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At Sage Environmental Consulting, we believe that every project is an opportunity to earn your trust. Our collective experience allows us to see the big picture clearly, and our deep understanding of industry complexities helps us apply proven solutions.
We've promised nearly four thousand clients a quality product, completed in a cost-effective manner, with friendly service and no surprises. We've done it through the leadership of the following team:
A respected serial entrepreneur, Steve Probst is the proud founder of a number of successful companies in the Environmental Industry. In 1998, Steve founded his first company, Sage Environmental Consulting L.P, and has grown it from $0 to $49 million in total revenue over the past 17 years. Sage Environmental Consulting has been a 5-time Inc. 5000 honoree since its foundation, ranking #2832 on the list in 2014. In 2006, Steve facilitated the inception of Dexter Field Services, L.P, and has fostered its growth from $0 to $12 million in total revenue. Dexter Field Services is also a 5-time Inc. 5000 honoree, ranking #406 on the Inc. 500 list of Fastest Growing Private Companies in 2010.
From 2006 through 2014, Steve oversaw the acquisitions of Bowman Environmental, AWR, CCI, Plant Services Inc., Bonanza Industries, and Wilkins Environmental to build up the presence and services of Sage.
While managing the six companies that make up the Sage family, Steve founded the 4C Marketplace in 2015, which was designed to share knowledge, build camaraderie, grow the industry, and advance the careers of those working in environmental compliance. Steve has also been a member of the Vistage CEO group since 2013.
Key Expertise
- Air Quality Compliance
- Title V Permitting
- Due Diligence and Auditing
- Construction and Operating Permits
- Risk Management
- Emission and Inventory Reduction
Project Experience
Title V Permits:
Title V Operating Permit Applications: Prepared operating permit applications for two brick manufacturing plants. Conducted audits and assisted in draft permit review. Completed necessary standard exemptions as part of the Title V process. (U.S. Brick — Mineral Wells & Elgin, Texas)
Title V Operating Permit Application - Waxdale Facility: The Operating Permit Application involved the completion of a comprehensive air emissions inventory, regulatory applicability analysis (positive or negative applicability determinations for all potentially applicable requirements), a Leak Detection and Repair Program, wastewater sampling and modeling, and air dispersion modeling. The project required the involvement of 8 different offices, over 9,000 staff hours and 1 year to complete. (S.C. Johnson & Son, Inc. — Racine, Wisconsin)
Title V Operating Permit: The operating permit application involved permitting strategy, data gathering, regulatory applicability analysis, and application preparation. A model permit was provided with the application to the state as the basis for the future operating permit. All insignificant sources were documented with emission calculations. Trivial sources were identified based on agency guidance including the EPA White Papers. (Navistar Intl. Transportation Corporation — Springfield, Ohio)
Title V Permit Application and Modifications: Prepared an operating permit application and subsequent modifications for the synthetic organic chemicals manufacturing facility. Scope of work included emission calculations and preparation of application forms for seven chemical manufacturing units and utilities within the facility. (Chicago Specialties — Chicago, Illinois)
Title V Permit: A full operating permit application was prepared based on the results of the 1997 Emissions Inventory. The scope of work included extensive regulatory analysis, completion of all required forms, and application preparation. (Huntsman Corporation — Longview, Texas)
Title V Operating Permit Application: Prepared Louisiana forms and report for the permit application. Created EXCEL template to provide consistency for future Emissions Inventory reporting. (Amite Foundry and Machine — Amite, Louisiana)
Title V Operating Permit: Calculated potential-to emit and prepared regulatory analyses and application forms for a permit application for the steel foundry. Created EXCEL template for future Emissions Inventory reporting. An "Outstanding Assistance" thank-you letter was received from the client for this job. (Atchison Castings — Atchison, Kansas)
Title V Operating Permit: The scope of work for the gray iron and aluminum foundry operating permit application included emission units identification, emission factors development, estimation of potential-to emit, regulatory analysis, and application forms preparation. (Clay and Bailey Manufacturing Company — Kansas City, Missouri)
Title V Operating Permits: Evaluated five branch campuses in Ohio and documented minor source status. Developed emissions inventory and documented the potential to emit for each emission unit. Negotiated regulatory interpretations involving the potential to emit. (Ohio State University — Columbus, Ohio)
Risk Management:
Risk Management Program: Implemented a compliance program to meet the requirements of Part 68 for propane tanks at several facilities. Assisted clients in complying with training, emergency response and other program requirements. (Atchison Castings — Atchison, Kansas)
Risk Management Program: Implemented a compliance program to meet the requirements of Part 68. Conducted off-site consequence analysis for sulfur dioxide, sulfur trioxide, and anhydrous ammonia, including detailed modeling. Recommended strategies to reduce the endpoint distance. (Chicago Specialties — Chicago, Illinois)
Risk Management Program: Implemented a compliance program to meet the requirements of Part 68. Conducted off-site consequence analysis for butane. Recommended strategies for communicating the risk to the public. (Mobil Oil Corporation — Baden, Texas & Petal, MS)
Emissions Inventory and Reduction:
Emissions Reduction Marketing System Application: Prepared emission calculations, and ERMS forms for the facility. Scope of work included comparative analysis of the facility emissions and regulatory applicability for seven years and estimation of the baseline emissions for the ongoing years. (Chicago Specialties — Chicago, Illinois)
1997 & 1998 Emissions Inventory: The facility is a polypropylene plant utilizing a gas phase, fluidized bed reaction system. The project included identification of individual emission units, development of emission factors, and correction of discrepancies between the state point source database and the facility permits. Application of correlation curves instead of average emission factors allowed the facility to lower fugitive emissions approximately 30 tons per year for the emissions inventory. (Huntsman Corporation — Longview, Texas)
Emission Inventories: Prepared 1995, 1996, 1997 and 1998 emission inventories for an air conditioner manufacturing plant. The facilities consisted of approximately 20 emission units. (The Trane Corporation — Tyler, Texas)
Emission Inventories: Prepared 1995, 1996, 1997, and 1998 emission inventories for a battery processing plant, including a secondary lead smelter. The project included the development of emission factors for various equipment, emission calculations, and completing forms for new equipment. (GNB Technologies — Frisco, Texas)
1995 and 1996 Emission Inventories: Prepared emission inventories for a battery manufacturing facility. The project included the development of emission factors for various equipment, emission calculations, and filing of all forms for a new account. (GNB Technologies — Framers Branch, Texas)
1996 and 1997 Emission Inventories: Developed a list of the steel foundry emission sources and performed emission calculations using individual emission factors and computerized spreadsheets useful for future inventories. Application of OCMA emission factors for binders significantly reduced the facility reportable emissions and fees. (Texas Steel — Fort Worth, Texas)
