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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.

Metal Casting Foundry. LMG conducted a comprehensive environmental compliance review of one of North America’s largest metal casting foundries. The foundry’s operations included aluminum lost foam and grey iron/ductile sand casting with more than 150 air emission units, an onsite special waste landfill, and extensive wastewater treatment including settling ponds. The foundry is a Major Source of air emissions, significant NPDES discharger, and large quantity generator. We conducted this review under tight timelines and reported the results of the audits directly to in-house counsel.

Iron & Steel Plant. LMG conducted comprehensive E&S audits and Environmental Management System (EMS) reviews of an integrated steel manufacturing operations in Ohio and Pennsylvania. These operations include the use of large natural gas furnaces similar to Pilkington float plant. The results of the E&S audits were used by senior management to identify environmental or safety compliance and risk management issues. The EMS reviews served as a gap analysis for the facilities in anticipation of complying with the ISO 14001 standard.

Automotive Parts Supplier. LMG conducted a comprehensive environmental permit review of an automotive parts supplier in Ohio. As part of the review, LMG conducted an evaluation facility’s compliance with federal, state, and local environmental requirements. We then developed an overall action plan for the facility that was designed to implement corrective actions cost-effectively and consistent with the company’s internal policies and procedures. LMG also developed a simple Excel-based electronic environmental data management system to assist the facility with tracking and recordkeeping associated with various environmental aspects of its operations.

Fiberglass Reinforced Plastics Manufacturing. LMG conducted a baseline environmental compliance assessment of a fiberglass reinforced plastics facility prior to the acquisition of the facility by an investment group. The assessment included a detailed evaluation of documentation and facility operations associated with an air emission inventory calculations, NPDES and drinking water well permits, historical SARA reporting and waste management. Based on the results of the assessment, a number of pre-acquisition corrective actions were implemented. LMG is also providing ongoing compliance assurance services to the facility.

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Environmental Compliance Assurance


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.

Medical Device Company. LMG provides ongoing environmental compliance services for a regional medical device company and a electroplating manufacturing company with five NE Ohio plants. Selected plants are classified as Major Sources for air emissions, large quantity generators, and significant industrial dischargers under local pretreatment regulations. For approximately 6 months, LMG provided weekly onsite environmental support at the plant locations. Annual compliance activities include permit compliance monitoring, inspections, preparation of air emission, SARA, and hazardous waste reports and facility-wide recordkeeping activities. Also provide strategic environmental information to Environmental Director to assist in long-term planning and identification of cost reduction opportunities.

Grey Iron & Steel Foundry. LMG has provided comprehensive Environmental Compliance Assurance Program (ECAP)© support for a grey iron & steel foundry located in Ohio from 2005 through 2008. Annual compliance activities included preparation of Air Emission, SARA, and hazardous waste reports and facility-wide recordkeeping activities. Also provide strategic environmental information to CEO and CFO to assist in asset management and acquisitions.

Ceramics Manufacturer. LMG provided onsite comprehensive E&S compliance assurance services to an Ohio-based manufacturer of ceramic components for electronic parts. This assistance included conducting an initial E&S compliance evaluation and management systems gap analysis. Based on the results of these activities, LMG developed an action plan for the facility and provided task-specific support for implementation of the plan. This support included: preparing required facility NPDES and air permits; updating safety programs and procedures for lock-out tag-out and provision of personal protective equipment; and conducting E&S training of personnel.

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

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.

Metal Casting, Metal Parts, and Plastics Manufacturing. For six or more years, LMG has provided ongoing environmental compliance assistance to various metal casting, metal parts, and plastics manufacturing operations located in Ohio. The assistance includes advising on all aspects of the facility environmental compliance and conducting environmental reporting activities including preparation of required air emission, SARA, and hazardous waste reports. In 2004, we began conducting these reporting activities electronically. In preparing the reports, LMG works directly with facility personnel to collect and validate data reported in the reports. This data is also typically reported to senior management in a summary format for cost tracking purposes and to identify potential opportunities for cost reduction.

Metal Manufacturing Plants. LMG conducted PCB equipment inspections at five metal manufacturing operations in Ohio and Indiana. The inspections focused on identification and classification of PCB-containing electrical and heat transfer equipment. Based on the results of the inspections LMG identified numerous unclassified PCB transformers, PCB capacitors, and other PCB-contaminated equipment. We then provided PCB management recommendations to the facilities that provided the foundation for a comprehensive strategy to comply with TSCA PCB regulations.

