / structural / temporal relationships

- Track the same operational event across media: a process upset, control malfunction, or routing change may create air, water, and waste implications at once
- Treat modifications over the permit term as time-sensitive: an apparently compliant later condition does not cure an earlier violation unless the governing authority expressly allows it
- Use compliance history as a severity amplifier where the documents show repeated deviations, late responses, or unresolved corrective actions
- If the record reflects only one facility, one permit, one discharge point, or one monitoring period in scope, state that expressly before analysis and do not invent additional categories

## 6. Output structure conventions

- Draft a compliance gap analysis memorandum organized by medium with a short executive summary up front
- Define the severity scale once, then present a medium-by-medium issue table with columns for source duty, actual record, gap description, severity, and consequence
- Follow each table with a concise narrative analysis that identifies the controlling authority, the operative facts, and the recommended corrective path
- Include a consolidated closing section that groups the highest-risk gaps and distinguishes immediate remediation from longer-horizon compliance fixes
- End with an explicit Recommended Actions section that uses imperative verbs, names the responsible role drawn from the source materials where available, and ties each action to a deadline or urgency anchor from the record or regulatory schedule
- Keep the memo oriented to the requested deliverable format and avoid generic compliance commentary that does not map to a specific permit term or facility record