Emission Inventory Questionnaires (EIQ): Prepared and submitted EIQ's for gasoline bulk terminals, chemical plants, and refineries in Houston, Fort Worth, Galena Park, and Beaumont. (Gasoline Bulk Terminals, Chemical Plants — Texas)
Construction and Operating Permits:
Construction and Operating Permit Applications: Prepared emission calculations, CAD drawings, and application forms for construction and operating permit applications for dye and pigment manufacturing facilities. (Chicago Specialties — Chicago, Illinois)
Permit Amendments: Permit amendments were prepared to allow the facility to modify the product finishing area units. The scope of work included identification of state requirements, emissions estimation, and preparation of the application. (Huntsman Corporation — Longview, Texas)
Construction and Operating Permits: Three permit applications were prepared during 1996-1998 to allow the facility increase the number of spine fin machines and switch from old paints and adhesives to more environmentally friendly coatings and adhesives. (The Trane Corporation — Tyler, Texas)
OXO Alcohols Unit - Air Quality Permitting Project Manager: Prepared TNRCC permit amendment application for a major OXO production unit in Freeport. Served as project manager, responsible for permit strategy, permit preparation, and regulatory negotiation. (Confidential Client, Major Chemical Plan — Freeport, Texas)
Air Quality Compliance:
Title III Synthetic Minor (Area) Source Determination: Determined minor (area) source status under Title III through enforceable limitations in the Title V operating permit application. (Chicago Specialties — Chicago, Illinois)
Air Quality Compliance Program: Conducted an audit of all air quality requirements, prepared exemptions, and permits to achieve compliance with air quality regulations. Implemented an MSDS software and prepared the SARA 312 and 313 forms for submittal. (Standard Alloys — Port Arthur, Texas)
On-Site Technical Assistance: Provided all aspects of on-site technical assistance for the Environmental Protection Departments Air Quality Division including preparation of approximately 20 permits, permit amendments, permit renewals, and approximately 30 standard exemptions. The units permitted include vinyl acetate, ethylene, fuel and raw materials, isopropanol, ethoxylated alcohols, in-plant distribution, and solutions vinyl resin. Also prepared the benzene waste NESHAP and NSPS Subpart RRR compliance programs. (Union Carbide Corporation — Texas)
Major/Minor Source Determination: Developed emission factors for foundry emission sources and estimated potential-to-emit for current and projected production levels. (Amite Foundry and Machine — Amite, Louisiana)
Title III Synthetic Minor (Area) Source Determination: Determined minor (area) source status under Section 112(a) of the CAA. (GNB Technologies — Frisco, Texas)
Title III SOCMI Plant Evaluation: A compliance plan and road map was developed for the plant. Chemical Manufacturing Process Units (CMPU's) subject to Part 63 Subpart F were identified. An implementation plan was prepared. Applicable requirement for other state and federal regulations were simultaneously documented for the purpose of Title V. (Sterling Chemicals — Texas City, Texas)
Major/Minor Source Determination: Developed emission factors for foundry emission sources and documented the facility's potential-to-emit. (Standard Alloys — Port Arthur, Texas)
Miscellaneous Applications:
Benzene Waste Operations Subpart FF: Prepared a waiver application requesting an extension of the compliance date for a major refinery in Texas and Illinois. Evaluated and documented compliance issues for approximately 10 chemical, petrochemical and refinery operations with respect to Benzene Waste Operations NESHAP Subpart FF. (Confidential Client, Major Refinery — Texas and Illinois)
SARA 313: Prepared the 1992 SARA Form R submittal for a major refinery in the golden triangle area. Extensive documentation was compiled to provide consistency for future reporting years. (Confidential Client, Major Refinery — Texas)
Notification of Modification: Prepared three applications for facility modifications, including reconstruction of the grinding area and construction of a new grinding area. (ACME Foundry— Coffeyville, Kansas)
SARA 313 Forms: Determined which chemicals exceeded the threshold quantity based on the MSDS and usage rates. Calculated the reported chemical releases and completed the required forms using EPA software. (Amite Foundry and Machine — Amite, Louisiana)
Sand System Modification: Prepared application forms and CAD drawings for a sand system control equipment modification project. (Sloan Valve — Augusta, Arkansas)
- B.S. Chemical Engineering, University of Illinois, Champaign/Urbana, Illinois, 1990
- State of Texas Professional Engineers License No. 84782
- TACB & TNRCC Air Permits & Air Toxics Seminar, 1995
- Air Operating Permits & Air Toxics Seminar, 1995
- American Foundrymen's Society Environmental Conference, 1998
- First Aid & CPR
- 40-Hr Health and Safety Training
Mark has more than 35 years of experience in environment, health and safety management. His experience includes leadership roles in industry, consulting and government. Following completion of his MS in Animal Ecology with a specialization in Limnology, Mark was part of a research team that characterized water quality and developed management strategies for 109 lakes and reservoirs in the State of Iowa. He then spent nearly 6 years with the environmental division of the Iowa Department of Natural Resources where he managed the State's ambient air monitoring network and reviewed Prevention of Significant Deterioration permit applications. Mark completing atmospheric dispersion modeling studies of SO2 emissions for all of the coal-burning sources in the State. His work was used to develop site- and source-specific emission limits to be incorporated into the State Implementation Plan. During this time, he also managed technical evaluations of a multi-state, low-level radioactive waste disposal site and developed the master plan for registration, investigation and remediation of underground petroleum storage tanks for the State. Mark then joined an air quality environmental consulting firm in Texas. During the next 12 years, he helped grow the consulting business from 9 employees located in one office to more than 150 employees with offices in 7 states. As a consultant, Mark helped build and serve a client base including oil refining; the synthetic organic chemical industry; upstream natural gas production and transmission; surface coating and printing operations; automotive component and aircraft manufacturing, pulp, paper and forest products; portland cement manufacturing; mining and lime production. His work for these clients included Prevention of Significant Deterioration (PSD) permitting, Title V permitting, regulatory agency negotiations, and regulatory and technical support in response to EPA compliance investigations (EPA Section 114 letters) as well as defense against enforcement actions. Mark was also recognized as an effective trainer for his courses on PSD air permitting courses and dispersion modeling. He has provided training through his consulting firm, the Air & Waste Management Association, the Technical Association of the Pulp and Paper Industry (TAPPI), and for numerous trade associations and technical conferences.
Although a small fraction of his client base, his work in obtaining timely PSD permits, preserving flexibility in Title V permits, and providing effective agency negotiations led to Mark joining Chemical Lime Company in 1997 as Director of Environment, Health and Safety. In 1997, this privately owned mining company and lime producer employed approximately 500 people in North America. Now operating under the name Lhoist North America, the company tripled in size in the US through both organic growth and acquisitions. With the exception of a 2-year period when Mark served was served as the Vice President of Operations for all mining and production facilities in the Eastern half of the US, he has continued his role directing the environmental and safety activities for Lhoist North America and its acquisitions.
