Plant Decommissioning – A leather tannery operating on a major river for over 140 years had outlived its efficient productivity and operations had been moved to a new facility. Performance personnel provided project management and on-site supervision to the decommissioning of the tanning process, waste treatment process, and facility clean-up operations. The project planning included process equipment clean out; hazardous material removal; and cleaning of all tanks, pits, drains, pipes and rooms as the operation was closed down.
Treatment of almost all process waste and clean-up waste materials were performed on-site in the wastewater treatment plant. Once the waste materials were treated, the wastewater plant was closed down in order to provide self-treatment of as much of the material as possible. After the facility was cleaned, a new stormwater system was developed, implemented, tested and approved by the state regulator. Management of this decommissioning, using the efficiency of on-site processes, allowed the project to be completed ahead of schedule and 30% under budget.
Compliance Assessments – Performance personnel have performed many different types of compliance assessments. One client requested a mock agency inspection to evaluate the facility personnel responses and where the company needed to focus resources to improve their training and compliance metrics. Inspectors arrived with a letter from the company president telling them to treat the inspectors as if they were regulators. The project was completed with a report identifying facility compliance to company inspection policies and regulatory issues.
Several clients use Performance personnel to perform corporate facility assessments for compliance with EHS regulations and corporate policies. These are very effective for providing an independent evaluation of the facility's compliance status as well as provide valuable suggestions for improvement of the facility operations and company systems. Several other clients use our compliance assessments as their ISO 14001 third-party audit to document compliance.
Emergency Response Plans – Performance personnel developed an emergency response plan for an entire community college, including a fire and emergency evacuation plan and Homeland Security terrorist response. We also developed a flipchart quick-reference guide for teachers and staff, response flowcharts for first responders, and an instructor training program and student awareness program.
Many industrial clients have used Performances "One Plan" Approach to integrate their spill prevention control and countermeasure (SPCC), storm water pollution prevention plan (SWPPP), pollution incident prevention plan (PIPP), and hazardous waste contingency plan into one document. This facilitates simplified updates of shared information like contact names, facility maps, and process changes when needed. The program includes the plan development, document creation, design of first responders guide, and training for the responders and employees.
Safety Programs – Performance personnel have developed safety programs to meet client needs based on their operations. Several clients have processes that trigger process safety management (PSM) system requirements. We have performed process hazard analysis (PHA) using the what-if checklist and failure-mode effects analysis for solvent-based adhesive processes to incorporate process modifications. We performed PHA and PSM audits and revisions for several clients. Applicability determinations have been incorporated into our compliance assessment project to document the client's status.
Performance has developed or consolidated applicable safety programs into a comprehensive safety policy and procedures manual for many smaller industrial clients. The safety manual provides a regulatory reference, practical guide for operation procedures, and a training system tracking matrix. We have provided the safety manager responsibilities as a contract service as well.
- Managed major water treatment process upgrade projects in Mexico and China. Treatment process added biological treatment capacity, which allowed the facility to recycle and reuse up to 90% of the treatment system output back into the plant water supply.
- Performance developed an Environmental Award program for industrial facilities globally to promote proactive programs including energy conservation, community outreach, byproduct recycling, and regulatory compliance.
- Performance developed a comprehensive safety and environmental program with training for all employees utilizing government grant monies.
- We performed FEMA and Hazwoper training for responders at a regional medical facility for community emergency response to natural disasters or acts of terrorism. We conducted several exercises to practice their response skills.
- Performed a comprehensive health and safety audit of a major pharmaceutical research facility to identify conformance with OSHA regulations company policies and OHSAS 18000 standards.
- Worked with a client performing safety audits, program development and training, resulting in MiOSHA SHARP award for safety.
- Performance obtained Title V Operating Permits for 13 compressor stations with negotiated conditions for operational flexibility. Several regulatory issues were overcome to provide maintenance operations to be performed without a permit modification.
- Performance permitted the installation of two turbine/compressor units at a large pipeline system. We obtained NSR/NSPS air permits and performed environmental inspection during construction and start up. Community noise surveys were performed to demonstrate minimal impact from installation of new equipment to meet FERC and local township requirements.
- Completed a system-wide asbestos inspection and abatement project at 13 compressor stations. The project included removal of thermal system insulation on hot water piping and exhaust stacks.
- Project-managed a response team to clean up contamination from a venting release. The area was approximately 1/2 mile wide by 5 miles long. Negotiated notice of violation with the state and EPA to a reduced penalty.
- Project-managed an investigation and remedial action for contaminated groundwater. Project included soil sampling, monitoring well installation and design/implementation of groundwater collection, treatment and disposal system with a wastewater evaporator.
- Developed and implemented natural gas fugitive emission reductions program for EPA Natural Gas Star program. Project included developing leak detection protocol and surveys documenting and correcting leaks at compressor stations and valve sites; investigation into new methods to control emissions; and calculating gas losses to report to EPA annually.
- Completed PCB remediation and negotiated clean closure with the state. Developed company-wide PCB investigation and collaborated with EPA on changes to TSCA regarding PCB use authorizations and removal standards.
- Project-managed a CERCLA drum site for a PRP group. Project included the location, excavation and repackaging of 3,700 buried drums; sampling, analysis and characterization of the waste material, and transportation and disposal of all drums and contaminated soils.
- Plant Expansion Management: Project manager for $1,600,000 plant expansion, which included design and construction of a new waste storage tank farm and improvements to waste treatment plant.
- Project-managed an Act 307 and LUST site. Project included removal of a leaking underground storage tank, testing and removal of contaminated soil, site restoration for reuse, and delisting petition to the state. This site has been delisted from the 307 list and removed from the LUST list.
- Prepared and submitted RCRA Part B and Act 64 operating license application to EPA and MDNR. Negotiated and revised the application to obtain issuance of both RCRA permit and Act 64 operating license on November 23, 1992.
- Project-managed an RCRA hazardous waste surface impoundment unit closure. The project included: removal and disposal of hazardous waste, liner and ancillary equipment; establishing background levels for constituents of concern; mapping soil contamination; sampling, analysis, excavation and removal of contaminated soil; and clean closure report certification for MDNR approval.