Environmental Projects

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.

Reinforced Plastic Composite Products Manufacturing. LMG provides ongoing NPDES permit storm water monitoring and reporting services for two reinforced plastic composite product manufacturing operations in Ohio. These services include monthly storm water sampling, completion of electronic DMRs, annual storm water inspections, and employee training.

Electro-Ceramic Manufacturing. LMG Developed a Total Toxic Organic (TTO) plan and SWPP plan for an Ohio electro-ceramic manufacturing operation with goal of obtaining No-Exposure Certification within 1 year

Metal Casting Operation. LMG Resolved NPDES oil & grease discharge issues at metal casting operation to eliminate non-compliance and obtain lower cost general NPDES permit coverage

Aluminum Extruding Company. LMG provided wastewater treatment consulting services for a major aluminum extruding company in Ohio. The project consisted of a technical, economic and regulatory evaluation of treatment methodologies for an existing caustic stripping line. The current configuration resulted in the generation of a hazardous waste stream (caustic). The final recommendation was a caustic recovery system that eliminated the hazardous waste stream, reduced caustic usage and scrubber water usage by >75%, and resulted in a non-hazardous filter cake.

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.

Fiberglass Reinforced Plastics Operations. LMG is providing ongoing hazardous waste management assistance for two fiberglass reinforced plastics operations located in Ohio. The assistance includes managing all aspects of the facility solid, universal, and hazardous waste generation and onsite accumulation. These management activities include conducting required weekly inspections, tracking required follow-up actions, training personnel, and performing required internal recordkeeping.

Metal Casting, Medical Parts, and Plastics Manufacturing. For the past six years, LMG has prepared annual hazardous waste reports for metal casting, medical parts, and plastics manufacturing operations in Ohio. In 2004, these reporting activities were conducted 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.

Integrated Steel Plant. LMG prepared a Source Reduction Strategy (SRS) program required for submittal for an integrated steel manufacturer in Pennsylvania. As part of this project, we conducted a comprehensive review of more than 25 processes generating residual wastes to identify specific methods and procedures currently used or historically evaluated to reduce the generation or toxicity of the residual wastes. LMG then investigated potential additional source reduction opportunities that could be applied to the processes in the future. Finally, we assisted the client in the development of policies and procedures to encourage and reward source reduction and pollution prevention at the facility.

Metal-Related Manufacturing Plants. LMG has provided required annual hazardous waste generator training to employees at a specialty steel facility, piezoelectric ceramics manufacturer, aluminum extruder, and steel coating operation. The training sessions include plant-specific information and materials to ensure personnel are instructed on company procedures and policies not just regulatory requirements.

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.

This information was then modeled in reasonable and conservative future costing scenarios. The modeling of the costing scenarios incorporated the probability results and investigation/remediation costs in an excel-based remedial costing analysis that also used statistical processes and the net present value (NPV) of money. The results of the remedial costing efforts were used for public company SEC reporting and by attorneys to defend the company from legal actions for additional reimbursement for environmental cleanup actions taken at the plant by the historical owners/operators.

Vacant Metal Products Plant. LMG conducted a third-party evaluation of remedial costing for a former metal parts manufacturing plant with a historical anodizing line. The existing remedial costing was based on traditional demolition and excavation of the anodizing line and surrounding soil. LMG’s evaluation identified use of risk-based RCRA closure as a viable option for closure. The risk-based closure was estimated to provide expected savings of greater than $300,000 compared to prior engineering estimates. The client is currently working with Ohio EPA to complete the risk-based 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.

Metal Products and Resin Manufacturing. LMG provided expert regulatory compliance assistance and project management for the successful completion of an Ohio EPA Consent Order associated with hazardous waste management at a metal products and resin manufacturing facilities in Ohio. Project activities included design and oversight of RCRA generator closures of 90-day accumulation areas at the facilities. LMG closure tasks 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.

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.

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.

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.