Key Expertise
- Prevention of Significant Deterioration (PSD) permitting & avoidance
- Environmental compliance (Section 114 investigations, compliance investigations)
- Regulatory agency negotiations
- Limnology
- NPDES/SWPPP permitting
- Mining and mine reclamation
- Due diligence
- Health and safety management
- Mergers & acquisitions
- Environmental & safety training
- Public policy
- Lhoist North America: Director of Environment, Health and Safety
- Trinity Consultants, Inc.: Vice President
- Iowa Department of Environmental Quality: Environmental Specialist
- Iowa State University: Research Associate
- Executive MBA Workshop, International Business Management, INSEAD, 1999
- MS, Animal Ecology - Limnology, Iowa State University, 1979
- BS, Zoology and Chemistry, Iowa State University, 1976
Professional Affiliations:
- Air & Waste Management Association
- National Lime Association
- Technical Association of the Pulp and Paper Industry Inc. (TAPPI)
- Iowa Academy of Science
Teresa has more than 13 years environmental experience working in chemical and petrochemical processing facilities with Title V permit applications, database systems and New Source Review Permitting. Her experience includes developing and implementing Compliance Assurance Systems.
Key Expertise
- Title V Permitting
- NSR Permitting
- Emissions Calculations
- Rule Interpretation and Regulatory Analysis
- Regulatory Compliance Management
- Database Development
- Release Reporting Management Tools
Project Experience
Federal Operating Permits
Developed initial and revision applications for Federal Operating Permits (FOP) for Refining, Petrochemicals and Specialty Chemical facilities. Assisted identifying regulatory applicability for new construction and equipment and process modifications. Audited facility applicability determinations to improved strategic enhancements for operational flexibility within permit representations. Created systems to manage regulatory determinations and facility compliance with FOP.
New Source Review Permitting:
Emission Estimation: Assisted client project teams to identify sources impacted by proposed construction or process modifications. Discerned key process factors that impacted estimated emissions and communicated potential roadblocks to project team. Provided insights to project team regarding emissions controls or process flexibility to minimize environmental emissions impact. Developed methodology and calculations to estimate emissions.
NSR Permit Assistance: Led construction project reviews to identify required controls and regulatory limitations and permit timing during project design phase. Development of NSR applications for Permit-By-Rules, Permit Revisions, Permit Alterations, Standard Permits, Changes to Qualified Facilities and Major Modification projects. Assisted with regulatory agency negotiations for permit conditions and proposed limitations, monitoring and recordkeeping requirements. Developed tools to manage compliance with permit representations and requirements.
Compliance Assurance:
Title V Compliance Assurance System: Project Technical: Worked with facility environmental staff to develop and implement Compliance Assurance System using programs such as PDC's IntelliRegs and client specific Access databases. Developed regulatory and permit driven tasks for compliance review. (Lyondell/Equistar –Multiple Texas Facilities).
1997 & 1998 Emissions Inventory: The facility is a polypropylene plant utilizing a gas phase, fluidized bed reaction system. The project included identification of individual emission units, development of emission factors, and correction of discrepancies between the state point source database and the facility permits. Application of correlation curves instead of average emission factors allowed the facility to lower fugitive emissions approximately 30 tons per year for the emissions inventory. (Huntsman Corporation — Longview, Texas)
Title V Compliance Assurance System: Project Technical: Reviewed facility Compliance Systems with environmental and operations personnel to ensure applicable requirements are identified and managed within facility. Teresa assisted environmental staff in managing applicable requirement changes such as identifying requirements for new sources and new applicable regulations and assisting client with developing comments to TCEQ regarding proposed rule changes. Reviewed facility deviation and release event reporting and provided responses during TCEQ follow-up. (Celanese LTD. – Multiple Texas Facilities).
Emission Inventories: Prepared 1995, 1996, 1997, and 1998 emission inventories for a battery processing plant, including a secondary lead smelter. The project included the development of emission factors for various equipment, emission calculations, and completing forms for new equipment. (GNB Technologies — Frisco, Texas)
Emission Event Reporting: Project Technical: Assisted clients in emission event reporting process through training of reporting guidelines, aiding in submittal of final notifications and working with TCEQ incident investigators. (Celanese LTD – Clear Lake and Bay City Plants).
1996 and 1997 Emission Inventories: Developed a list of the steel foundry emission sources and performed emission calculations using individual emission factors and computerized spreadsheets useful for future inventories. Application of OCMA emission factors for binders significantly reduced the facility reportable emissions and fees. (Texas Steel — Fort Worth, Texas)
Regulatory Reporting: Project Technical: Assisted clients in preparing required regulatory report packages for annual Texas Emissions Inventory, annual SARA 313, NSPS, NESHAP and MACT semi-annual reports and Title V semi-annual deviation reports. (Celanese LTD – Clear Lake and Bay City Plants).
- B.S. Chemical Engineering, University of Texas, 2002
- Contractor Safety Council Basic Plus
Vickie is an experienced Contracts Manager with extensive knowledge in all aspects of managing contractors in handling projects associated with reviewing, negotiating and executing contractual agreements for clients, subcontractors, independent contractors, lease agreements and other agreements as needed. She manages all correspondence regarding insurance certificates, pre-qualifications forms, health & safety, purchase orders and accounting vendor forms. Assisted in development of company's proposal, invoice, purchase order and contract procedures.
Key Expertise
- Review, Negotiate and Execute Contractual Agreements
- Manage Inquiries and Correspondence Regarding Insurance Certificates
- Maintain and Manage Internal Modules for all Contractual Documents
- Supervised four Administrative Assistants
- Managed Account Receivables
- Developed Ishikawa Diagrams
- Assisted with Development of Conceptual Designs of Timesheets, Expense Reports and Client Invoicing
Sage Environmental Consulting, L.P.: Contracts Manager: Baton Rouge, Louisiana: August 2003- Present:
- Review, negotiate and execute contractual agreements for clients, subcontractors, independent contractors, lease agreements and other agreements as needed
- Manage all inquiries and correspondence regarding insurance certificates, pre-qualification forms, health & safety, purchase orders and accounting vendor forms
- Maintain and manage internal modules for all contractual documents
- Project Director for "Invoicing Overhaul" Project which consists of the following phases: new timesheet, expense report, other direct costs and client invoicing modules. Worked with consultant for 1 ½ years in conceptual designs, work flows, procedures and project requirements. Assisted in developing, training and implementing modules accordingly.
- Assisted Chief Executive Officer in restructuring the company's proposal, invoicing, purchase order and contract procedures, and trained employees on invoicing, account receivables, health & safety and contract procedures
- Supervised four administrative assistants. Responsibilities included tracking monthly billable hours, performance reviews and addressing inquires regarding personnel and job responsibilities
- Managed account receivables, and developed Ishikawa Diagrams consisting of root cause analysis for account receivables and unbilled charges
URS Corporation: Contract Administrator II: Baton Rouge, Louisiana: April 2000 – August 2003:
- Financially assisted in managing $4 million annually
- Provided weekly cost analysis on projects
- Monthly invoice reviews, invoice summaries and progress reports
- Managed account receivables
- Completed appropriate work authorization and contract forms for project amendments and new projects
- Assisted Project Managers with proposals
- Reviewed contractual agreements
URS Corporation: Human Resource Administrator: Baton Rouge, Louisiana: October 2000 – March 2002:
- Recruited at Louisiana and Mississippi colleges
- Interviewed applicants
- Responsible for reference checks
- Processed all offer letters and internal paperwork
- Conducted new employee orientation
- Employee relations
- Attended management meetings to ensure awareness of employee projections
- Provided guidance on employee complaints
- Policies & procedures training
- Timekeeping presentations & training
- Maintained applicant flow charts
- Served as local Benefits Coordinator
The Shaw Group Inc.: Executive Assistant: Baton Rouge, Louisiana: May 1998 – February 2000:
- Internal support for the Chief Executive Officer
- Researched companies that were potential acquisitions
- Responsible for correspondence, expense reports, credit cards and travel arrangements
- Event Coordinator
- Maintained and coordinated the flight schedule for two planes and four pilots
- Supervised five employees
- Assisted in the production and editing of documents for the Human Resources Dept.
