Challenge
A client who operates a corn milling, germ oil processing and bioproducts facility experienced a significant environmental incident followed by substantial operational and organizational changes. To help re-establish and maintain a robust environmental compliance program, they partnered with TRC to identify gaps and assist with the implementation of corrective actions.
Solution
Our practitioners TRC’s auditors conducted a comprehensive, independent environmental compliance audit that served as the baseline for ongoing issue resolution. The audit reviewed key environmental programs and media, including compliance related to a Title V air permit, Risk Management Plan (RMP), waste, water, wastewater, storm water, environmental reporting (e.g. reporting under the Emergency Planning and Community Right-to-Know Act), PCBs, Spill Prevention, Control, and Countermeasure (SPCC) Plan and storage tank compliance.
Numerous and significant compliance gaps were identified, with a contributing factor being the limited expertise and number of facility staff.
To support post-audit corrective actions, TRC provided two days of on-site assistance every two weeks for a period of 6 months, supplemented with additional remote support. Key activities included:
- Addressing audit findings, including documentation of waste determinations and submittal of revised environmental reports to various regulatory agencies
- Preparing air permit applications, updating records, and submitting regulatory notifications
- Hands-on mentoring and technical guidance to plant leadership and environmental manager
- Clarifying roles and responsibilities related to environmental compliance
- Integrating environmental requirements into daily business operations
- Supporting broader environmental compliance and management system efforts
Results
In addition to clarifying where the compliance gaps existed and the potential severity of those gaps, TRC’s post-audit support helped the client:
- Accurately complete required environmental reports
- Achieve compliance with air emissions regulations
- Extend accountability for compliance across appropriate staff roles
- Implement sustainable practices to maintain long-term regulatory compliance