REPRESENTATIVE PROJECTS
 
Bruce Carter Associates has extensive past work in the following areas:
 

 
 

Site Assessment and Remediation Projects

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BCA provided site remediation and environmental engineering services at more than 400 sites in thirty-one states (plus Puerto Rico). 
 
* Environmental compliance and risk reduction for metal fabricating firm, with facilities in Indiana and Texas. To date, the work has involved preparation of state air permits, FESOPs, Title V permits, emissions inventories and statements, storm water pollution prevention plans and waste minimization plans. The project has also included preparation of SPCC plans, OSHA compliance regarding the handling and disposal of paint room materials, hazardous waste generation, and AST's and UST's. 
 
* Environmental and OSHA compliance assessment for a food processing facility in Indiana. To date, the project has included the preparation of an emissions inventory, state air permits and a SPCC plan. 
 
* Remedial Investigation and Feasibility Study for the closure of the waste disposal site of the former Ingram-Richardson plant in Frankfort, IN. Work was performed at the site, a top ranked state-listed superfund site (CERCLIS), under a work plan negotiated with the state. The site contains an estimated 35,000 cubic yards of waste, including porcelain enameling frit, which contains high concentrations of numerous heavy metals. 
 
* Environmental Site Assessment and remediation coordination and observation of many industrial facilities preparing for the sale or refinancing of property in sixteen states. The projects involved the identification of potential environmental hazards/liabilities and coordinating the removal and disposal of potentially hazardous chemicals, wastes, wastewater, sludges, underground tanks, transformers, asbestos, contaminated equipment, soil and water as necessary. 
 
* Remedial Investigation and Feasibility Study for an industrial site in Rockford, Illinois, where underground tanks had leaked approximately 7,000 gallons of petroleum solvent, contaminating the soil and groundwater. Remedial options included groundwater pumping and aeration, soil vapor extraction, in-situ bioremediation, in-situ hot air stripping, containment, etc. 
 
* Design, Pilot Testing, installation and operation of a soil vapor extraction (SVE) system at an industrial facility in Louisville, KY that contained more than 7 tons of a chlorinated solvent in the soil at the site. The SVE system draws 530 SCFM of air through the soil from a subsurface area up to 1,000 feet in diameter to remove the solvent from the soil. Farlow Environmental has operated up to four soil vapor extraction units. 
 
* Environmental Site Assessment and subsequent preparation of an RI/FS, remedial design, regulatory coordination, contractor bid specifications and observation of remediation for a closed industrial site in Dallas, TX where chlorinated solvents were found in the soil beneath the plant floor and in the groundwater. With the approval of the Texas Water Commission, the soil remediation included on-site aeration of over 750 cubic yards of soil. Our studies indicated, however, that most of the groundwater contamination near the site was attributable to an off-site source. 
 
* Coordination of the removal or abandonment of more than 400 underground tanks and the removal and/or remediation of associated contaminated soil at commercial/industrial sites in twenty-two states. This work included regulatory notification, coordination, permits, contractor coordination and bid specifications, observation of removal and disposal of tanks, wastes and contaminated soils, analysis of excavated areas and performance of subsequent environmental work, as required. 
 
One such project, initiated as an environmental site assessment, involved the removal of three fuel tanks at a closed industrial facility in Cambridge, MA. More than 1,000 gallons of fuel oil, which had previously leaked around one tank into the surrounding soil, was recovered and approximately 1,500 tons of contaminated soil were excavated and removed from the site. Beyond considerable client, regulatory and contractor coordination, we evaluated soil disposal and remediation alternatives with respect to least cost and (severe) time constraint objectives. The final remediation included steam injection to mobilize and recover fuel oil that had migrated beneath the adjacent building. 
 
* Site investigations and technical assistance to legal counsel on a multi-million dollar lawsuit against several industries, regarding the contamination of an aquifer used for public water supply. This project involved various site investigations, soil and groundwater sampling and analysis, review of state and federal agency records, collection of geologic data, development of groundwater flow and solute transport models, development and analysis of a large data base, preparation of affidavits, etc. Our work on this project spanned a period of about five years. The lawsuit was resolved to the satisfaction of our client, due to the strength of the technical case we developed. 
 
* Remedial Investigation and Risk Assessment (RA) of industrial site in Cincinnati, Ohio with separate phase tetrachloroethane (PCE) in the groundwater beneath the site. The RA included an exposure assessment, evaluation of PCE fate and transport, a toxicity assessment and a risk characterization. 
 
* Investigation and Risk-Based Corrective Action (RBCA) for a site in Kokomo, Indiana with petroleum contaminated soil. The corrective action plan included intrinsic bioremediation and groundwater monitoring. 
 