Louisiana Chemical Association: Administrative Assistant: Baton Rouge, Louisiana: June 1996 – May 1998:
- Internal support for Public Affairs, Education and Health and Safety issues
- Public relations
- Designed and edited promotional materials
- Production and distribution of press releases and publications
- Scheduled meetings and training sessions
- Attended committee meetings
- Data entry of annual Health & Safety survey information and tabulated results
- Monthly distribution of minutes to over 150 members
- Invoicing
Part-time positions were held during school, 1992 – 1996, at Allstate, MetLife, Thomas Insurance Agency, Blockbuster Video and Camp Fire.
- B.S. Business Administration, Northwestern State University of Louisiana, Natchitoches, Louisiana, May 1996
- "Effective Negotiating" and "Effective Negotiating II" Certifications, June 2008
Robert has over 25 years' experience as a Senior Financial Executive that specializes in management reporting such as extensive forecasting and budgeting utilizing IRR, ROI, EVA and other financial models. Robert has negotiated and participated in various acquisitions and dispositions, led an employee (ESOP) buyout and developed acquisition analysis tool and integration of acquisition. Extensive experience in the international management of developing subsidiaries in Venezuela (acquisition) and Mexico (start-up operation). Robert has participated on JV Boards in UK, Norway and Italy (financial staff reporting directly to him). Led IPO and ESOP for two separate companies, implemented SOX compliance system, led search and implementation of a $5 million Enterprise Reporting System, SEC Reporting, and experience working with Wall Street community, fund raising, analyst communication, broker/dealer communications, etc.
Key Expertise
- Merger Acquisitions
- Forecasting and Budgets
- International Management
- Security Reporting
- Broker/Dealer Communications
Mayes Manufacturing: Chief Financial Officer - Overall Financial Management for $35 million manufacturing and fabrication company. (June 2014 – December 2014)
Providence Environmental and Engineering: Vice President and Chief Financial Officer – Led an employee buy-out through an ESOP and served on the Executive Management Team reporting directly to the BOD. (January 2012 March 2014)
Exousia Advanced Materials Inc. (Public Company): Vice President CFO/COO – Overall Financial Management of the Company as well as Operational responsibility for the company. Responsible for all accounting functions from original entry to GL as well as invoicing, collections, vendor relationships, etc. Responsible for all SEC filings, banking relationships. Reported directly to the CEO and the BOD. (2005 – December 2014)
2001 – 2005 Consultant – Variety of clients largely on Sarbannes Oxley Matters. Lead team of consultants at Amedysis Inc., a public company, in examining, designing and then implementing effective internal controls that met the requirements of SOX.
Thomson South Louisiana Printing ($38 million subsidiary of $9 billion Public Company) Chief Financial Officer – Overall Financial reporting and accounting responsibilities for a holding company of 30+ publications. Reported directly to the CEO. (1995 – 2001)
OSCA, Inc ($250 million international oil and gas subsidiary of $3 billion Public Company) Vice President and Chief Financial Officer – Helped to grow this oilfield services company from $35 million in annual revenues to over $250 million. Responsible for accounting, HR, AP and AR. Led the financial valuations, due diligence and integration of 14 acquisitions and 3 dispositions. Sat on a J.V. Board for North Sea Operations. ( 1982 – 1995)
Bourgeois, Bennett, Thokey and Hickey CPA's Senior Audit and Tax Manager –. Rose from entry level accountant to Senior Manager of this large regional firm in New Orleans. Responsible for a wide variety of clients from oil and gas service companies to media and retail companies. (1976-1982)
- BS, Accounting, University of Southwestern Louisiana, Lafayette, LA
- MBA, University, Southwestern Louisiana, Lafayette, LA
Brett has over 29 years of experience in regulatory compliance, management, and process engineering. His company, Dexter Field Services is a leading provider of leak detection and repair services (LDAR) serving refiners and chemical manufacturers throughout the USA. His experience has been gained working in the petrochemical industry for 10 years and as an air environmental consultant for 2 years. Industry environmental experience includes assignments as an environmental manager, HSE manager (two separate refineries), and air quality specialist. Brett's air quality permitting experience is diverse and includes: PSD/Non-attainment NSR permits, Flexible Permits, Standard Permits, minor NSR Permits and Permit-By-Rule authorizations. His skills include customer service management, project management, historical project impacts analysis, facility netting, Federal Rule applicability determinations, emission calculation methods, project planning/execution, and agency interface. Brett has lead environmental due diligence teams for multiple US refinery acquisitions, and has lead EPA negotiations regarding air quality compliance liabilities and Global Consent Decrees. Brett's initial industry experience involves process engineering assignments for the Big Spring refinery for 4 years, including the chief process engineer for the Fluid Catalytic Cracking Unit. Brett is a graduate of the University of Texas with a B.S. in Chemical Engineering.
Key Expertise
- HSE Program – Facility Integration
- Air Quality Permitting
- Federal Regulatory Compliance and Auditing
- HSE Management System
Project Experience
Air Quality Permitting
Brett has extensive experience in preparing, both directly and as a project manager, air quality permit applications. Due to the differing age, size, and location of Fina's two refineries, his permitting experience is diverse, which includes Permit-By-Rule authorizations, Standard Permits, minor NSR Permits, Flexible Permits, and PSD Review/non-attainment NSR. His skills include historical project impacts analysis, facility netting, Federal Rule applicability determinations, emission calculation methods, project planning/execution, and agency interface. Brett has also managed or assisted in the development of long-term permitting strategies to balance compliance with organization Capital Expenditure programs. Long-term permitting strategy projects have included NOx RACT compliance, grandfather source permitting, low-sulfur fuels, and joint venture investments.
