EPA-Audit and Audit-Assistance
The EPA will come and audit thousands of facilities per year, incuding multiple facilities for one company. The EPA Region 6 audits thousands of Oil and Gas facilities per year and several hundred Salt-Water Disposal Facilities as well. They use a 16-page Audit packet when the perform the audit which covers dozens of chapters of codes and requirements.
The way the audit works is they could send you a letter first and then meet you a few days later at the facility. They can also show up anytime and require you to show your paperwork immediately. However, the usual method is sending you a letter and also calling before they come. This doesn't give you much time to prepare everything. Most companies can't get everything together this quick.
When they begin the audit the first thing they ask for is the SPCC Plan and they go straight to the date that the Engineer signed the Plan. They look for signatures. If you have not signed your plans they will assume that you haven't read the plan and they will continue the audit as if you don't have a plan. This will hurt you when the Enforcement Officer contacts you.
Assuming everything was signed correctly, then they look for all the correct sections in your plans, including the 18page Flowline-Contingency Plan (section 109) to be with the SPCC Plan. This is big deal if you don't have this. They will give you several deficiencies for not having a flow-line plan, and you will have to pay a penalty and meet a new set of requirements. Not only do you have to pay pentalies but you're still required to get the compliance completed. They will normally give you 21 days to complete what you don't have. You will still be required to pay a fine and also complete the work to be done. In addition you will likely pay a lot more to a company because it will be considered a rush-job by many companies. This is why it's better to be prepared and have everything complete well before you are audited.
Another problem you have if you wait to prepare your plans is that the EPA will require 3 years of Annual Field Inspections to be with your SPCC Plans. Even if your plans are new they will require to produce all three years in the past. They may also want to see your Tier 2 Reports for the last three years. This is why companies that wait to prepare everything will pay a lot more in the end. We like to tell our clients, "It's better and cheaper to have it and not need it, than to need it and not have it."
We will assist all of our clients when they are audited and also perform the audit for them if they would like us to. The EPA can ask tricky questions and knowing the answers can save you a lot. For instance if they ask you, "What do you do with your contaminated soil?" You need to know how to answer the question or they will give you deficiencies. The correct answer for this question is that you have a remediation garden where you remediate the soil. The contaminated soil is mixed with proper chemicals and fertilizers to remediate the soil before using again. They have hundreds of questions like this they could ask, and it's important to know your answers.
If you're worried about doing your own audit, then it's time to become our client and we will do them for you. We have helped with more than 100 Audits and we can handle this for you. Give us a call today and let us be your compliance department.
