Project Experience
| Client/Project: |
Frontier Refining Inc. / Air Compliance Matrix |
| Project Location: |
Frontier's Cheyenne, Wyoming Refinery |
| Project Description: |
Frontier retained Rule to evaluate requirements of the air regulations
and Frontier's operating air permit application that are applicable to
Frontier's process operations and develop a mechanism to communicate
those requirements in a useable format to specific operations
activities. The completed regulatory/operations matrix is being used
by Frontier to write environmental sections in operations manuals and
as a basis for an environmental management system.
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| Client/Project: |
Guida, Slavich & Flores; Compliance Air Audit |
| Project Location: |
Petroleum Refinery |
| Project Description: |
Rule was retained by Guida, Slavich & Flores to conduct an air regulatory
compliance audit of various specific operational components at a
petroleum refinery. Rule collected and evaluated operational and permit
data pertinent to the refinery's compliance with the applicable state and
federal regulations for the National Emission Standard for Benzene Waste
Operations and Prevention of Significant Deterioration (PSD) permits
requirements.
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| Client/Project: |
Ultramar/Diamond Shamrock / RCRA Facility Investigation Management |
| Project Location: |
Commerce City, Colorado |
| Project Description: |
Rule is retained by Ultramar/Diamond Shamrock's Colorado Refining
Company (CRC) to serve as project manager for the implementation of a
refinery wide RCRA Facility Investigation (RFI). Rule's responsibilities
included advising CRC regarding agency negotiations, directing project
team technical activities, preparing and submitting technical reports,
interfacing with CRC's contract and in-house attorneys to develop
regulatory directions and technical approaches and representing CRC in
negotiations and forums with other oil companies participatory in related
RFI efforts.
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| Client/Project: |
Frontier Refining Inc. / MACT Compliance |
| Project Location: |
Frontier's Cheyenne, Wyoming Refinery |
| Project Description: |
Frontier retained Rule to assist the refinery in preparing for and
documenting its compliance with Refinery MACT I requirements. Rule
worked with Frontier to enhance certain environmental programs and
prepare Frontier's Notice of Compliance Status Report, annual emissions
inventory, fugitive emissions monitoring reports, toxic release inventory,
first MACT periodic report and other related compliance documents during
the MACT implementation and documentation period.
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| Client/Project: |
Tilly & Graves; Hydrocarbon Release Evaluation & Expert Services |
| Project Location: |
Denver, Colorado |
| Project Description: |
Tilly & Graves (T&G) engaged Rule to evaluate a large, industrial release
to groundwater that was posing a regulatory concern for the client's
down-gradient property. Rule's evaluation of historic release and
existing environmental data indicated the client should not be subject
to regulatory action. Rule, with Tilly & Graves presented our analysis
of the to the governmental agencies involved in the release and persuaded
the agencies that they had no basis to enforce against the client.
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| Client/Project: |
Holland & Hart; Regulatory Support and Management; Petroleum Refinery |
| Project Location: |
Rocky Mountain Area |
| Project Description: |
Rule personnel assisted client's counsel in the development of an
environmental strategy for a large petroleum refinery in the Rocky
Mountain Area. Rule's activities included meeting with the client and
clients counsel, assessing existing regulatory activities, including NOV's
if any; pending federal and state regulatory action; and in establishing the
clients business considerations with respect to the agencies actions.
Rule personnel developed and presented a regulatory strategy program that
identified regulatory options, evaluated option costs and benefits and
assisted the client and client's counsel in developing an approach for
presentation to the regulatory agencies.
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| Client/Project: |
Gardere & Wynne, P.C. / Valuation of Environmental Conditions |
| Project Location: |
1000 Oil and Gas Properties in Four Western States |
| Project Description: |
Rule was retained to provide a third-party valuation of the environmental
issues, if any, associated with approximately 1000 producing oil and gas
properties in a four-state area. Rule gathered historic release and
regulatory information; evaluated other author's assessments of the
environmental conditions and potential liabilities at the sites; and
conducted a valuation of other author's environmental mitigation cost
estimates for various groupings of wells, tank batteries and other oil
and gas properties. Rule provided its written opinions to counsel.
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| Client/Project: |
Faussone, Taylor & Bond P.C. / CERCLA Liability at a Refinery |
| Project Location: |
Michigan |
| Project Description: |
Fassone engaged Rule to provided expert witness services regarding the
practical aspects of groundwater contamination that might be caused by an
abandoned petroleum refinery relative to a solvent recycling facility.
Rule's opinions were based upon review of: existing site and area data,
applicable environmental regulations; historical activities at the site and
from surrounding industrial and commercial facilities; and opinions espoused
by other parties involved in the litigation. Rule presented opinions in
depositions regarding the site conditions. The case was settled prior to
trial.
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| Client/Project: |
Confidential |
| Project Location: |
Colorado |
| Project Description: |
At two of the client's manufacturing facilities, Rule worked under
Colorado's self-audit privilege to review certain construction and
operating documents, prepare emissions estimates and air permit
applications and negotiate construction permits and an operating air
permit.
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| Client/Project: |
Expectra-Berthoud |
| Project Location: |
Berthoud, CO |
| Project Description: |
Rule evaluated the wastewater treatment system compared to the
industrial wastewater permit conditions. Rule advised Expectra-Berthoud
regarding operating process efficiency eliminating system bottlenecks.
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| Client/Project: |
Adair Group, LLC. / Safety Program Development and Implementation |
| Project Location: |
Denver, Colorado |
| Project Description: |
Adair Group retained Rule to customize and implement a construction
safety program to Adair's specific needs and culture on a three-month
schedule. The program incorporates Adair's various construction divisions
and projects including wood-frame; steel erection and tenant finish
interior build-out. Rule implemented the program through corporate /
construction site training and provided supervisor competent person training.
