Introduction

RCA Management Inc. is an Ohio-based environmental consulting and strategy firm. RCA provides complete, professional EHS evaluations and strategic planning in many areas; including managing stack testing, EHS auditing, EPA air permitting - including Title V, environmental assessments, indoor air monitoring (IAQ), ecological wetlands, physical safety, and industrial hygiene. With over 75 years of experience in the EHS fields, our firm recognizes and responds to a need for cost-effective and comprehensive solutions. By providing quality service and continuously expanding its knowledge of relevant technologies and regulations,

RCA expands its capabilities to meet the demands of today’s most complex EHS issues.
Not many Companies can boast of such accomplishments, especially EHS service Companies. Here at RCA Management, we truly are a group of professionals; we share in the accomplishments of each other to better serve our clientele. We could not be here to celebrate this accomplishment if it wasn’t for you. Together we have worked to reach solutions to your pollution and safety problems.

With combined professional service exceeding 75 years, we are able to provide professional environmental, health and safety solutions based on our experiences and certifications, but we are not finished; we still are achieving milestones others just wish they could. Our professionals were the first in the nation to conduct air emission testing under the Secondary Aluminum MACT Standard.
 
 
We also have Certified ISO 14000 auditors for those companies in need of environmental managements systems (EMS) certification, consistent with their business differentiation strategies. We have also expanded our engineering expertise by adding to our staff graduate engineers including P.E. certification and Masters degree.

Additionally, to assist in incorporating environmental and business strategies we have onboard a graduate chemist with an MBA degree. So as you can see we truly are in business to help your business.

We are constantly self-evaluating to achieve the right mix of technical professionalism. High quality work, is what we strive to deliver. To that end we have in place management teams with new and innovative compliance strategies and business solutions based on current compliance regulations. Additionally, we review on a daily basis, current regulatory, business, and governmental activities through the use of internet, email, trade association technical committee membership, professional associations, and periodic publications for the latest updates.

As new regulatory enforcement strategies emerge, RCA’s innovative approaches will quickly emerge as the best solution. We really are your “part time/full time” compliance managers. RCA’s professional staff includes engineers, environmental managers, chemists, industrial hygienists, and technicians who are experienced in aspects of State and Federal regulatory compliance. This experience allows RCA Management Inc. to offer quality EHS services in the following areas:

- Measurement and Analysis of Stack Emissions
- Design and Selection of Pollution Control Equipment
- On-site Investigative Inspections of Pollution Equipment
- Industrial Hygiene Investigations
- Indoor Air Quality Sampling and Testing
- Safety & Health Written Programs and Training
- Water Quality Analysis and Related Studies
- Air Pollution Modeling and Permitting
- Title V Permitting
- Compliance Auditing
- Resource Conservation and Recovery Act (RCRA)
- Water Pollution NPDES Permits
- Storm Water Pollution Prevention Plan (SWPPP)
- Spill Prevention Control Countermeasures (SPCC)
- Real Estate Site Assessments (Phase I, II, III)
- Underground Storage Tank (UST) Removals and Closure Plans
- Commercial/Industrial Site Remediations
- Groundwater & Wastewater Sampling and Analysis
- Asbestos Inspection and Abatement Services including AHERA
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA/SARA)
- ISO 14001 (Environmental Management Systems)

Our regulatory expertise and technical knowledge gained through training, education, and experience, combined with our technical staff, provide our clientele with the most accurate and up-to-date information in the EHS fields today.

The experienced professionals at RCA Management Inc. receive extensive professional training and have received certification in many areas, including the following:
- Certified Environmental Professional
- Certified Hazardous Materials Manager
- Certified Environmental Inspector
- Certified Environmental Trainer
- 40-hour OSHA Training - Hazardous Waste Site
- Asbestos Abatement Supervisor
- Asbestos Building Inspector
- Hazardous Waste Operations/Emergency Response
- Air Pollution Training Institute
- Visible Emission Evaluator
- Air Pollution Dispersion Modeling
- Lead Inspector Training
- Occupational Respiratory Protection
- Industrial Noise
- Environmental AssessmentsTo maintain its high level of quality, RCA Management is committed to the continued implementation of programs that will ensure accurate, reliable, and complete data. RCA’s personnel are knowledgeable and experienced in QA practices and are able to respond and resolve EHS problems that may occur.

Professional Qualifications

RCA Management Inc. is dedicated to providing quality, professional services to its' clientele. To this end, the team of professionals that RCA employs is comprised of highly educated and qualified experts committed to providing the level of service that is expected. RCA Management Inc. can dispatch any number of staff members to ensure that a project is completed in a timely and professional manner.
RCA Management Inc. services nearly all industrial categories. From simple wastewater sampling to the most complex air emissions testing, our personnel specialize in meeting the needs of each industry. This section presents biographical sketches of key personnel involved with the Consulting, Evaluation, Engineering, and Testing services offered by RCA Management Inc. In-house and on-the-job training, as well as seminars and workshops, keep RCA Management employees apprised of current regulations and technical issues. Following are brief resumes for key personnel. Full resumes for these personnel are available upon request.

