Our team conducted environmental compliance audits under the Texas Environmental Health and Safety Audit Privilege Act. The environmental compliance audits included a review of U.S. Environmental Protection Agency (EPA) and Texas Commission on Environmental Quality (TCEQ) regulations in the areas of hazardous and non-hazardous waste generation and recycling; Spill Prevention, Control and Countermeasure (SPCC); Storm Water Pollution Prevention; Emergency Planning and Community Right-to-Know Act (EPCRA) reporting; wastewater discharge; and air emissions permitting. The work was performed under the direction of NuStar’s legal counsel.
We prepared a letter report of audit findings, identified compliance gaps, and cost estimates for corrective actions. A summary table was prepared for each Site documenting violations discovered to date. We also participated in meetings, conference calls and email correspondence with NuStar as needed to discuss audit findings.