* Insitu bioremediation of more than an acre of diesel contaminated soil at a trucking facility, through the application of bioventing. The soil contamination resulted from leaking underground storage tanks and a surface spill. Free product was measured to be as much as 30 inches on the groundwater. Farlow Environmental designed the system and obtained state approval for the remediation design. Remedial operations at the site succeeded in removing greater than 500 gallons of free product (diesel fuel) before full implementation of the bioremediation system. 
 
* Various solid waste landfill projects including the permit applications and designs for new landfills, a vertical expansion and a horizontal expansion, groundwater monitoring, methane monitoring, design and testing of a compacted clay soil liner, computerized annual volume calculations, investigation of potential soil borrow sites, etc. The designs have included synthetic impermeable membrane liners and leachate collection systems. 
 
* Planning, design and field investigations in support of three RCRA closure projects in Indiana. The projects have included developing and obtaining IDEM approval for closure plans, performing investigations, monitoring remediation and certifying clean up activities.
 

Air Emissions Consulting Projects

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BCA provides continuing air emissions consulting services to more than 150 manufacturing facilities located throughout the country. BCA places a strong emphasis on knowledge of local regulations, relationship with the regulatory agency and training to address many complex air emissions for its clients. Some examples of work experiences are: 
 
* A Tennessee-based boat manufacturing company planned to relocate to a new facility. Due to a planned increase in boat production and the addition of a personal watercraft line, the facility needed a permit from the Tennessee Department of Environment and Conservation to emit 330 tons of VOC. Permitting for this facility was complicated by its proximity to the Great Smoky Mountains National Park and the Joyce Kilmer/Slickrock National Wilderness Area. BCA prepared a PSD application for the proposed facility. Reviews by the US Department of Interior, the US Forest Service and the USEPA were required. Permitting for this facility required the preparation of a Best Available Control Technology (BACT) analysis, ISCST2 modeling for styrene, and toxic air screening for all hazardous air pollutants. The PSD included an analysis of impact of the facility on air quality-related values of these Class I impact areas. 
 
The PSD application was submitted on October 13, 1993, and reviewed by the various agencies and considered complete on December 3, 1993. A public hearing was held on January 10, 1994, and the permit was issued January 17, 1994. 
 
* BCA was requested to conduct ISCST2 modeling for styrene emissions from three (3) fiberglass boat manufacturing facilities at two locations in Maryland. The modeling was required to demonstrate compliance with the State of Maryland's ambient air standards for existing emissions at two of the facilities. Modeling was performed at the third facility to select an appropriate stack height for a proposed ventilation system. 
 
* A Texas-based tub and shower manufacturer had received styrene odor complaints from the Texas Air Control Board (TACB). This facility needed to reduce off-site ambient styrene concentrations while still allowing for future increases in production. BCA was retained to complete a Best Available Control Technology (BACT) Analysis and demonstrate compliance with strict ambient styrene concentration limits imposed by the TACB for odor complaints. This project required the use of documented emission factors specific for the facility's operations, completion of a BACT analysis, and performance of ISCST2 dispersion modeling to demonstrate compliance. SCREEN2 dispersion modeling was used to determine proper stack height for the proposed ventilation system. 
 
* An Oregon-based boat manufacturing facility was expanding its operations and moving to a new facility. As a result, the facility was required to perform a Best Available Control Technology (BACT) analysis to comply with the Oregon Department of Environmental Quality (DEQ) air permitting requirements. BCA was retained to do the necessary BACT analysis that was subsequently submitted and approved by the Oregon DEQ. 
 
* An Indiana-based fiberglass fabricator was faced with an immediate increase in production demand, requiring a fast-track permit application. BCA was retained to obtain the necessary permit. BCA entered negotiations with the Indiana Department of Environmental Management (IDEM) and successfully negotiated a permit and a timetable that met the fabricator's production requirements. 
 
* An Indiana wood siding prefinisher contracted BCA to review its permit application previously submitted to the Indiana Department of Environmental Management (IDEM) by another consultant. BCA was also requested to respond to IDEM's requests for additional information and to complete a Best Available Control Technology (BACT) analysis. In addition, BCA designed an appropriate ventilation system for the flow-coating operations. 
 
* In April 1994 BCA assisted thirty-eight Indiana manufacturers, in complying with Indiana's emissions inventory reporting requirement. Each facility was required to assess its emissions of criterion pollutants, and provide information regarding its processes. The facilities were requested to calculate and provide data with respect to anticipated hazardous air pollutant (HAP) emissions. 
 
* An Indiana wood RV-component manufacturer requested that BCA prepare a permit application for its surface coating and milling operations. In addition, BCA reviewed the efficiency of the facility's existing dust collection system and the installation of an additional system. 
 
* BCA assisted an Indiana wood Venetian blind-slat manufacturer in the design review and permitting for an automated wood coating system. The high-volume system, developed by a Chicago firm, is designed exclusively for application of water-based coatings. 
 
