New Owner Audit

Owner/Client

Confidential Client

Location

Southeast Ohio Area

CEC Services

  • Air Quality Compliance

Owner Objective

The owner was seeking to avoid any compliance liability, financial or otherwise, for any air permitting or compliance violations that may have been missed during the due diligence process prior to acquiring a group of new production assets. As companies acquire new assets, it is important to verify the oil and gas sites are operating in compliance with both state and federal air regulations and that they address, and disclose, any discovered air quality deficiencies relating to the storage vessels and their associated control systems outlined in the audit agreement.

CEC Approach

CEC developed a programmatic approach to identify any compliance, or potential compliance violations with state, as well as federal air regulations relating to the on-site storage vessels. Additionally, CEC provided suggested solutions and remedial actions for those identified violations.

CEC broke the project down into five (5) components, or tasks. First, CEC personnel had to build the audit protocols and checklists. This would determine what we had to do and how it had to be done. CEC then performed the field survey and equipment inventory component of the audit. Data was collected in the field to aid in the compliance review of each of the facilities. While the field activities were being completed, the desktop review component began. This step involved the emissions calculations, regulatory analysis and permit applicability determinations. The audit findings were then compiled and memorialized into a document for submittal to the client. After client review, this information was then provided to the EPA. The final component was to perform leak detection surveys to verify the success of any corrective actions relating to identified compliance issues.