Regulatory Compliance and Auditing
Working both in the industry sector and as a consultant, Brett has managed the implementation and auditing of numerous state and federal regulatory programs affecting the petrochemical industry. Specific experience includes:
- Historical PSD Review (114 Questionnaire Responses)
- Low Sulfur Fuels Analysis (State and Federal)
- NSPS, Subpart QQQ, Auditing and Implementation
- NESHAP, Subpart FF, Implementation, Auditing, and Compliance Certification
- MACT, Subpart CC, Implementation and Auditing
- MACT, Subparts F, G, and H, Implementation and Auditing
- Upset Reporting (MACT (Subpart A) SSMP, CERCLA, EPCRA, TNRCC)
- OSHA PSM Auditing
- Risk Management Plan Implementation and Auditing
- NPDES Permit/Pollution Prevention Plan Auditing
- RCRA Program Auditing/Investigations
HSE Management Systems
Compliance assurance is the end goal of Management Systems. Brett has fostered the development of integrated management systems while serving in his role as HSE Manager within Fina. Since joining Sage, Brett has participated and/or led audit(s) of a major pipeline company's RMP and PSM programs. Specific experience includes:
- Risk Management Plan Development and Auditing
- Process Safety Management System Auditing
- Title V Compliance Assurance/Action Tracking Database(s)
- Modern Safety Management System (International Safety Rating System)
- B.S. Chemical Engineering, University of Texas, Austin, Texas, 1988
Jeremy is a degreed chemical engineer with experience in a variety of environmental fields, with a focus in air-related environmental compliance. Jeremy's areas of expertise include 40 C.F.R. Part 60, Subpart Ja (NSPS Ja) Compliance, Flare Consent Decree Support, Texas New Source Review (NSR)/Prevention of Significant Deterioration (PSD) Permitting, and Federal Greenhouse Gas (GHG) Permitting.
Key Expertise
- NSPS Ja Compliance
- Flare Consent Decree Compliance
- Texas NSR/PSD Permitting
- Federal GHG Permitting
- Honeywell TDC-3000 Distributed Control System
Project Experience
Flare Systems Analysis and Compliance
Flare Consent Decree Compliance: Engineer: Interfaced with the environmental and engineering departments at the BP Whiting Business Unit (WBU) to track the status of compliance with flare regulations (NSPS Ja, Consent Decree). Compiled information for all flares covered under the Consent Decree to create a Data and Monitoring Systems and Protocol (DMSP) Report detailing flare design specifications (flare tip, knockout drum, sweep gas, etc.), flare gas recovery systems and their respective components, and monitoring systems. Created a reference manual detailing proper operation of flare systems in compliance to all relevant standards and rules. Developed and maintained a checklist for Consent Decree flare design specifications and compiled a list of references to demonstrate compliance. (BP Products North America – Whiting, IN)
NSPS Flare Management Plans: Engineer: Reviewed refinery flare systems for flare configurations and design specifications, process unit connections, flare header contributions, and flare gas recovery system for both two newly constructed flares and six existing flares. Used information obtained from the review process to develop a Flare Management Plan for each flare in accordance with NSPS Ja. The flare system design specifications, fuel gas recovery system, monitoring instrumentation, minimization assessment, and root cause analysis were all characterized in the plans. (BP Products North America – Whiting, IN)
Flare Training Material Development: Engineer: Assisted in development of presentations that detailed proper flare operation to site personnel, including adjustment of assist gases and natural gas to maintain high combustion efficiencies. Created flare reference cards to be used by site personnel as a guide to flare operation and to increase retention of knowledge after training presentations. Produced multiple one-page guides on subjects related to flare operation to be used by site personnel as references. (BP Products North America – Whiting, IN)
Flare Waste Gas Minimization Plan: Engineer: Assisted in development of a Waste Gas Minimization Plan by identifying process connections to the flare system on P&IDs and determining the frequency of use for each connection. Populated a spreadsheet containing characteristics of each connection to the flare system and provided additional information for field identification. (Northern Tier Energy – St. Paul Park, MN)
Flare Instrumentation Audit: Engineer: Documented the location and orientation of instrumentation on the flare headers and determined whether any compliance risks were associated with the configuration. Provided alternative plans for compliance as needed. (Refinery Client – September 2013)
Air Permitting
Texas NSR Permit Application: Engineer: Performed a top-down Best Available Control Technology (BACT) analysis for criteria pollutant emissions. Cross-referenced existing permits with proposed technologies to find solutions that were both technically and economically feasible. Gathered information using the federal RACT/BACT/LAER Clearinghouse (RBLC) database to compile a list of numerical standards for control technologies that were applicable to the facility. (Chemical Facility Client – October 2013)
Texas Permit-by-Rule (PBR) Application: Engineer: Developed air quality authorization documentation under Texas state regulations. Calculated applicable emissions for proposed systems and registered a PBR in addition to creating a PBR note-to-file. (Chemical Facility Client – October 2013)
Federal GHG Permit Application: Engineer: Performed a top-down Best Available Control Technology (BACT) analysis for GHG emissions. Cross-referenced existing permits with proposed technologies to find solutions that were both technically and economically feasible. Gathered information on various CCS systems and compared against currently employed technologies to determine the efficiency and technical feasibility of each option. (Power Facility Client – November 2013)
Greenhouse Gas (GHG) Research for PSD Permit: Engineer: Conducted research to determine the economic feasibility of a Carbon Capture and Storage (CCS) system as part of a Best Available Control Technology (BACT) analysis. Gathered information on various CCS systems and compared against currently employed technologies to determine the efficiency and technical feasibility of each option. (Celanese – Clear Lake, TX)
- B.S. Chemical Engineering, Tulane University, New Orleans, Louisiana, 2012
- Sage Flare Essentials – Instruction by Dr. Troy Boley, Mr. Herman Holm, Mr. Derick Kopp, March 2013
- Certified Engineering Intern (EI), License #31587 – Louisiana Professional Engineering and Land Surveying Board
- Transportation Worker Identification Credentials (TWIC) Certification
- Basic Plus Safety Training – Houston Area Safety Council
Professional Affiliations
- American Institute of Chemical Engineers
- Griffith, DJ and Griffith, JM. "Topics in Thermodynamics," instruction manual for CHEG 311, McNeese State University, 2010
- Griffith, JM. "Picture Editor Guide," instruction manual for Honeywell TDC-3000, Process Control Lab, McNeese State University, 2010
Stephanie is well versed in various provisions of the Benzene Waste Operations NESHAP (BWON) and NSPS QQQ regulations and Consent Decree implementation – from BWON and NSPS QQQ Audits and Compliance Program development, to Consent Decree lab audits, and carbon canister design documentation, she's done it all. In addition to her technical specialties, Stephanie is also a member of Sage's Executive Leadership Development Team. In this role, she provides Marketing leadership for the 4C HSE Conference and serves as Client Guardian for 4C Marketplace business development.
