Composites Industry

For ACMA, ECRM prepared the following technical reports on behalf of the association's Government Affairs Committee.
- Guidance on Undefined Terminology in the Reinforced Plastic Composites MACT Rules.
- Non-Economic Impacts on the Reinforced Composites Industry of Emission Control by Oxidizer Systems
- Emission Control VS Pollution Prevention for Open Molding of Composites: Incremental Benefits and Impacts
- Technical Evaluation of Capture and Control at Three Composites Facilities
- Marginal Benefit/Impact Analysis: Control Versus Covers to Reduce Resin and Paste Mixing Emissions
    in the Manufacture of Reinforced Plastic Composites
- Potential Impact of Reasonably Available Control Technology Requirements on Composites Plants
- Pollution Prevention in Reinforced Composites Production vs VOC Control for New Sources: Technical Equivalence

- Comparison of MACT Standards for Surface Coating Operations
- Critical Review of TTE-Based Emission Test of Pultrusion Line
- Trip Report: Noble Composites Inc, Goshen IN (assessment of control feasibilty)
- New Source Review: A Primer for Composite Fabricators (rewritten to cover 2002 rule revisions)
- Guide to the Estimation and Permitting of Particulate Emissions from the Manufacture of Reinforced Plastic
- Impact of Styrene PEL Reduction on Composites Manufacturers in California (co-author)
- Designing Eco-Friendly Products - How Green Are Composites?

Dave Lipiro also participated in the following ACMA initiatives:
- Evaluation of emission studies to expand the Unified Emission Factors
- Critical review of emission tests used to support enforcement action
- Review of styrene health effects data
- Industry advocacy concerning proposed Ohio regulations
- Environmental life cycle assessment of composites

For CSP of Ohio, ECRM has helped secure air permits (Title V and other) for over over 50 emission units, developed permit compliance tracking databases, and developed facility risk reduction plans (integrating requirements for oil and hazardous substance management with storm water discharge management).

For Cadence Innovation, ECRM developed permit compliance tracking databases, assists in preparation of regulatory submittals, conducts environmental compliance audits of all plants on a three-year cycle, and helped implement the company's ISO 14001-compliant environmental management system.

For two pultrusion operations in Ohio, ECRM expedited issuance of "synthetic minor" permits exempting these plants from the RPC MACT rule. For two other pultrusion operations, ECRM developed MACT compliance assurance systems incorporating averaging of reduction credits and averaging of enclosure opening times. 

Consumer Products and Bakeries

ECRM has prepared permit applications for four commercial bakeries in Indiana, Ohio, and Massachusetts for T. Marzetti and New Horizons Bakeries. A statistical analysis of data used to derive two bakery emission factors (EPA ACT vs AIB) was prepared to justify use of the lower emission factor at three sites. In Massachusetts, an analysis of Best Available Control Technology (BACT) was prepared demonstraing that VOC control would not be cost-effective. ECRM also evaluated odor abatement options at this site. In Ohio, ECRM secured an air permit covering a critical expansion project, incorporating conditions that maximize operating flexibility and avoid triggering control requirements.

ECRM has helped secure air permits covering production of scented candles at Lancaster Colony Corporation's Candle-lite plant in Ohio, the largest candlemaking facility in the nation. To support this effort, models of VOC emissions from each process were developed and have been accepted by Ohio EPA.

Prior to founding ECRM, Dave Lipiro participated on compliance audits at three breweries for Anheuser Busch and four tobacco products plants for Philip Morris.


As a subcontractor to InteGreyted Consultants LLC (now Delta Environmental), ECRM participated in multimedia compliance audits of six power generation and distribution sites in New Jersey and Delaware, operated by Conectiv, a large regional utility. These were complex audits due to the many regulations affecting power plants, including NSR/PSD, Acid Rain, NSPS, and CAM.

Paper and Lumber

As a subcontractor to InteGreyted Consultants LLC, ECRM participated in comprehensive mulimedia environmental audits of paper mills operated by Kimberley Clark in Georgia and Vermont. ECRM also prepared permit applications for Taylor Lumber, and developed emission factors for individual sawing and woodworking processes.

Chemical and Pharmaceutical

ECRM participated as an InteGreyted subcontractor on two successive compliance audits of Abbott Laboratory's five-plant drug production complex in North Chicago, Illinois. ECRM was also asked to provide an executive-level review of compliance management systems at these massive and complex facilities.

ECRM conducted compliance audits of five plants acquired by the former BFGoodrich Chemical Company. Prior to founding ECRM, Dave Lipiro participated in audits of many of BFG's PVC, VCM, and elastomer plants then operated in the US.


For Alcan Aluminum, ECRM assisted the Warren OH rolled products plant to gain OEPA approval to modify its coating lines to eliminate use of hexavalent chromium. ECRM helped Alcan successfully negotiate issues related to the process discharge with OEPA and the Warren sewer district.