Large Manufacturing Corporation Compliance Audit

Summary

Nova conducted a multimedia environmental compliance audit of a manufacturing company consisting of six facilities. The compliance audit was requested by a potential buyer to evaluate environmental liabilities prior to acquisition.

Nova’s scope included the following:

1. Review of regulatory agency databases to assess permit status and compliance history.

2. Facility inspection and personnel interviews to assess operations and determine applicable compliance requirements.

3. Review of current compliance management and documentation practices.

4. Identification of compliance gaps.

Solution

The audit resulted in the following recommendations:

• Prepare a comprehensive tool to track air emissions and air permit triggers during planned expansions.

• Acquire a stormwater permit and develop a stormwater pollution prevention plan (SWPPP).

• Cease improper management and disposal of hazardous and universal wastes.

• Implement a proactive used oil management process to avoid triggering of SPCC requirements.

• Initiate EPCRA Tier II reporting.

Based on the findings, the buyer was able to implement practices to significantly reduce environmental liabilities, properly manage existing requirements, and proactively manage new requirements as planned expansions were implemented.

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