Key Expertise
- GHG Reporting
- Database Manipulation
- BWON Reporting/Sampling/TAB Calculation
- Air Permitting
- Air Dispersion Modeling Analysis
- Emissions Monitoring
- Refinery MACT I
- Enhanced Oil Recovery via Carbon Capture and Sequestration
- Quantitative Chemical Analysis Techniques
- IC/GCMS/MS, PNMR/IR/UV Spectroscopy
- Chemical Measurement of Environmental Water Quality Indicators
Project Experience
GHG Reporting: Project Technical: The GHG Reporting Project was performed in response to the Greenhouse Gas Mandatory Reporting Rule. Responsibilities included: creating a GHG reporting tool for multiple refineries, collection of all data required for calculations, interviews with environmental management, performing various calculation methods depending on quality of information available, and reporting to the USEPA. (Sinclair Casper Refinery – Casper, Wyoming, Sinclair Wyoming Refinery – Sinclair,Wyoming)
BWON Quarterly Reporting/Sampling: Project Technical: The BWON Quarterly Reporting/Sampling was performed to satisfy Consent Decree requirements and involved: quarterly end-of-line benzene quantity calculation and reporting, compliance sampling, and operator interviews. (Sinclair Wyoming Refinery – Sinclair, Wyoming)
RRR ICR Comp. 1: Project Technical: The RRR ICR Component 1 project was performed in order to comply with USEPA's Information Collection Request related to the Refinery MACT rule in early 2011. Responsibilities for component 1 included: QA/QC of all data gathered and reporting of all data gathered to the USEPA. (Sinclair Wyoming Refinery – Sinclair,Wyoming, CVR Energy, Inc. – Coffeyville, Kansas)
Heat Exchanger MACT Applicability Analysis: Project Technical: The Heat Exchanger MACT Applicability Analysis included the following duties: Stream speciation analysis via P&ID review and maintanence compliance analysis. (Sinclair Wyoming Refinery – Sinclair, Wyoming)
Energy Production and Contaminant Degredation Using Microbial Fuel Cell Systems: Project Technical: The MFC program was focused on determining the feasibility of using MFC technology to enhance anaerobic microbial degradation of petroleum constituents in sediments through passive oxidation, and the ability of groundwater and (or) sediment MFC systems to significantly reduce contaminant concentrations in the field under natural conditions. (Client Confidential)
Effects of Irrigating with Treated Oil and Gas Produced Water on Crop Biomass and Soil Permeability: Project Technical: The goal of this work was to examine the effectiveness of using blends of poor quality, high SAR, produced water (from CBM and traditional petroleum industry source oil extraction wells) for irrigating and maintaining the physical integrity of three representative soil types and achieving normal crop production of two representative crops from the PRB using a series of greenhouse experiments. This study also included a detailed soil core analysis for each respective soil type/water blend. (Client Confidential)
In-Situ Treatment of Acid Mine Drainage Using Bio-Organo Oxygen Elimination Treatment: Project Technical: The objective of this proposed work was to investigate and develop a bioreactor system utilizing and enhancing Sulfate Reducing Bacteria (SRB) activity to neutralize acidity and remove metals from the acidic seepage discharged (AMD) via Biological Source Teatment (BST) techniques. The ultimate goal was to develop a system that provides long term, low maintenance treatment of acid discharge to comply with the current permitted obligations and State of Tennessee water quality standards. (Client Confidential)
Chemoautotrophic (CAT) Biological Carbon Capture and Re-use Process - Process Development: Project Technical: In this study, the client's patent-pending CAT process was utilized to investigate an alternative form of biological carbon capture to address the impact on the economic future of the Western coal-fired power industry. The CAT process provides the energy sector and other industrial emitters with a carbon capture and re-use technology that produces salable products, thereby turning an environmental hazard and expense into a valued resource with potential to significantly reduce foreign oil imports and domestic consumption. (Client Confidential)
Education/Professional Affiliations
- B.S., Chemical Engineering – Biomedical Option, Chemistry Minor, University of Wyoming, Laramie, 2007
- Occupational Safety and Health Administration (OSHA) - Basic Plus Orientation 2011
- AERMOD Modeling for Permits Training 2011
- Society of Women Engineers
- "Possibility of Insulin-Producing Cells Derived from Mouse Embryonic Stem Cells for Diabetes Treatment" – 2007
- "Enhanced Oil Recovery via Carbon Dioxide Sequestration" – 2006
- "Mercury Emissions Reduction in Coal-fired Power Plants" – 2006
- "Desulfurization of Coal via Sulfur-Reducing Bacteria" – 2006
For more than 27 years, Anita has been an environmental, health, and safety (EH&S) professional serving broadbased industrial operations. She has successfully implemented, and managed EH&S programs at both corporate and facility levels and understands the industry from the ground up—to deliver support to meet an organization's environmental needs . With a solid understanding of the regulations, professional respect with regulators, and strong working relationships with corporate and plant environmental personnel, Anita has managed and executed hundreds of projects and programs in 28 states and 3 provinces. Anita has focused her skills in serving clients through her role as client guardian, integrating engineers and scientists with our clients to develop environmental solutions while delivering business value to their organizations. Anita has worked at over 75 facilities throughout the US and Canada. Prior to joining consulting, Anita served as vice president of regulatory affairs for Pratt Industries (U.S.A.), Inc. She was responsible for EH&S programs throughout the company's U.S.A. operations.
Key Expertise
- Environmental Health and Safety Compliance
- Environmental Management Systems
- Compliance Audits and Due Diligence Support
- GHG and Carbon Management Strategies
- Water Management and Wastewater Treatment
- Wastewater and Storm Water Permitting
- Regulatory and Enforcement Negotiations
- Remediation Planning and Implementation
Project Experience
Water ,Wastewater, and Solid Waste Projects
Solid Waste (Ash Management Options): Client Service Manager: Provided a senior technical review of analysis of ash management options for beneficial reuse of the manufacturer's coal and wood ash. The company was able to use alternative cost-effective management options. (Paperboard Manufacturing Company, Georgia)
Ash Landfill Consent Order & Closure Plan: Develop remedial investigation strategy and closure strategy for a historical ash landfill that was exhibiting groundwater impacts. Negotiated resolution with the state regulatory agency, while effectively managing third party participation. Implemented closure plan that was protective of the environment, met state and federal requirements, and was effective at preventing groundwater degradation.
