Environmental Compliance Reviews

Environmental Compliance and Auditing

An environmental compliance review evaluates the operations and equipment at a property, determines the applicable environmental requirements, identifies where gaps exist, and presents a pathway to compliance. Compliance gaps may be caused by many factors, including acquisition of new operations, the continuous development of new environmental regulations, facility growth or expansion, and personnel changes resulting in loss of inherent knowledge.

While commonly assumed to apply only to heavy industry, environmental regulations apply to a surprisingly wide range of activities at a wide range of properties. Examples of regulated operations and equipment that may be present at residential, commercial, institutional, or light industrial properties include:
  • Electrical Generators
  • Boilers
  • Fluorescent Light Bulb, Battery, and Used Oil Disposal
  • Stormwater Discharges
  • Refrigerant / Coolant Use
  • Storage of Common Materials

The above operations and equipment may trigger air permit requirements, EPA NESHAP requirements, water discharge permitting, spill plan development, waste disposal management requirements, and EPCRA reporting requirements. While understood and proactively managed by large industrial facilities, these regulations often are not well communicated to other business sectors and may represent unidentified liabilities.

Examples of gaps identified and remediated by Nova during past reviews at non-industrial properties include:

Improper disposal of EPA-regulated waste within common trash
Outdated hazardous waste registrations belonging to prior building tenants
Improper permits for air emissions from emergency backup electrical generators.

Considering the current environment of increased regulatory enforcement, these reviews ensured a sound investment by removing potential liabilities.

To support a client’s liability assessment and management processes during due diligence, Nova designs environmental compliance support that aligns with the level of risk presented by a property. Commonly as an extension of a Phase 1 Environmental Site Assessment, but also as a stand-alone effort, Nova conducts Limited Environmental Compliance Reviews for residential, commercial, institutional, and light industrial properties. These reviews determine applicable requirements and identify compliance gaps. They are commonly conducted within the typical timeframe of due diligence efforts and are scoped to ensure cost-effective identification of primary concerns that present real liabilities. Nova then works with the client to develop corrective actions to ensure sustainable compliance.

Due diligence efforts to identify compliance liabilities have been a standard tool used by industry professionals for many years. When appropriately tailored to a client’s needs, Nova’s Limited Environmental Compliance Reviews are valuable for a wide range of property types.

John Bale image

Author:
John Bale
Environmental Compliance Group Manager
Nova Consulting Group Inc.
(612) 310-7957
john.bale@novaconsulting.com

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