* As a result of an internal audit, an Indiana-based recreational vehicle manufacturer discovered that a permit was needed for their surface coating operations. BCA was retained to complete the required air permit application and do a Best Available Control Technology (BACT) analysis for this facility. 
 
* An Indiana facility of an international transformer manufacturer was requested by the Indiana Department of Environmental Management (IDEM) to update an existing permit to include omitted operations. BCA was retained to conduct an emissions inventory and complete an air permit application for surface coating and particulate emissions at this facility. 
 
* An international manufacturer of organic chemicals retained BCA to update their existing air permit and complete an application for a new process at their Indiana-based facility. 
 
* A previously registered Indiana-based flexographic printing company requested BCA to evaluate their regulatory compliance at their present operations. BCA was also requested to determine the regulatory status for a proposed expansion that would increase the facility's label production by 54 percent. At the facility's present operations, BCA determined the facility would require a permit from the Indiana Department of Environmental Management and be subject to RACT standards that limit the amount of VOCs contained in the inks applied to the label substrate. BCA recommended the use of water-based inks that would decrease the facility's VOC emissions by 66 percent. The company accepted BCA's recommendations and implemented a water-based ink process that allowed the company to maintain its registered status after the expansion. This facility received the Indiana Governor's Award for Pollution in 1995. 
 
* An Indiana-based furniture manufacturer planned to relocate its chair manufacturing facility to its consolidated operations in southern Indiana. A PSD application was prepared and approved by IDEM requiring ISCST2 Modeling, reactive plume modeling (RPMIV), and toxic air screening for all hazardous air pollutants. The PSD included an analysis of the impact of the facility on air quality related values in this Class II impacted area. The PSD application was filed on November 18, 1994 and a final PSD permit was issued in March 1995. 
 
In addition, the PSD required post construction monitoring of ozone. BCA is currently conducting ambient air monitoring of ozone according to IDEM and EPA requirements. 
 
* An Indiana-based manufacturer of diesel engines requested BCA to prepare Part 70 permit applications for three of its manufacturing facilities. The permit applications required preparation of an emissions inventory, development of permitting strategy to ensure long term growth of the facilities, and the preparation of compliance monitoring plans in accordance with IDEM guidance. 
 
* Part 70 Permit Applications -- In 1995 and 1996 BCA prepared over 40 Part 70 Air Permit Applications required of manufactures under Title V of the 1990 Clean Air Act Amendment. 
 
* FESOP Permit Applications -- In 1996, BCA prepared more than 30 FESOP Applications required of manufactures under Title V of the 1990 Clean Air Act Amendment. 
 
* Bruce Carter Associates, L.L.C. developed a training seminar format and presented Title V seminars at numerous locations around the state of Indiana. The seminars were designed to assist small to medium size manufacturing companies in their understanding of the "Title V" permitting requirements of the 1990 Clean Air Act Amendments. BCA and the Indiana Chamber of Commerce participated in a series of seminars in Indianapolis, Fort Wayne and Bloomington; presenting information on "Title V" to a broad industry group. To date, over five-hundred participants have attended Title V seminars offered by Bruce Carter Associates, L.L.C. For more information, please contact our office.
 

Industrial Hygiene, Safety and Training Experience

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BCA staff has historically provided chemical safety training and industrial hygiene services to a wide variety of clients. Such work has emphasized hazardous waste site worker training for OSHA compliance, building surveys/inspections for asbestos and air quality monitoring. In 1992, BCA began providing comprehensive Health and Safety related training to a variety of our clients. Some examples of our experience are: 
 
* Periodic testing of compressed breathing air for an electronic circuit board manufacturer. 
 
* Preliminary investigation and sampling for a chlorinated solvent air contaminant source at an attenuator manufacturing and assembly plant. 
 
* Health and Safety plan preparation and air monitoring during the investigation and excavation of highly contaminated soils, including potential carcinogens and petroleum products. 
 
* Industrial hygiene surveys and sampling at various industrial sites. 
 
* Asbestos surveys, bulk sampling, air monitoring and third party oversight for asbestos removal projects at buildings in several states (AL, GA, IL, IN, KY, LA, MA, PA and TX). 
 
* OSHA Audits for various industries. 
 
* Emergency response training for in-house spill response teams at major facilities including pharmaceutical, petroleum refining, agribusiness and resin manufacturing companies; including training for over 200 oil refinery personnel in OSHA 40-hr and emergency response operations. 
 
* OSHA required 40-hr. training for workers on hazardous waste sites. Courses have been provided both at BCA's training facilities and at the clients site. 
 
* OSHA required 24-hr. training for hazardous waste TSD facilities. 
 
* OSHA Hazard communication standard training for a major manufacturing facility. 
 
* DOT HM-126F training for Safe Transportation of Hazardous Materials at facilities and sites throughout the State of Indiana and in various other states.
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