D. RCA professionals responded to a secondary metal manufacturer’s complaints of high CO levels within the offices were making personnel sick. CO monitors were placed within the office areas and allowed to data log CO levels over the remainder of first shift and for most of second shift. While the sampling was occurring, an investigation of potential CO sources was conducted throughout the plant and the offices. High CO levels were confirmed within the offices. The different CO measurements taken were used to locate an office with a return air duct that originated within the plant near a forklift staging area.

E. On a quarterly basis, RCA, Inc. performs personal lead sampling for several industries that either melt lead containing materials or use lead containing materials within their products. All sampling and employee work procedures are monitored and detailed within the final report along with the final sampling results. All results are compared to OSHA’s PEL and recommendations are made based upon the OSHA standard and specific operations at the facility.

F. Due to a high number of lost workdays, over the course of one year, an industrial facility was contacted by OSHA to work out an effective facility-wide safety plan or face a potential inspection as part of OSHA’s Comprehensive Compliance Program. RCA professionals performed a facility-wide safety and industrial hygiene audit which included a review of all safety related documentation, any OSHA correspondence, current and past record-keeping, interviews with section managers, a review of facility operations, and a compilation of all facility policies. Using this information, a safety priority list was established. A written safety plan was developed while facility safety concerns were being addressed.

G. RCA professionals conducted a Phase II assessment of an industrial property in the Greater Cleveland area. The project included development of a sampling plan to target specific areas of the facility that were suspected of being contaminated. The plan included identifying sampling locations, establishing analytical parameters, executing field operations (drilling and sampling), supervising laboratory analysis, and report compilation including data interpretation and recommendations. The project included over 20 soil borings to various depths, and collection and tracking of over 100 soil samples for a variety of organic and inorganic analysts.

H. RCA professionals were contracted to conduct a Site Assessment and Corrective Action Plan (CAP) for an industrial facility with leaking Underground Storage Tanks (UST's). The initial phase of the project included supervision of the UST removal, implementation of closure activities and development of Closure Report per BUSTR. During closure activities, extensive petroleum contamination was discovered. EEI developed and implemented the Site Assessment/Characterization, and CAP for this site. The project included removal and disposal of contaminated soils, design, Statement of Qualifications
construction, and development of a ground water monitoring well network (4 wells), ground water sampling, and additional soil sampling to confirm remediation efforts. The successful implementation of this project resulted in a No Further Action (NFA) letter from BUSTR, and near maximum reimbursement from the State Assurance Fund.

I. A facility accused of dumping and disposing of industrial chemicals contracted with RCA professionals to develop and implement a sampling plan. The suit alleged that the facility had several dumping areas on-site, and also that chemicals had been illegally disposed in streams surrounding the site. EEI developed a sampling strategy that included sub-surface investigations in areas of known "debris" dumping, sub-surface investigations in areas of alleged dumping, and sampling and analysis of stream surface water and sediment. The results of the project determined that there were no industrial contaminants associated with the "debris" dump; there were no additional disposal areas, and that there were no measurable impacts realized in the streams or sediment.

J. A facility being auctioned in bankruptcy court required a Phase I Environmental Assessment to be completed in one week. The project was quoted and awarded on a Monday. RCA professionals mobilized a team and conducted the assessment on Tuesday and Wednesday. Copies of the completed assessment were delivered to twelve (12) potential bidders by Saturday.

K. RCA professionals developed an NPDES permit application for storm water discharges for a 160-acre industrial facility. The project included site reconnaissance to locate storm water discharge outfalls, determine drainage areas and flow patterns, delineate impermeable surfaces, identify hazardous storage/disposal areas, and identify methods for storm water and pollutant control. In addition, sample collection and analysis was performed along with flow determination.

L. Several industrial facilities were assisted by RCA professionals in developing and completing closure plans for various RCRA projects. Program Management included liaison between client, contractors, and EPA officials. The projects included site investigation and assessment, UST removal, waste characterization and disposal, health-based risk assessments and supervision of closure activities. In many cases, RCA professionals were able to reduce client financial liability by proposing alternate disposal methods and/or negotiating with EPA.

M. RCA professionals assisted a large steel foundry in completing their annual Title III Form R (Toxic release Inventory) reporting. A review of all MSDS’s (greater than 250) was completed and compared against purchase records. This data was used to complete the Form R for the previous operating year. Generic record-keeping forms were also established for the specific materials that were reported to be maintained over the course of the next year to make reporting easier in the future.

N. A steam generating facility requested a Title V study be undertaken by RCA professionals. The emission sources at this facility included natural gas and coal-fired boilers, coal stockpiles, fly ash and grate ash storage, and roadways. Control equipment and efficiencies were identified as well. The major emissions from this facility were total particulate (TP) and sulfur dioxide (SO2). Emission factors were obtained from current permits and stack testing. Non-permitted source emission factors were derived by using best engineering judgments based on EPA standards. Calculations determined this facility to be Title V regulated. Recommendations were made on how to operate under Title V, or change operations in order to attain minor status.

O. A Title V study was conducted by RCA professionals for a facility with high VOC and HAP emissions. The study was divided into three phases. Phase 1 involved identifying more than thirty sources of air emissions, both point source and fugitive. This included incinerators, cleaning chemicals, UST's, ovens, and individual operating lines. For each emission source, a specific pollutant or HAP was identified in conjunction with Title V requirements. All permits and MSDS's were also collected for any of the identified sources. In Phase 2, emission factors were determined for each of the pollutant sources through federally enforceable permits, a mass balance, and EPA's AP-42 manual. With additional operating data for each of the sources identified in Phase 1, calculations were completed to determine the tons per year of specific pollutant emitted per source. The final phase involved collating the data into a report along with a facility-wide emissions summary for VOC's and HAP's on both a potential and actual basis. Recommendations were made concerning the facility's options under Title V and updating or acquiring any additional permits to maintain facility compliance.

P. RCA professionals completed a Title V study for an automobile component manufacturing facility. Sources identified at this facility included holding furnaces, die cast machines, shot blasters, and air handling units. Control equipment, such as bag houses, was also identified, along with its efficiency and associated processes. Particulate, NOx, and HAPs were the major pollutants. In Phase 2, Federally enforceable permits contained emission factors. For some sources, permit emission factors were deemed out-dated, therefore stack testing was performed to obtain a more accurate representation. Calculations for each source, in tons per year (tpy), were completed according to the type of pollutant emitted. Once these calculations were collated into a facility-wide emissions summary, a major or minor source determination was made. Even though this facility was a minor source, RCA professionals made recommendations to update existing permits and to update record keeping procedures for identifying major and minor status under Title V in the future.