Outside counsel for a Fortune 500 manufacturing company hired Barr to conduct audits at 35 facilities across the U.S. for compliance with water-discharge requirements at the federal, state, and local levels, including NPDES, stormwater, and industrial-pretreatment permits.
The broad objective was to identify known and potential liabilities associated with operations involving specified media at each plant, including screening for the presence of emerging contaminants and addressing compliance with new and pending regulations.
Within 18 months, our team completed audits at all 35 sites, despite having to reschedule some visits on short notice when competing priorities at certain plants required that.
Working remotely, Barr team members reviewed each facility’s manufacturing processes and chemical usage to deter-mine whether plant operators were accurately characterizing and appropriately disclosing water-related discharges. In addition, we reviewed relevant permits, monitoring data, compliance records, inspections, notifications, and change-management procedures. Subsequently, small teams of engineers and scientists visited each facility to observe conditions and develop recommendations.
For each facility, Barr prepared an assessment report detailing:
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Regulations and permits pertaining to wastewater and stormwater management
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The assessment protocol
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Findings, observations, risk areas, and recommendations
When requested, Barr also evaluated facilities’ pretreatment programs and stormwater pollution-prevention plans (SWPPPs), supplying technical memos afterward with findings and recommendations for each facility.
The scope of the detailed audits encompassed reviewing not only permits, facility plans, compliance records, and on-site operations, but also historical regulatory applicability and archived records of sampling results. In addition, Barr interviewed facility staff, and in some cases, to facilitate site walkdowns, we prepared process and layout drawings for facilities with missing or incomplete drawings. Our teams:
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Identified gaps in existing facility plans and permits that would need to be updated for the plants to maintain compliance with applicable state and federal regulatory programs
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Recorded gaps in compliance with applicable regulatory programs
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Provided best practices that sites could adopt to better manage and execute their environmental programs
To promote quality assurance and quality control, Barr developed measures for audit completeness, uniformity of process, consistent presentation of information, and quality of final deliverables. We established audit and interview templates, report consistency guidelines, and data inventories to be followed for each audit. For each facility, a customized assessment table was generated that itemized all conditions and requirements to be reviewed based on federal, state, and local requirements, as applicable.
In addition, to foster systematic documentation of all issues, Barr compiled a comprehensive database of recommendations by facility, categorizing findings, observations, and program risks (e.g., wastewater, stormwater, product storage). We also created a list of issues common among the facilities to help our client efficiently address improvements.
Finally, two Barr technical team members reviewed each final deliverable for content accuracy, completeness, and document quality.
We presented audit findings and recommendations to our client’s corporate and outside counsel, discussing documented and potential areas of noncompliance that could have significant impacts on business operations. For each site, we provided final reports listing corrective actions.