Landfill Closure Plan Renewal: Client Service Manager: Provided a senior technical review of renewal of the operating/maintenance plan for a closed landfill. Anita successfully reduced monitoring parameters to reduce long-term costs. (Liner Board and Corrugated Manufacturer, Michigan)
Holistic Evaluation of Process Water and Co-Products Management: Project Manager: Served as project manager and senior technical support to improve process water quality, expand water reuse, and minimize discharge to the receiving stream. Provided conceptual design of process water system improvements to refine process water quality and increase recycling. Also developed a water balance for the facility, which was able to become independent of its third-party water source and maintain compliance with its NPDES permit. (Lime Manufacturing Facility, Alabama)
Effluent Coliform Evaluation: Client Service Manager: Provided senior technical support to evaluate treated process effluent that tested positive for fecal coliform results. The evaluation concluded that the coliform results were likely false positives, due to other constituents in the mill effluent. The facility was able to avoid additional evaluation and limits for control of fecal coliform. (Gypsum Board Facility, Texas)
Major NPDES Permit Modification and Treatment Plant Redesign: Client Service Manager: Provided project coordination and senior technical review for the development of NPDES permit modification and wastewater treatment plant design changes to address changes in the mill's manufacturing processes. The facility changed its manufacturing process, adding new process chemicals and using additional water that would be discharged to the treatment plant before release to the receiving stream. It was determined that the wastewater treatment plant would need to add additional treatment process to remove the process additive and meet the revised NPDES permit limits. (Hardboard Mill, North Carolina)
Groundwater Evaluation: Client Service Manager: Coordinated a senior technical review to determine the status of groundwater contamination of the site, which had been managed by a previous owner. Determined current status of the monitoring program and evaluated potential future clean-up liabilities. (Corrugated Box Plant, Kansas)
Compliance Evaluation for Thermal Water Quality Regulations: Client Service Manager: Conducted a senior technical review to determine if treated paper mill effluent would meet future temperature water quality standards. The evaluation determined that the facility's existing effluent quality would meet new regulations without capital or operating changes. (Paper Manufacturing Facility, Wisconsin)
Water/Wastewater Treatment Plant Capacity Evaluation: Client Service Manager: Provided senior project technical assistance to address process water quality and effluent treatment plant capacity and bottlenecks. Anita evaluated system data to determine the effectiveness of the current water-handling and treatment systems. Implemented system sampling plans to demonstrate the effectiveness of performance-improvement trials when modifying operating chemistries. Identified operating changes to the wastewater treatment plant to optimize performance and ensure compliance with effluent discharge limits in the facility's certificate of authorization (permit). (Hardboard Facility, Nova Scotia, Canada)
SPCC and SWPPP Plan Updates: Client Service Manager: Provided project coordination and a senior technical review for SPCC and SWPPP plan updates. Updated the plans to conform to current environmental regulations and incorporating plan changes to address modifications of the site conditions. (Recycled Paper Mills, Georgia and New York)
SPCC and SWPPP Plan Updates: Client Service Manager: Provided project coordination of SPCC and SWPPP plan updates. Updated the plans to address site modifications and conform to environmental regulations. (Recycled Tissue Facility and Converting Operation, Wisconsin)
Multi-Media Audits
Due Diligence/Compliance Assessments: Client Service Manager: Coordinated Phase I ESAs at multiple locations to support the expansion of the company's mining operations. Anita identified CERCLA environmental concerns for the company to consider as part of the acquisition process. (Lime Mining and Manufacturing Company, Alabama, Florida, New Mexico, Texas, and Utah)
Phase I ESA and Limited Compliance Audits: Client Service Manager: Coordinated Phase I ESA and limited compliance audits for the acquisition of six paper mills and converting operations in North America. Anita supported the corporation's goals to complete the acquisition while mitigating potential environmental risk. (Packaging Company, Illinois)
Phase I ESA to Support Facility Divestiture: Client Service Manager: Coordinated a Phase I ESA for the seller, who was preparing the paper mill for potential divestiture. Identified potential CERCLA environmental concerns for the seller to address and/or disclose as part of the property transfer. (Tissue Paper Company, Illinois)
Due Diligence Assessment: Client Service Manager: Provided senior technical support for Phase I ESA and limited compliance assessments for a major corporate acquisition during a fast-tracked acquisition process. Identified potential liabilities and addressed them as part of the property transfer. The project supported the corporation's goals to complete the acquisition while mitigating potential environmental risk. (Integrated Paper Company, Arkansas, Maine, Michigan, and Wisconsin)
Phase I ESAs to Support Facility Divestiture: Client Service Manager: Coordinated Phase I ESA for the seller, who was preparing the paper mills for potential divesture. Identified potential CERCLA environmental concerns for the seller to address and/or disclose as part of the property transfer. (Integrated Paper Company, Mississippi and Wisconsin)
Due Diligence for Strategic Acquisition: Client Service Manager: Provided quality control and a senior technical review to support the potential acquisition and conversion of a closed facility. Evaluated the current permitting status and determined permits that would need to be obtained, potential permit limits, potential capital needed to meet the applicable permit limits, potential impacts to the wastewater treatment plant, and modifications that would need to be implemented at the wastewater treatment plant. The evaluation supported the acquisition process by providing a road map of environmental activities, potential costs, and timelines to meet the new operation's environmental obligations. (Recycled Paper Company, Wisconsin)
Compliance Audit: Client Service Manager: Provided environmental compliance assessments at a corrugated box plant. Identified compliance gaps and developed a corrective action plan. Developed a list of applicable requirements and implementation due dates for facility staff to expand on. The project results provided an environmental platform to guide and enhance ongoing compliance efforts. (Converting Operations, Kansas)
Compliance Assessments and Applicable Requirements: Client Service Manager: Provided environmental compliance assessments at paper mills and converting facilities, identified compliance gaps, and developed a corrective action plan. Compiled a list of applicable requirements and implementation due dates for the facility. Anita established a task-management system by assigning staff members to complete the required tasks. This comprehensive environmental platform provided guidance and enhanced ongoing compliance efforts. (Recycled Paperboard and Converting Company, Georgia and New York)
Facility Permitting: Client Service Manager: Provided senior quality control and technical support to secure environmental permits for Greenfield operations manufacturing corrugated containers. Anita obtained air permits and permit-by-rule authorization, pre-treatment permits for treated wastewater, and solid-waste authorization and stormwater permitting and plans. She ensured that this fast-tracked project started up in a manner that's consistent with the company's business goals. (Corrugated Converting Facility, Kentucky and Texas Corrugated Converting Facility, Kentucky and Texas)
Environmental Management and Training
Annual Environmental Roundtable Support: Client Service Manager: Coordinated and provided senior technical support to corporate and plant environmental staff, covering environmental aspects that impact the client's facilities: CRTK, SPCC plans, stormwater plans, ISO 14001 implementation, GHG monitoring and reporting, air emissions reporting and certifications, and SQG hazardous waste management. Anita conducted training using interactive dialogue to target the facility's information needs. (Recycled Tissue Manufacturer, Wisconsin)
ISO 14001 EMS Implementation: Client Service Manager: Provided senior technical support to facilitate implementation of ISO 14001 for the client's paper mills and converting operations. Integrated EMS with existing business and quality systems to minimize duplication and optimize ease of integration. The EMS system facilitates recordkeeping, environmental task management, continuous environmental improvements, and a platform for implementing GHG and sustainability programs. (Recycled Tissue Manufacturer, Alabama, Arizona, New York, and Wisconsin)
ISO 14001 EMS Implementation: Project Manager: Provided project management and senior technical support to facilitate implementation of ISO 14001 for the client's paper mills and converting operations. Integrated EMS with existing business and quality systems to minimize duplication and optimize ease of integration. The EMS system facilitates recordkeeping, environmental task management, and continuous environmental improvements. (Paper Mill, Michigan)
On-Site Environmental Support: Client Service Manager: Delivered on-site environmental support to supplement the facility's environmental staff and address environmental requirements. Anita completed a compliance assessment to identify applicable requirements and a gap analysis to identify areas needing corrective action. Developed a task-management system to identify what tasks needed to be completed, who was responsible, and when they were required to be performed. Also demonstrated when the tasks were completed and which ones were still open. This on-site support ensured enhanced compliance and systems for ongoing program improvements. (Recycled Paper Manufacturing and Converting Facility, New York)
Onsite Environmental Support: Client Service Manager: Coordinated and provided senior technical support to deliver on-site environmental assistance to supplement the facilities' environmental staff to address environmental requirements. Anita completed a compliance assessment to identify applicable requirements and a gap analysis to identify areas needing corrective action. Developed a task-management system to identify what tasks needed to be completed, who was responsible, and when they were required to be performed. Also demonstrated when the tasks were completed and which ones were still open. This on-site support ensured enhanced compliance, systems for ongoing program improvements, and training opportunities for existing staff.
