Helping Companies Find Their Way

Helping Companies Find Their Way

Environmental Project Experience
Air Compliance Assistance

Ohio Industrial Manufacturing Plant. LMG provided Clean Air Act (CAA) regulatory compliance assistance and technical advice during negotiations for the successful resolution without penalty of a USEPA Region V Notice of Violation (NOV) for a Title V industrial manufacturing plant in Ohio. As part of these activities, we worked with outside counsel to advise senior management on specific technical issues and resulting operation changes associated with strategies for NOV resolution.

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Air Permitting

Non-Recovery Coking Plant. LMG has led all Major Source PSD permitting efforts for the 1.44 million ton per year FDS Coke Plant proposed for Toledo, Ohio. The permitting efforts have included obtaining the initial final PSD permit to install (PTI) within 120 days and two subsequent PTI modification applications. We have also provided extensive technical information to Ohio EPA characterizing all coke plant process operations, estimating air pollutant emissions from more than 50 different sources, conducting air dispersion modeling, and determining Ohio BAT/BACT compliance.

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Brownfield Redevelopment

Closed Window Manufacturing Plant. Project Manager and principal environmental consultant for a closed former window manufacturing plant that was sucessfully redeveloped into a trucking distribution facility. The plant had operated more than 50 years with onsite metal anodizing, extruding, machining, coating, and various assemby operations. As part of the Ohio VAP actions, LMG conducted a comprehesive Ohio VAP Phase I ESA and identified more a dozen Areas of Concern (AOCs). We then conducted a comprehensive soil and groundwater investigation at the plant.

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Environmental Auditing

Glass Manufacturing Company. LMG conducts annual comprehensive environmental, health, and safety (EHS) audits of the North American operations of a Fortune 500 glass manufacturing company. The EHS audits are conducted as part of corporate legal risk management procedures and involve coordination and follow-up with individual plants, corporate EHS staff, company general counsel, and outside counsel. 

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Environmental Site Assessments

Gray Iron, Ductile, Stainless Steel Foundries. LMG conducted comprehensive pre-acquisition environmental assessments for six foundries recently acquired by a foundry holding company. The foundries included gray iron, ductile, and stainless steel casting operations in New York, Oklahoma, Oregon, and Washington. The environmental assessments included Phase I ESAs, limited Phase II investigations, and environmental compliance audits.

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Post Merger, Divestment and Acquisition Integration

Composite Plastics Manufacturer. LMG acted as the EHS integration expert conducting post-acquisition follow-up actions at a Northeast Ohio reinforced composite plastics manufacturing facility bought by a European counterpart. As the representative for the the seller as well as the ongoing EHS consultant for the buyer, LMG was uniquely poised to facilitate the completion of the buyer's post-acquistion actions within 60 days.

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RCRA Enforcement Assistance

Metal Products and Resin Manufacturing. LMG has provided expert regulatory compliance assistance and project management for the successful completion of an Ohio EPA Consent Orders and resolution of Notice of Violation (NOV) letters associated with hazardous waste management at metal products, plating, medical device manufacturing, and resin manufacturing facilities in Ohio.

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Site Remediation

Closed Industrial Site. LMG conducted the insitu chemcial oxidation of volatile organic compounds (VOCs) consisting of primarily xylenes that contaminated soil and shallow groundwater at a closed industrial site. We conducted these remediation activities as part of a Ohio Voluntary Action Program (VAP) No Further Action (NFA) letter. The soil and groundwater contamination was present in a limited area approximately 100 feet by 20 feet in size. However, the highest VOC concentrations in the soil were in the groundwater smear zone approximately 10 to 12 feet below ground. In addition, VOC concentrations in the shallow groundwater exceeded 200,000 ug/L at selected monitoring wells. Based on this information and the owners requested short remediation timeframe, LMG selected insitu chemical oxidation using injected hydrogen peroxide as the remedial approach. 

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Water/Wastewater Compliance

Metal Casting Operation. LMG provides ongoing regulatory compliance assistance for a metal casting operation in Ohio with both NPDES and POTW-permitted wastewater discharges. As part of these activities, we have negotiated to use laboratory results of split samples collected quarterly by the POTW authority resulting in an annual cost saving of $10,000. LMG also has prepared annual wastewater surveys and an NPDES permit renewal application for the casting operation.

