At EHS, our extensive experience with strategic environmental management, permitting, site assessments/investigations and safety management can help you identify potential problems early in the project to minimize liabilities and keep the project on schedule. Our expert staff of environmental and safety professionals provide cost-effective and timely solutions in today's competitive business climate.
The following project descriptions are just an example of the capabilities at EHS:
Regulatory Compliance Assistance
EHS Technology Group was initially retained to conduct an environmental regulatory compliance audit and to perform a "GAP Analysis" for ISO 14001 at a local company. This audit identified several regulatory compliance issues to be resolved. In addition, the GAP Analysis determined the facility had procedures, policies and practices in use that placed the facility in about 30 % conformance with the ISO 14001 Standard.
At the direction of the environmental, health and safety coordinator of the facility, EHS Technology developed a comprehensive environmental management system for the facility. In this role EHS took the lead in the development of all phases of the environmental management system (EMS). This included:
• forming and facilitating teams to identify
the environmental aspects, significant impacts to the environment, and the identification
of potential objectives and targets
• the preparation of first draft documents that included policies, procedures,
work instructions and records for the EMS
• integration of select ISO 9000 program procedures and documents into the ISO
14000 EMS
• regular meetings with the top management to review the development of the
EMS and to conduct training on their roles and responsibilities
• assist in the selection of the ISO 14000 registrar
• conduct internal audits of the EMS to prepare the facility for registration
and to provide on-the-job training for their internal auditors (Note: EHS used
staff that were not involved with the development of the EMS and were RAB trained
auditors to perform this task)
• developing and implementing the training for all facility personnel, including
the special training for operational controls and emergency preparedness
• support services throughout the registration process.
The company received ISO 14001 registration as a result of this effort. The corporation, based in Germany, has adopted the EMS as the standard for the corporation and has retained EHS Technology to begin the implementation of it throughout the other facilities in the US.
EHS Technology Group, LLC (EHS) was retained by a developer of computer systems for the management of automobile inventory, sales and service to assist them in the investigation of potential indoor air quality issues at two of their Dayton, Ohio facilities. In response to several health related complaints at the two locations, EHS was asked to identify potential causes of the reported symptoms, perform any required empirical measurements or sampling, interpret the results, and develop conclusions/recommendations for further action. EHS began the project by inspecting the sites to gather data, including interviews with affected employees and a review of Material Safety Data Sheets for chemicals used. Based on this information, a sampling plan was developed that included measurement of the following parameters:
• Mold
• Bacteria
• Volatile Organic Compounds
• Dust
• Carbon Monoxide/Carbon Dioxide
• Heat/Humidity
• Ventilation Rate
Upon conclusion of the sampling phase of the project, EHS reviewed the results and identified any potential health related impacts. A detailed report was prepared for the client describing the nature of the sampling performed, the results and recommended actions. EHS also made a presentation to all company employees summarizing the results in an understandable manner.
As a result of physical modifications made to several chrome plating lines at their Louisville, Kentucky facility a defense contractor was interested in determining whether the exhaust ventilation system was still properly balanced. EHS Technology Group, LLC (EHS) was retained to evaluate the plating lines and make recommendations as to the effectiveness of the fume capture system in its final configuration.
EHS visited the site and inspected all capture hoods for proper functioning. Capture velocity at each was then measured and recorded. The results from the entire system were then compared against both the original design criteria and generally accepted industrial ventilation design standards.
In a final report, EHS provided specific recommendations for the necessary adjustments to assure optimum performance of the fume capture system. In addition, EHS was able to identify an opportunity to consolidate the ventilation from regulated processes into one common air pollution control device, thereby reducing cost and labor resources needed to maintain compliance.
In order to assess what impact their automobile and scrap metal shredding operations were having on the surrounding neighborhood, EHS Technology Group, LLC (EHS) was contracted to perform an impact analysis investigation at an Indianapolis, Indiana metal recycling facility. The three major issues of concern were noise, dust, and exposure to heavy metals. In order to accomplish their goals, EHS first developed a sampling plan that identified key locations at the fence line and beyond to perform noise and air measurements.
The sampling effort was performed while plant operations were running at peak capacity. EHS collected ambient air samples and had them analyzed for several potentially present heavy metals, as well as total dust. Noise levels were also measured in the surrounding neighborhood. The results of these monitoring efforts were then compared to both regulatory exposure limits and ambient levels commonly found in an urban industrial setting.
