A confidential client owns and operates hundreds of reciprocating internal combustion engines (RICE) across the country at its various oil and gas facilities. The client hired Barr to complete a comprehensive regulatory-applicability review of the client’s engine inventory and audit of its compliance programs with regards to the applicable state, federal, and county air quality regulations and associated air quality permits. The intent of the audit was to demonstrate whether the client was correctly determining regulatory applicability and that its RICE compliance program and practices are consistent with industry standards.
Barr reviewed the client’s existing process for determining engine applicability, created compliance tasks, provided recommendations for process improvements, and confirmed that the process adequately applies requirements and tasks to each type of engine. Significant challenges included managing the large number of engines, the many different regulatory jurisdictions (states), and the large amounts of associated data. Collaborative and consistent communication between Barr and the client allowed us to help the client transition its audit policy from a site-by-site process to a program-wide approach.
Senior Environmental Scientist
Principal Emeritus Senior Environmental Consultant