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Air Dispersion Modeling

Reinforced Plastic Composites Plant. LMG used Aeromod complex and simple terrain modeling to determine off-site odor impacts from a reinforced plastic composites manufacturing plant. As part of this project we meet with senior Ohio EPA agency personnel to negotiate corrective actions for ongoing exceedances of PTO emission limits. Using facility-specific emission factor inputs and operational designs, we determined alternative air pollution control options that allowed the plant to keep off-site odor impact concentrations below odor threshold levels and discontinue use of carbon-absorption odor control systems which were required by a previous compliance directive. This allowed the facility to save an estimated $40,000 in O&M costs.

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APC Evaluations

Iron & Steel Plant. LMG prepared the technical response to air pollution control vendor, on behalf of a confidential Iron & Steel Plant, regarding warranty issues for a NOx oxidation system. Vendor technology did not meet warranted specifications regarding level of control and data interface with existing facility computer database. During the project we worked directly with vendor to obtain needed continuous emission monitoring equipment, level of APC turn-down sensitivity required, and computer interface compatibility to ensure ongoing compliance with permit terms and system optimization.

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ECAP/Onsite Support

Reinforced Plastic Composites. LMG provides ongoing comprehensive Environmental Compliance Assurance Program (ECAP)© services for a regional reinforced composite plastics with two NE Ohio plants. Plants are classified as Major Sources for air emissions and large quantity generators. Annual compliance activities have included preparation of air emission, SARA, and hazardous waste reports and facility-wide recordkeeping activities. We also monitor permit compliance and conduct weekly compliance inspections. In addition, LMG provides strategic environmental information to Vice President and Environmental Director to assist in long-term planning, asset management, and cost reduction opportunities.

 

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Environmental Compliance Assistance

Fiberglass Reinforced Plastics Manufacturing. For eight years LMG has provided ongoing environmental compliance reporting assistance for two fiberglass reinforced plastics operations located in Ohio. The assistance includes advising and managing all aspects of the facility environmental reporting activities including preparation of required air emission, SARA, and hazardous waste reports. In addition, we have prepared facility environmental plans and procedures including the SWPP plans, waste management procedures, RCRA contingency plan, and employee training procedure.

 

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Onsite Support

Fortune 100 Consumer Products. LMG is providing onsite environmental staffing resources to a Fortune 100 consumer products manufacturing plant located in NE Ohio. Our staff conduct required environmental management activities and the preparation of air emission, SARA, and hazardous waste reports. 

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RCRA Closure

Sign Manufacturing & Installation Company. LMG provided oversight, investigation, design, and project management for the successful completion of an Ohio EPA Consent Order associated with the closure of an unpermitted hazardous waste management unit at a sign manufacturing and installation company. Project activities included preparation of a Sampling and Analysis Plan (SAP), Remedial Action Plan (RAP), and management/oversight of the final closure remediation activities. LMG closure tasks included design of a cost-effective soil removal work plan that was approved by Ohio EPA, contractor oversight, final inspection and sampling of the area, and preparation of the final closure report.

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Remedial Costing

Specialty Chemicals Manufacturing Plant. LMG was retained by the current owner of a specialty chemicals manufacturing plant to develop remedial cost estimates for soil and groundwater contamination issues undergoing agency oversight at the plant. In developing the remedial cost estimates, we reviewed historical information and investigation data to evaluate the probability that contamination at specific areas of concern (AOCs) were related to releases by the current owner's operations. LMG then evaluated existing investigation and remediation cost information, identified alternative remedial options that could be more cost-effective, and developed independent costing information for comparison purposes.

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Waste Generator Assistance

Confidential Metal Parts Manufacturing Plant. LMG developed the technical design, acted as general contractor, and provided P.E. certification/oversight for the installation of a hazardous waste 90-day accumulation tank system for liquid acid wastes. The tank system was designed with multiple tanks to allow for potential segregation of acid waste streams for future recycling or resale. Installation of the AST system was completed in less than 2 weeks and the entire project was conducted in approximately 60 days.

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