How to Impress an EPA Compliance Auditor: Do Your Own Audit First!
Have you ever received a letter that the EPA is “coming to a town near” you for an NPDES Permit Compliance Audit? If you have, you are familiar with that gut-wrenching thought: Are we ready? While you are certainly aware of the requirements contained in your NPDES permit, and you know you have put forth a solid effort to comply with these requirements, there is still that underlying question: Are you ready?
If you have never been through this process before, it can be confusing and intimidating. You will immediately question how you prepare, what you need to provide, if you are in compliance and what happens if you aren’t. Using a DIY approach first, you can identify and begin to fix issues before the auditor is at the door.
This DIY approach will involve conducting an independent internal compliance audit, ideally by an entity that does not have day-to-day control over implementing your NPDES permit. This independent audit should be conducted by individuals who have experience with EPA audits and understand what the EPA will be looking for and what questions will be asked, and go through the following steps:
- Identify measurable components of the permit
- Establish goals that are measured/assessed by performing the internal audit
- Establish an objective auditing protocol that includes the creation of an audit database with key measurable components of each specific NPDES permit component being audited
- Input audit information into the audit database to create baseline information
- Perform follow-up audits to compare results with previous audit results, time permitting, to determine if specific NPDES permit components have achieved the measurable goals
- Use these results to create new measurable goals
Audit results are used to ensure that the requirements of the NPDES permit are being met. Interviews with staff who have day-to-day control over NPDES permit implementation are critical and allow for a better understanding of program implementation related to compliance with the permit.
A final audit report is then created to explain the implementation of the NPDES permit requirements. This report includes potential compliance issues and recommendations for program modifications to bring the program into compliance. If the independent internal compliance audit is being conducted as a result of notification of an EPA audit, then there should be no surprises when EPA conducts their audit.
If the independent internal compliance audit is being conducted to assess the current status of your NPDES permit implementation program, then you can implement the final audit report recommendations for program modifications to bring the program into compliance with the NPDES permit and know that you will be in compliance if EPA were to audit your program. And if they do, you are ready to impress them!