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Resource Conservation and Recovery Act (RCRA) Audit for Storage and Distribution Terminal

aerialstoragetanksW&M recently was tasked to review a client’s storage and distribution terminal facility operations and provided them with assurance of regulatory compliance under the Resource Conservation and Recovery Act (RCRA) and Clean Water Act (CWA).  W&M successfully conducted an environmental compliance audit to determine regulatory applicability and potential compliance gaps with state and federal environmental regulations.  The audit was conducted under the Texas Environmental, Health, and Safety Audit Privilege Act.  The results of the audit also provided suggestions for future management practices aimed to help them save time and money.

Areas covered in the audit included:

  • Client’s Wastewater Permit and Wastewater Treatment Plant operations;
  • Storm water discharge permitting and an existing Storm Water Pollution Prevention Plan (SWP3) were reviewed;
  • RCRA compliance including waste classification and waste handling practices;
  • The client’s Industrial and Hazardous Waste Notice of Registration (NOR) was evaluated for potential gaps, discrepancies, and completeness for waste codes and management units. Identified waste codes for removal, reduction, or clarification; and
  • Client’s existing Spill Prevention, Control and Countermeasure (SPCC) plan, including site oil storage and handling procedures, were reviewed to identify potential gaps with 40 Code of Federal Regulations (CFR) §112 regulations.

For more information about this project or to explore ways W&M can help you with your companies compliance needs, please contact Heather Woodward.

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