ENVIRONMENTAL AUDITS

Environmental Findings Do Not Announce Themselves.

A multi-media audit across air, water, waste, storage and reporting — with findings ranked by enforcement exposure and a closure plan that accounts for what the fix actually costs.

Book a 20-minute call See what is involved

Air permits & limitsWater stormwater & dischargeWaste RCRA generator statusReporting Tier II & EPCRA
HOW COMPANIES GET SURPRISED

Safety violations get noticed. Environmental ones accumulate quietly.

Generator status drifted upward

Production increased, a new process came online, and monthly hazardous waste generation crossed a threshold nobody was watching. Every obligation attached to the higher tier has been unmet since.

Permit conditions nobody reads

Air permits contain monitoring, recordkeeping and reporting conditions beyond the emission limits themselves. Most violations found in inspections are recordkeeping conditions, not exceedances.

Stormwater plan written once

An industrial stormwater permit requires an updated plan, routine inspections, monitoring and annual reporting. Plans written at permit issuance and never revisited are the norm.

Thresholds crossed without reporting

Tier II and EPCRA obligations trigger on quantities stored or released, and those thresholds are lower than people assume for extremely hazardous substances.

New equipment installed without review

A new coating line, boiler or dust collector can require a permit modification before installation. Construction first, permit later is a common and expensive sequence.

No one owns environmental at all

In most small and mid-sized manufacturers, environmental sits with whoever has capacity. Deadlines are annual, so a gap goes unnoticed for a full year.

WHAT WE DO

We audit across media, then rank by what will actually bite.

We review permits and applicable regulations against what your operation actually does — materials, processes, storage, discharges and emissions — then walk the site. Paper compliance and field compliance diverge quickly, and the divergence is the finding.

The report ranks each item by enforcement likelihood and potential consequence, with a closure plan that separates the things fixable this month from the ones requiring capital or an agency submission.

Scope

  • Permit inventory and condition-by-condition review
  • Hazardous waste generator status determination
  • Storage, labeling, accumulation time and manifesting
  • Stormwater plan, inspections and monitoring
  • Air permit conditions, monitoring and recordkeeping
  • Tier II, EPCRA and TRI applicability
  • SPCC applicability and plan adequacy
  • Ranked findings with a costed closure plan
FAQ

Environmental audit questions

Are audit findings protected?

Some states have environmental audit privilege or immunity statutes with strict conditions, and EPA has a self-disclosure policy that can substantially reduce penalties for violations found, disclosed and corrected promptly. Both require deliberate handling, which is a conversation to have before the audit rather than after.

Should we self-disclose what we find?

Often yes, and the calculus depends on the violation, your state, and whether the conditions of the applicable policy can be met. It is a decision to make with counsel and a credentialed environmental professional together.

How long does an audit take?

Typically two to four days on site for a mid-sized manufacturer, plus report time. Multi-media audits take longer than single-media ones and are usually worth it.

Who performs the audit?

A CHMM-credentialed professional, with specialist support brought in where the work requires a specific engineering discipline.

Do you help close the findings?

Yes — that is usually where the engagement continues. Finding problems without closing them creates documented knowledge of violations, which is worse than not looking.

Know your generator status before EPA does.

Twenty minutes to scope an audit and identify which media carry your real exposure.

Book a 20-minute call