A detailed report was then prepared for the client describing the nature of the sampling performed and the results. The report was prepared in such a manner as to allow distribution to both regulatory agencies and interested parties in the community.
A Japanese pharmaceutical company retained the services of EHS to facilitate a hazard and operability (HAZOP) study for a new sodium erythorbate manufacturing plant. This study was conducted as a portion of the Process Safety Management compliance for the new facility. Activities included in the study were:
• Selection and application
of appropriate analytical methodology
• Analysis of facility siting and human factors
• Review of incidents based upon an existing Japanese facility
• Identification of applicable process nodes for study
• Determination of potential deviations, causes and consequences using HAZOP
guide word analysis technique
• Evaluation of engineering and administrative controls, consequences of their
failure and the range of possible effects on employees in the workplace
Regulatory Compliance Assistance
EHS provides continuing environmental consulting services for a number of automobile part manufacturers. These consulting services include:
Air Pollution
• Air Permitting
• Air Toxics Review and Modeling
• Best Available Technology (BAT) review
• Emission Inventories
• Emission Testing
• Annual Emission Fee Statement
• Quarterly Reporting for Emission Sources
Water Pollution
• POTW Permitting
• NPDES Permitting
• NPDES Storm Water Permitting
OSHA
• Health and Safety
• Hazard Communication
• Industrial Hygiene
Community Right-to-Know
• SARA Title III Section 311/312 and Section 313
Additional Issues
• Pollution Prevention Plans
• Waste Minimization Plans
EHS was hired by a large wood furniture manufacturer to assist wuth air permitting issues. A rapid and extensive expansion at the facility was proposed. It was very likely that the plant would quickly have a level of air emissions subject to the PSD rules. EHS was tasked with completing a facility wide emission inventory to determine current permit limits and actual emissions. Emission testing was performed by the company's contractor supervised by EHS to verify the actual emissions versus the permit allowables. The proposed production, and subsequent emission increases were calculated and analyzed with respect to the PSD rules. EHS then completed a thorough review of the PSD requirements, including air dispersion modeling protocol. In addition, EHS conducted meetings with the Ohio Environmental Protection Agency to coordinate the PSD permitting process from the initial stages. As a result of this early planning, it was determined that the facility could be repermitted to avoid applicability with the PSD rules. EHS then completed the facility-wide repermitting process, which allowed the facility to expand while continuing daily operations.
EHS completed a Phase I Property Assessment for the subject property, which included historical review, regulatory file review, a review of previous environmental investigations and a site inspection, in support of a potential property transfer. The site is an industrial building which housed a tool and die manufacturing facility from 1947 to 1992, and now houses a specialty fabrication shop. The property is located in North Dayton, and is surrounded by additional industrial facilities, most of which have been operated as metal fabrication shops or tool and die manufacturing facilities for part or all of their histories. The property is underlain by the highly-productive Buried Valley Aquifer System Sole Source Aquifer, and is located slightly over one mile southwest of, and downgradient from the City of Dayton municipal wellfields. Previous Phase I and Phase II investigations conducted on the property had determined that the ground water beneath nearly the facility was contaminated by trichloroethene (including at wells on the upgradient property boundary), but had not identified any on-property source of chlorinated solvents which might have been responsible for the ground-water contamination.
A Phase II Property Assessment was completed on the subject property, which included sampling and analysis of ground water from previously-installed wells, the installation of five additional monitor wells, and soil sampling in areas surrounding and upgradient from the one downgradient well at which anomalously high concentrations of trichloroethene had been detected. The sampling confirmed that the ground water beneath the property was contaminated, but also confirmed that there was no on-property source or source area of chlorinated solvent contamination. The report concluded that the groundwater contamination was the result of exclusively off-property, upgradient releases. One potential upgradient source was identified through information obtained in a review of Ohio EPA files. A reasonable scenario was developed to show how contamination from a sidegradient source may have been responsible for the contamination of the subject property. This scenario involved reconstruction of the shifting groundwater flow directions with time caused by production at an upgradient water supply well, and the later shutdown of this well. Institutional controls were established to protect on-site workers from exposure to the contaminate ground water, and a No-Further-Action letter was prepared for the volunteer. Following the filing of deed restrictions, this No-Further-Action letter will be submitted to Ohio EPA, in order to obtain a Covenant Not-To-Sue.
