Certificates of Approval, Licences and Permits

Mr. Lethbridge has extensive experience in developing strategic approaches to obtaining Certificates of Approval that ensure operational flexibility for the facility while clearly demonstrating the ability to maintain compliance with regulatory requirements both now and in the future.

Projects have included:

• Basic Comprehensive CofA for an unintegrated Steel Mini Mill; large Glass Fiber Insulation Manufacturing facility; Sintered Metal manufacturing facility; etc.
• Major expansion of a sodium silicate manufacturing plant with multiple processes
• Thermal destruction device for condensate and exhaust from chemical reactors
• Complex consolidation of overlapping and conflicting approvals for several large manufacturing plants resulting in greater operating flexibility
• Conversion of large industrial furnaces from air/gas to oxygen fired burners
• Large Bioremediation processes for a chemical and resin manufacturing facility including air and waste management approvals.
• Carbon black manufacturing plant
• Fuel additives blending and processing plant
• Several pharmaceutical manufacturing facilities
  

Emission Inventories

Mr. Lethbridge has developed the emission estimation module of the LEHDER Environmental Information Management Service (LEIMS). Based on the LEIMS module, emission inventories are for a wide range of industrial facilities that allow the proponent to predict both short and long term emissions.
He has prepared Emission Summary and Dispersion Modeling Reports to support both CofA applications and STAC submissions; prepared annual emission estimate and reports for NPRI; and annual, smog season and quarterly reports for O.Reg. 127.

Some of his clients include:

• Large nitrogen based fertilizer manufacturer based in Courtright, Ontario
• Glass fiber insulation manufacturing facilities in Ontario, Alberta and Quebec
• Steel Mini Mill based in Cambridge, Ontario
• Glass textile manufacturing facility based in Guelph, Ontario
• Polyester resin manufacturer located in Guelph, Ontario
• Fuel additive manufacturing and blending facility in Corunna, Ontario
• Large Petrochemical facility located in Corunna, Ontario
  

Process Assessments

Mr. Lethbridge has conducted process assessments of various operations to address specific concerns.
Some of these assessments have included:

• Conducted an evaluation of a furnace operation which included speciation and quantification of particulate emissions, particle size determination to determine causes of elevated opacity. The study determined that sodium sulphates present as tramp ingredients in the raw materials were the most significant contributor to opacity as a condensing fume.
• Developed and demonstrated air pollution control system which reduced particulate emissions by 30% through use of pollution prevention techniques.
• Conducted pilot plant trials of wet ionizing precipitators to control emissions from thermoset polymer curing process. Trials culminated in the successful selection of scrubber which significantly reduced opacity and particulate emissions when installed in two manufacturing plants.
• Prepared a mass balance for metals and elements on a nickel smelter to predict distribution of material inputs to product and various by-product and waste streams including air discharges. The outcome of the study is used for raw material selection and annual reporting to ARET, NPRI and Reg. 127.

Odour Evaluation Studies

• Managed odour evaluation of Ontario chemical plant to develop compliance program. Program included evaluation of process emissions for both odour strength and chemical definition, identification of prevention and control options, obtaining necessary approvals for control device and performance testing.
• Conducted odour evaluation of large California insulation manufacturing facility to develop solutions to eliminate odour complaints. The program elements included ambient odour survey in neighborhood of plant, evaluation of process emissions for odour strength, modeling of multiple sources to prioritize emission sources for abatement plans, and identification of prevention and control options. A testing program identified the substance responsible for odourous emissions. A material substitution option was demonstrated to eliminate odour emissions. The solution has been implemented. No odour complaints have been received in over six months.
• Conducted odour assessment of a corn processing facility to identify the sources that contributed to ground level odour off site.
• Developed an odour abatement program at a large Central Ontario manufacturing facility to develop solutions for odour complaints from an organized citizens group. A key element of the program was the development of an environmental complaint procedure to facilitate communications between concerned citizens and operating facility management. Solutions included extension and/or reorientation of stacks for improved dispersion, and material substitution to eliminate odourous materials.

Air Dispersion Modeling

Mr. Lethbridge has performed and managed air dispersion modeling studies using regulatory models including ISCST3, ISCSTPrime and AERMOD. Most of these studies have required the development and assessment of potential solution options to maintain or obtain compliance with regulatory standards or corporate objectives.

Facilities assessed include carbon black manufacturing facility; glass fiber insulation manufacturing facilities; steel mini mill; glass textile manufacturing facility; large appliance manufacturing plant; surface metal plating chemical manufacturer; sodium silicate plant, uranium refining facility; etc.

Jurisdictions where the modeling studies were undertaken include:

• Ontario
• Quebec
• Alberta
• Texas
• California
• Wyoming
  

Property Liability Management

Site Investigation and Remediation

• Conducted many Phase I investigations for real estate transactions and due diligence programs.
• Conducted and managed Phase II investigations and Phase III management plans for large Ontario industrial sites. Concerns included phenols, metals, PAHs, DNAPLs, petroleum hydrocarbons and solvents. Extensive programs undertaken include the following:
  • chemical producer with multiple spill areas of DNAPL and petroleum hydrocarbons
  • manufacturing site with historic foundry operations
  • research and development centre
  • manufacturing site with onsite disposal of waste materials including metals and organic

Property Stewardship

• Conducted proactive assessment of a large manufacturing complex which identified poor material storage and handling practices which potentially could contribute to significant liability in the event of a spill or release.

Environmental Management and Compliance Systems

Environmental Audits

• Conducted many Phase I investigations for real estate transactions and due diligence programs.
• Conducted and managed Phase II investigations and Phase III management plans for large Ontario industrial sites. Concerns included phenols, metals, PAHs, DNAPLs, petroleum hydrocarbons and solvents. Extensive programs undertaken include the following:
  • chemical producer with multiple spill areas of DNAPL and petroleum hydrocarbons
  • manufacturing site with historic foundry operations
  • research and development centre
  • manufacturing site with onsite disposal of waste materials including metals and organics

Property Stewardship

• Conducted proactive assessment of a large manufacturing complex which identified poor material storage and handling practices which potentially could contribute to significant liability in the event of a spill or release.

Education and Professional Memberships B.A.Sc. Chemical Engineering, University of Waterloo, 1979 Member, Air and Waste Management Association Member, Professional Engineers of Ontario Trainer, Certificates of Approval, Air Dispersion Modeling, NPRI and O.Reg. 127 reporting etc.