Metal Casting, Metal Plating, FRP Facilities. LMG is providing ongoing EPCRA and SARA chemical management and reporting assistance for a metal casting, metal plating, and FRP composite fabricating operations in Ohio. As part of these activities, we have developed procedures and vendor notifications to obtain required chemical information. LMG has also prepared annual SARA Tier I updates, Tier II reports, and Form Rs for submittal by the client. These activities have included the preparation on an Excel-based chemical data management system to automate and standardize the chemical reporting process.

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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.

We conducted the environmental assessments under tight timelines and reported the results of the assessments directly to senior management including the Chairman and Chief Financial Officer. Potential environmental risks at five of the six foundry sites were sucessfully evaluated and corrective actions implemented or limitations on liability from the seller obtained. One site consisted of an abandoned operation that was sucessfully divested to local quasi-governmental authority after we conducted additional Phase II investigation and generated targeted environmental liability costs. LMG’s solution resulted in escrowed remediation savings of more than $500,000 that were split 50/50 between seller and buyer.

Metal Parts Machining Plant. LMG conducted a comprehensive evironmental assessment of a medium sized metal parts machining plant. Performed on behalf of a private equity firm, the project involved a Phase I ESA and environmental compliance audit of the existing operations. In addition, we conducted a pre-planned targeted Phase II investigation of the plant based on the preliminary Phase I ESA findings. Based on the results of the compliance audit, LMG worked with the private equity firm to identify corrective actions and operational changes that reduced or eliminated these potential business risks. Furthermore, the results of the target Phase II investigation were used by the firm to negotiate a long-term lease for the real property instead of an outright purchase. LMG completed the entire project within an expedited 3-week timetable allowing the buyer to omplete the industrial plant purchase within the seller’s timetable.

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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.

Non-Recovery Coke Plant. LMG conducted a detailed feasibility study of the use of activiated carbon for the control of mercury emissions from non-recovery coke plants. The study included a comprehensive review and segmentation of DOE coal-fired utility boiler ICR on mercury emissions and activiated carbon control. Based on the results, we successfully moved Ohio EPA from a fixed 90% mercury emission reduction requirement to a flexible mercury emission reduction goal for non-recovery coke plants. In addition, LMG was able to obtain a cap on the injection rate for activiated carbon required for mercury emission control effectively reducing our client’s potential O&M costs by an estimated $200,000 or more per year.

Iron & Steel Plant. LMG conducted a process optimization study of a two-tower caustic scrubber system designed to control NOx emissions. Based on initial evaluation it was determined that system could be optimized through use of no-cost modifications. Using trial results, the system was modified to stabilize pH fluctuations through drastically changing pollutant concentrations, resulting in optimization of caustic usage and a caustic usage reduction of approximately 35%.

Iron & Steel Plant. LMG conducted an engineering analysis of various NOx air pollution control (APC) technologies for a mixed acid pickling line with actual emissions of over 120 tons per year. This included a technical and economic analysis of all options evaluated. Based on our technical and economic analysis an innovative APC technology was selected which would allow the facility to modify operations and adjust the level of control needed from APC unit to continue to achieve compliance with permit requirements and avoid New Source Review permitting.

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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.

The BACT study included development and successful incorporation of the use of an innovative horizontal coke pushing process into an enclosed quench car controlled with a baghouse. LMG prepared the submittial and obtained a MACT compliance determination from USEPA Region V authorizing the use of this innovative approach. The flat pushing of coke into an enclosed quench car is expected to reduce construction and operating costs associated with controlling pushing air pollutant emissions by more than $10 million over the life of the project.

Industrial Rubber Tire Manufacturing Plant. LMG prepared a Permit to Install (PTI) application package and subsequent Title V permit renewal application for an industrial rubber tire manufacturing plant that is a major hazardous air pollutant (HAP) source. The project included reviewing facility equipment, practices, and operational data for accuracy and applicability to state and federal environmental regulations. We also managed the preparation and submittal of 3 PTI applications as part of the Title V renewal that clarified application data, provided increased operation flexibility, and proposed less restrictive operating conditions. This process included utilizing dispersion modeling results and production planning input to demonstrate regulatory compliance with higher emission rates.

Reinforced Composite Plastics Plant. LMG prepared a Permit to Install (PTI) application package, Title V Applicability Assessment and subsequent Title V permit application re-submittal for a fiberglass reinforce plastic (FRP) composite fabricating facility that was a major source of hazardous air pollutants (HAPs) such as styrene. The project included reviewing practices and facility operational data for applicability to state and federal environmental regulations and determined the facility to be applicable to the Title V permit application process. We also managed the preparation and submittal of 30 PTI applications for existing equipment that resulted in less restrictive permit conditions. This included utilizing dispersion modeling results and production planning input to determine modified emission rates that allowed operational flexibility while attaining regulatory compliance with permit Terms and Conditions.