A substantial portion of Rule's remuneration for this project is based
upon Rule's performance as judged by Adair.
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| Client/Project: |
Talbot Insurance Agency, Inc. / Sandia Casino Construction Project |
| Project Location: |
Sandia Pueblo, Albuquerque, New Mexico |
| Project Description: |
Rule was retained to assist Talbot in the development; implementation and
administration of an owner controlled insurance program (OCIP) at a $100MM
casino construction project on the Sandia Pueblo. Rule is providing a
full-time safety coordinator to represent the owner, Talbot, and the OCIP
on the construction site. The insurance carrier demonstrated the success
of the project safety performance by providing a substantial dividend payment
to the owner.
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| Client/Project: |
Duke Energy Field Services / Process Safety Information |
| Project Location: |
National |
| Project Description: |
Duke retained Rule to evaluate process chemicals and potential mixing scenarios at its numerous gas processing facilities across the nation, and develop process safety information (PSI) as required under the Process Safety Management OSHA standard. The PSI had to be presented in a format that was useable for training and emergency response at Duke's facilities and for use during hazard analysis required for process safety management.
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| Client/Project: |
A.J. Gallagher |
| Project Location: |
Western Kansas |
| Project Description: |
Rule was retained to evaluate an alleged contractor exposure to isocyanates at an auto body painting facility in a trade school in western Kansas. Rule's safety staff visited the site, collected workspace and personnel air samples during facility operations, and evaluated the physical and mechanical setting of the facility. The collected samples were analyzed for a variety of chemical constituents associated with auto body painting operations. The sample results were compared against a variety of regulatory and industry standards for exposure to isocyanates. Rule prepared a report describing the findings of the sampling effort and its conclusions concerning the issues addressed during the study for submittal to the client.
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| Client/Project: |
Heavy manufacturing client |
| Project Location: |
Greeley, Colorado |
| Project Description: |
Rule provided an analysis of safety process and operations for this heavy manufacturing facility. The deliverable product was a gap analysis, for the Owner's Board of Directors, regarding current operations compared to the requirements for OSHA Voluntary Protection Program (VPP) application. The report included strategies and defined the level of effort required for successful application to the merit level VPP. Subsequent projects for this client included environmental compliance evaluation for inventory reporting and an updated custom written safety program.
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| Client/Project: |
Residential concrete foundation contractor |
| Project Location: |
Denver, Colorado |
| Project Description: |
Rule was engaged by this contractor to assist and participate in their OSHA informal conference for citations and proposed penalties. The meeting resulted in a reduced settlement based on a hazard abatement plan and the demonstrated management commitment for safety process improvement by hiring Rule. The existing written safety program was reviewed and updated by Rule and translated into Spanish. Rule performs the function of the safety department providing strategic planning and ongoing safety training for management, supervisors, safety committee members and workers. Rule provides training for staff in record keeping, injured worker claim management, return to work program and OSHA compliance for residential construction.
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| Client/Project: |
Confidential Manufacturing Client |
| Project Location: |
International |
| Project Description: |
Rule developed a standard format for this client's MSDS'. Currently Rule is working with an
internal multi-discipline team to address end-user needs for MSDS' for all products produced. Because these products are intended for international markets the European community requirements for MSDS' information is required to be addressed by Rule.
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| Client/Project: |
PrintXcel |
| Project Location: |
National |
| Project Description: |
Rule has been retained by this national printing company to function as the interim safety manager to reduce injuries in 10 plants around the country. Assignments include: an in-depth analysis of injury causes, development of a standard written program, development of a standard audit form to establish a performance baseline and scoring system, training requirements, training local management in injury prevention techniques, delivery of training for safety committees and mentoring of in-house staff in safety management.
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| Client/Project: |
Colorado Contractors Association (CCA) |
| Project Location: |
Colorado |
| Project Description: |
Rule provides the trainer for the Traffic Control Supervisor (TCS) course and certification of successful candidates. A certified TCS is a required to be on the job and develop methods of handling traffic on Colorado Department of Transportation jobs. CCA is one of two certifying organizations recognized in Colorado.
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| Client/Project: |
Associated General Contractors of America (AGC) |
| Project Location: |
National |
| Project Description: |
Rule provides training for trainers on a National basis of the design and implementation of traffic control work zones. A portion of the training Rule provides is focused on adult learning and training techniques. Rule was also involved in the development of the updated course to reflect the recently adopted millennium edition of the Manual of Uniform Traffic Control Devices (MUTCD).
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| Client/Project: |
Educational facility |
| Project Location: |
Greeley Colorado |
| Project Description: |
Rule was engaged to assess a potential mold issue in a facility temporary building. After a detailed inspection and air sampling process a determination of the presence of mold was validated. Recommendations were developed and presentation of results was communicated to employees and board of regents.
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| Client/Project: |
Hinkle Law firm |
| Project Location: |
Denver Colorado |
| Project Description: |
Rule was retained to support litigation and opine on the report by another consultant on applicable standard use to determine the habitability of a rental property. An earth laboratory occupied the property for 20 plus years and left traces of heavy metals. Rule was able to determine applicable standards and develop via dialog with the lawyers a probable strategy to pursue the former tenant for damages based on good science and industrial hygiene testing techniques.
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| Client/Project: |
Hamilton-Sundstrand |
| Project Location: |
Denver Colorado |
| Project Description: |
Industrial Hygiene Services were provided to this Aerospace manufacturer. Air monitoring was completed in the plating operation to determine the air concentrations of contaminates. In complying with the updated respiratory standard Rule recommended the appropriate respiratory protection based on exposures. Review of work practices were reviewed and one on one coaching was completed for affected workers.
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