Environmental Site Assessments and Compliance Audits
Our attorneys have counseled domestic and international clients on all aspects of environmental site assessments ("ESA") and compliance audits, including the retention of consultants, the scope of work, documentation of draft reports, finalization of reports and resolution of any deficiencies identified in the course of an audit. We have participated in numerous ESA and compliance audits conducted as part of transactional and regulatory due diligence on behalf of purchasers, sellers, lenders, and operators of numerous industrial, residential, commercial, and manufacturing facilities. We regularly review compliance audit reports prepared by consultants and the EPA, and negotiate site access agreements.
We have counseled numerous industrial clients on ESA and compliance audits, including waste-to-energy incinerators, the scrap recycling industry, the textile industry and the non-coal surface mining industry. Our firm has in-depth experience with the municipal management, operation, and maintenance (MOM) Audit Program for EPA. Finally, we are well-versed in the self-audit privilege.
Sample representations include:
- Helping develop the first compliance audit program for a Fortune 100 forest and paper products company, and serving as the primary attorney responsible for the implementation of the audit program. This included giving advice on audit findings and insuring that appropriate corrective action was immediately taken;
- Advising clients on numerous international ESA and compliance audits, including audits in Canada, Eastern and Western Europe, the Caribbean, China, Australia, Indonesia, and South America;
- Preparing a comprehensive audit manual for a very large semiconductor manufacturing plant; and
- Developing a comprehensive air-quality auditing program for a major investor-owned electric utility with five separate generating stations.