Automotive Parts Supplier. LMG reviewed and revised a FESOP permit and conduct air toxics modeling for a major plastic automotive parts manufacturer. The original facility permit restricted the use of paints to specific booths and operating hours to keep VOC emissions below 100 tpy and HAPs below 25 tpy total. We worked with the paint supplier to determine specific non-VOC and non-HAP paints as alternatives to the current paints used. Realistic paint schedules and operating hours were determined by production departments and through the use of reduced HAPs and a VOC bubble permit the facility was able to gain the flexibility to use any paint in any booth within limited operating hours. This allowed the facility the ability to respond to rush orders and last minute scheduling and overtime needs

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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.

Rubber Parts Extruding Plant. LMG used Aeromod complex terrian modeling to optimize the minimum increased stack heights required for existing sources at a rubber parts extruding plant to comply with offsite air toxics standards without requiring additional air pollution control (APC) equipment. The modeling required incorporation and analysis of a wide range of stack scenarios that varied the number of stacks, location, air flow, and air pollutant emission rates. Based on the modeling results the plant was not required to install APC equipment and stack configurations were optimized to reduce ongoing O&M costs and reduce inital capital costs.

Medical Bandages Adhesive Coating Operation. LMG developed a compliance assurance plan for off-site nuisance odors for an adhesive coating operation manufacturing medical bandages in response to a regulatory agency. As part of the project, we conducted air emission dispersion modeling under varying operating scenarios to develop fence line odor concentrations. This baseline data was then used to evaluate various control options including exhaust stack height and velocity modifications, thermal oxidizer temperature and retention time modifications, and operating modifications. Based on this evaluation the facility was able to demonstrate to the agency that an odor control system was not necessary and that a combination of product substitutions and a modest stack height increase was appropriate to address the off-site odor impacts.

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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.

LMG was a key participant in direct discussions with USEPA Region V staff regarding the key issues raised in the NOV and the facility’s positions. We also concieved and conduced benchmarking studies to support facility regulatory positions. In addition, LMG managed the preparation and was the primary author of the facility’s response to a CAA Section 114 Request issued by USEPA Region V.

Non-Recovery Coke Plant. LMG is providing ongoing technical assistance regarding an appeal to the Ohio Environmental Review Board (ERB) of the final Permit to Install issued for the FDS Coking Plant in Lucas County, Ohio. As part of these activities, we have worked with outside counsel to advise senior management on specific technical issues associated with the final PTI and drafted the technical basis for the appeal. LMG is a key participant in direct discussions with Ohio EPA regarding the key issues raised in the appeal and the FDS Coke Plant’s positions.

Industrial Rubber Tire Manufacturing Plant. LMG prepared a MACT Applicability Determination Request submitted to USEPA Region V for an Industrial Rubber Tire Manufacturing (RTM) Plant that was a Title V facility. The applicability determination was a key component of the company’s long-term strategy to avoid the addition of costly air pollution controls to an adhesive application process associated with an industrial tire manufacturing process. Based on the information provided within the request the Title V facility was determined to fall within a MACT rule that allowed application of an adhesive coating with more than 10 times the hazardous air pollutant (HAP) content than specified under a secondary MACT rule that other operations were required to met at the facility.

Grey Iron and Steel Foundry. LMG provided expert assistance associated with an air emission odor investigation initiated by the New York Department of Environmental Conservation (NYDEC) against a grey iron and steel casting operation in New York. The assistance included design and implementation of a strategic response to isolated neighborhood complaints and NYDEC requests for corrective actions. We also met with NYDEC personnel to provide additional information associated with alternative sources of odors in the area and inconsistencies in the nature and timing of the odor complaints. Based on this information, NYDEC discontinued all enforcement actions and the client avoided unnecessary capital costs associated with construction of a super stack and additional air collection system for the metal casting operation.

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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.

Project activities have included the preparation of facility responses to Ohio EPA, writing hazardous waste management procedures for implementation by the operations, preparation of a RCRA contingency plans, performance of employee RCRA training, and oversight of the RCRA generator closure of a 90-day accumulation area at the facilities. LMG closure tasks have included design of a cost-effective work plan approved by Ohio EPA, contractor oversight, final inspection and sampling of the area, and preparation of the final closure report.

Sign Manufacturing & Installation Company. LMG provided expert regulatory compliance assistance and project management for the successful completion of an Ohio EPA Consent Orders associated with 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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