Generator Closure and Remediation
EHS prepared a Ground Water Quality Assessment and Monitoring Plan and a Remediation Plan for the facility located in Springfield, Ohio. Preparation of the plans has involved ground water sampling of existing monitor wells, survey of well locations to determine the direction of groundwater flow, evaluation of previous investigations to prepare detailed geologic and hydrogeologic descriptions and evaluation of laboratory analysis to determine the type and location of contamination. EHS has been involved in extensive negotiations regarding closure, consent orders and plan development with regulatory agencies. Cascade is now waiting for comments on plan submittals in order for EHS to perform an extensive site investigation to determine the horizontal and vertical extent of contamination. After evaluation of laboratory data, EHS will design and construct site-specific soil and groundwater remediation systems.
RCRA Closure Oversight
EHS has provided technical assistance and oversight to a refining facility for closure of four major RCRA hazardous waste storage tanks, a major drum accumulation area, and several minor less than 90 day hazardous waste accumulation areas. The refinery is being decommissioned which has resulted in the removal of various wastes. During the refinery operation the storage tanks and the drum accumulation area were used routinely as a part of their RCRA management activities. During decommissioning of the facility, approximately 8 minor accumulation areas were used for the temporary accumulation of RCRA hazardous wastes prior to disposal. For the tank and major drum accumulation area closure, EHS prepared and gained approval from the OEPA of a closure plan for the facility. All of the areas were "clean-closed." Two areas were required to undergo risk analysis to determine that the levels of contaminants remaining on the site were of acceptable levels. EHS, also wrote a closure plan for approximately 8 minor less than 90 day accumulation areas which provided the required level of flexibility in application while complying strictly with the requirements of a generator's closure. EHS professionals supervised contractors and the facility's employees in the appropriate clean-up activities and sampled to verify clean closure. For several sites background levels of certain contaminants were taken to identify background contaminants which had elevated levels detected in the cleanup samples but had nothing to do with the RCRA activity at the accumulation area. Final reports and required certification were also provided by EHS.
EHS initially was brought into the project to perform environmental assessments prior to a possible property transfer of a facility that recycled lead-acid automobile batteries in the early 1980's. The Phase I assessment recommended a Phase II investigation with sampling. A Phase II investigation of the property was conducted, which included characterization of the site, and sampling and analysis of the soils, ground water, surface water, stream sediments and waste materials present. Based on sampling results, notification was made to USEPA under the CERCLA program due to the presence of hazardous concentrations of lead that were present on the property and which were also being carried off site. EHS was involved in negotiations with the agency and other PRPs, and has critically reviewed work plans prepared by the EPA and other consultants. EHS has directed some of the remediation work and has overseen other parts of the remediation that was conducted by other PRPs. Remedial efforts overseen by EHS included decontamination, recycling and disposal of equipment stored in the building and in the yard, removal and disposal of other wastes present on the site, and the decontamination and dismantling of the building. EHS has also prepared a work plan for the removal of contaminated soils remaining on the property.
This project was accomplished in three phases. The first phase consisted of the removal and replacement of two underground storage tanks (UST); a diesel fuel and unleaded gasoline tank. The second phase consisted of removal of a leaded gasoline tank and abandonment and replacement of two shock oil tanks. The third phase consisted of removal and replacement of five underground shock oil tanks. All the engineering design incorporated the removal of existing tanks (some were abandoned in place), installation of the new tanks, all permit work, supervision of tank removal and installation and reporting of the tank closures to the proper authorities. The design drawings consisted of all or some of the following parts:
1. Removal of tanks and all
associated items
2. Concrete pad installation and details
3. Tank installation layouts
4. Process and instrumentation layouts
5. Fire suppression system
6. Electrical distribution
7. Electrical control diagrams
8. Installation of PLC-5 software (after tank installation)
9. Specifications (equipment, materials and installation)
Some remediation work was also accomplished. EHS assisted the client in keeping the regulating authorities informed during the design and installation. EHS prepared the air permits required by the local agencies and the closure reports of the existing tanks were written and submitted to the proper authorities.