Resource Conservation and Recovery Act (RCRA) Audit Storage and Distribution Terminal
W&M conducted an environmental compliance audit to determine regulatory applicability and potential compliance gaps with state and federal environmental regulations at a storage and distribution terminal facility. The audit was conducted under the Texas Environmental, Health, and Safety Audit Privilege Act. 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;
- Resource Conservation and Recovery Act (RCRA) compliance including waste classification and management;
- 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 code issues 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.
Audit findings were presented to the client in the form of tables listing potential issues and suggested solutions. Findings were also discussed in person and were managed with the Client’s input into the appropriate corrective actions.
W&M was able to review the client’s operations and provide them with the assurance of regulatory compliance. Suggestions for future management practices helped to save the client time and money.