Robert S. Anderson
President

Mr. Anderson has over 30 years professional experience in the EHS industry throughout the United States. In addition to founding RCA Management Inc., Mr. Anderson worked with Envisage Environmental. Prior to Envisage Environmental, Mr. Anderson worked for the EPA as a Source Sampling and Ambient Air Monitoring Supervisor. Mr. Anderson has a Bachelors Degree from Cleveland State University. He has lectured on a variety of air pollution topics at Case Western Reserve University, Kent State University, the University of Akron, and at several Industrial Conferences. He is a member in numerous professional organizations and maintains certification in many areas of pertinent training.

Michael D. Coker
Environmental Consultant

Mr. Coker has over 25 years experience in industrial environmental project management. Previously he held environmental positions in the specialty chemicals industries and EPA. Mr. Coker received a Bachelor of Science in Chemistry from Piedmont College, and a Masters in Business Administration from Baldwin Wallace College. Areas of expertise include source sampling, remedial actions, underground storage tank removals, training in the transportation of hazardous chemicals and waste, property transfer evaluations, Superfund cleanups, Title V, SARA, RCRA, and air permitting. He has presented papers and published writings, concerning pollution control to numerous industrial professional organizations.

Ray Zucker
Environmental Consultant

Mr. Zucker has over 20 years experience in the environmental and engineering field and received a Bachelor of Science in Chemical Engineering from the University of Detroit and a Masters Degree in Chemical Engineering from Cleveland State University. His background includes wastewater treatment, hazardous waste management, and solid waste management. Mr. Zucker specializes in water/wastewater and Hazardous Waste programs, Title V, SARA, RCRA and Air Permitting.



Project Experience


We at RCA Management Inc. are dedicated to quality and integrity. Our RCA Management professionals have performed thousands of EHS projects for government and industry. A list of selected clients is presented below. Additional clientele, projects, and references may be obtained upon request.

Republic Steel USEPA
Elkem Metals Wright-Patterson AFB
LTV Steel General Services Admin.
Elyria Foundry Rickenbacher ANGB
Youngstown Thermal Loring AFB
Kirkwood Industries First Energy (former CEI & Ohio Edison)
Lester Precision Die Casting American Steel Foundries
BP Oil UCAR Carbon Co.
General Electric Co. TRW
Goodyear Tire & Rubber GenCorp.
Alcoa Avery-Fasson
Republic Engineered Systems Marathon Oil
Sajar Plastics Oatey Co.
Lesco Inc. Shell Sands
Denison University Western Reserve Mfr.
Stone Creek Brick Co. Victory-White
Anchor Fasteners & Bedford Wire Co. River Recycling
CitiCorp. Real Estate Bank One, Cleveland
Soprema USA Morgan Matroc
Grubb & Ellis CRESCO
National City Bank Cleveland State Univ.
Ohio University Coven-Goldman Associates
Reeco Martin Marietta
Stone Container Corp. Kent State University
Oberlin College Clow Water Systems
Packaging Corp. of America PPG Industries
North Star Steel Warren Consolidated
AIMCOR Empire Detroit Steel
Copperweld Steel Latrobe Steel


Several representative project descriptions are presented below. Because of RCA Management’s respect for client confidentiality, information regarding the client has not been presented. If more information and/or references are desired, please contact RCA Management Inc. for assistance.

A. RCA Management’s personnel have provided management and source sampling services to the Ferro Alloy Association for the purpose of developing emission standards for their industry. The approach was to sub-categorize the industry and set a particulate limit (as a surrogate for HAP metals) for each subcategory in the format of the New Source Performance Standards (NSPS) for this industry. The particulate limits being developed are based on results of emission testing from various ferro alloy facilities. During this project RCA’s staff members sampled emissions from five facilities falling into the above classification. The project was successful and is being reviewed by the USEPA.

B. The Aluminum Association and the EPA Office of Air Quality Planning and Standards (OAQPS), Standard Documentation Section, Industrial Studies Branch, have been working jointly to obtain accurate information on the emissions of processes involved with the Secondary Aluminum Production Source category. Members from RCA’s team agreed to participate in this joint effort for the purpose of establishing Air Pollution MACT standards. The EPA identified several facilities located throughout the U.S. to participate in the Air Task Force of the Aluminum Association. These facilities were chosen because the furnaces, coupled with the air pollution control units, were thought to be representative of the Best Existing Controlled processes. The purpose of the testing was to obtain accurate emission rate data from several processes. Specifically, to determine the emission rates entering and exiting the controls. Testing parameters included total suspended particulate matter (TSP), metals, hydrochloric acid (HCL), total hydrocarbons (THC), hydrogen fluoride (HF), chlorine (Cl), dioxins/furans, and carbon monoxide (CO). In addition, visual determinations were made of the opacity of emissions exiting the controls and fugitive emissions around each furnace.

C. Upon receiving numerous complaints from office employees concerning headaches, dizziness, and nausea, RCA professionals were contacted to perform an indoor air quality analysis. The air quality survey included airflow testing from the air conditioning ducts within the office area and eight hours worth of air sampling for CO, relative humidity, and temperature. Further, employees were interviewed within the area of complaints and without, an inspection of the general office area was completed, and records were reviewed concerning dates of the complaints. A report was generated detailing all sampling results and information gathered while on-site. Recommendations were made based upon these results and information that ultimately led to a correction of the problem area.

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.