To maintain compliance with their ISO 14001 Environmental Management System and Customer requirements, WKW Extrusion asked Envirologic to provide a routine Environmental Audit.
Initially, Envirologic performed an Environmental Compliance Evaluation. The purpose of the evaluation was to identify which major environmental programs and regulatory requirements, if any, may apply to the facility's operations. As a part of the evaluation, Envirologic inspected the property and reviewed relevant databases and documents including waste manifests, contingency plans, and existing permits.
One of the results of the evaluation was the identification of the use of chemicals that may need to be reported under the Emergency Planning and Community Right to Know Act (EPCRA) Section 313. To evaluate this specific finding, an Environmental Audit was conducted of the operation's EPCRA Section 313 compliance. The audit was completed consistent with State and Federal programs that provide opportunities for penalty reduction. The audit determined that nitric acid use exceeded U.S. EPA reporting thresholds and had not been reported for several years. Envirologic built spreadsheets and procedures that documented the past usage of nitric acid and allowed for tracking in future years. Violations were then reported to U.S. EPA by the client through U.S. EPA's self-disclosure portal. Past reports were compiled and submitted, providing the necessary corrective action. The client was provided with the spreadsheets and other user-friendly tools so they could manage this effort independently in the future.
Envirologic's two-step approach to this project involved first identifying pertinent regulatory programs and then auditing specific areas where the client was less sure of their status and ability to self-correct any deficiencies. It allowed us to schedule and design an audit that was focused and uniquely tailored to our client's needs. Through timely self-disclosure and correction of violations, the client was also able to take advantage of provisions under Federal law that provide mitigation or elimination of penalties. As a result, the client has returned to compliance, is prepared to maintain that status, and is well equipped to maintain their obligations to clients and their ISO 14001 Environmental Management System certification.
"Working with Envirologic was very helpful. They took time to collect data for our specific location to ensure accuracy on the project. Envirologic helped to guide us in the right direction for current and future state and federal reporting requirements." - Luke Ryskamp, WKW Extrusion