ISO 14001 EMS Implementation: Project Manager: Provided project-management and technical support to facilitate implementation of ISO 14001 at a company that manufactures diesel engine piston inserts. Integrated EMS with existing business, quality, and social-responsibility management systems to minimize duplication and optimize ease of integration. The EMS system facilitates recordkeeping, environmental task management, and continuous environmental improvements. (Foundry Company, Michigan)
EHS Integration Support: Client Service Manager: Facilitated integration of the environmental and safety departments. During the process, selected representatives from both departments identified policies, procedures, and best practices that should be retained, as well as the activities that should not continue. Realigned resources based on need without reducing overall staffing. Achieved the company's goal, which was to realize synergies so that the client could optimize EHS performance throughout the organization. (Wood Products Corporation, Tennessee)
Sustainability Program Facilitation: Client Service Manager: Provided a senior technical review for presentation of the aspects and impacts of implementing a robust management system to attain the corporation's sustainability goals. Anita provided a foundation for the company to identify components to integrate into corporate business management practices to ensure attainment of the corporation's sustainability goals. (Recycled Tissue Manufacturer, Wisconsin)
Hot Topic/Regulatory Update: Client Service Manager: Provided a senior technical review of presentations to environmental and senior management staff of emerging regulatory changes that are likely to impact their facilities during the next five years. The company integrated the potential impacts into its near-term business planning. (Integrated Pulp and Paper Company, Arkansas, Kentucky, Michigan, North Carolina, South Carolina, Tennessee, and Wisconsin)
Strategic Environmental Management and Training Support: Client Service Manager: Facilitated a workshop to support a multilingual, international lime company in the development of its overall corporate governance programs relating to environmental management systems and auditing. Anita provided a foundation for the corporation to use in evolving corporate governance policy and protocols. (Lime Mining and Manufacturing Company, USA, Belgium, Brazil, Germany, France, Poland, and the U.K.)
Environmental Training: Client Service Manager: Provided a regulatory overview for key environmental staff, covering applicable environmental requirements. Anita covered NPDES permitting, stormwater plans, SPCC plans, SQG/CESQG, and emerging air issues. She provided "train the trainer" materials to be deployed cost-effectively throughout the corporation to ensure standardized training. (Lime Mining and Manufacturing Company, Texas)
Environmental Highlights for Operations Managers: Client Service Manager: Provided a senior technical review of presentations covering regulatory overview and implications of stormwater and wetlands regulations to mining and lime manufacturing operations. The primer provided operational personnel with a basic understanding of how to integrate environmental compliance into day-to-day business management practices. (Lime Company, Texas)
Audit Protocols and Auditor Training: Client Service Manager: Provided senior-level oversight of the development of an audit protocol and auditor training for facilities throughout the United States. Anita developed an audit protocol template for one facility at this lime manufacturing company and used it as the audit protocol for a compliance audit, which was used as part of a hands-on training session for the company's environmental audit staff. She then tailored the template to be used as the audit protocol for the corporation's other facilities. The project enhanced the corporate governance program by expanding audit protocols and auditor training. (Lime Mining and Manufacturing Corporation, Alabama, Arizona, California, Missouri, Nevada, Tennessee, Texas, and Virginia)
Air Quality and Emissions Control
Boiler MACT: Client Service Manager: Coordinated the evaluation of mercury control options for coal and biomass-fired boilers to come into compliance with the recently finalized Boiler MACT standards, without causing the facility to modify current fuel sources or significantly impacting capital or operating costs. The determination provided control options that would allow the facility to maintain its competitiveness. (Integrated Paper Mill, Wisconsin)
Air Permit Modifications: Client Service Manager: Supported the evaluation and permit modifications to allow a paper company to implement capital and maintenance improvements at their site while sustaining manufacturing operations. (Tissue Manufacturing and Converting, Arizona)
Air Permit Modifications: Client Service Manager: Supported the development permit renewal and permit modifications to allow for continued manufacturing operations and boiler replacement. (Paper Converting Facility, Georgia)
GHG/Carbon Management
GHG/Carbon Management: Client Service Manager: Assisted a pulp and paper company to benchmark its GHG emissions against others in North America and Europe to help the company set their GHG goals and objectives. The corporation wanted to know how they compare with their competitors in the marketplace and incorporate this information into their carbon management program. (Integrated Paper Company, North America)
GHG/Carbon Management: Client Service Manager: Coordinated a facilitated discussion about carbon management and climate change with corporate and plant environmental staff. Anita provided an overview of carbon-management program considerations such as measuring/monitoring, scope (Scope 1, 2, or 3 emissions), reporting, supply chain management, goal setting, implementation, review, and modification. She provided a foundation for the company to use in developing and implementing its carbon-management program. (Tissue Paper Manufacturing and Converting Company, Alabama, Arizona, New York, and Wisconsin)
GHG/Carbon Management: Client Service Manager: Coordinated a greenhouse gas (GHG) reporting applicability review to determine if the paper manufacturing facilities were subject to the reporting requirements of the GHG monitoring and reporting rules. Developed a QA/QC plan and reporting template to support data collection consistent with reporting requirements. (Recycled Paperboard Manufacturer, Georgia, Louisiana, and New York)
GHG/Carbon Management: Client Service Manager: Coordinated the development of GHG management strategies, established a carbon footprint for the facility's products, and developed GHG monitoring and reporting protocols. Anita provided tools to integrate GHG management into overall business goals relating to capital and operating planning. (Recycled Paperboard Manufacturer, Indiana)
GHG/Carbon Management: Client Service Manager: Supported the development of GHG management strategies to establish carbon footprints for the corporations' products, utilizing the Forest Industry Carbon Assessment Tool (FICAT). Included scope 1, scope 2, and applicable scope 3 emissions in the evaluation. The evaluation provided the carbon footprints of the effects of the facilities' manufacturing activities on carbon and GHG emissions along their value chain. The project provided transparent validation of the carbon footprint of this company's low-carbon-impact products. (Paperboard and Corrugated Manufacturing Facilities, Georgia)
- B.S. Microbiology, Michigan Technological University, Houghton, MI, 1980
- Water/Wastewater Engineering & Design Course, University of Wisconsin, Green Bay, Wisconsin, 1985
- Licensed Industrial Water, Wastewater Treatment and Storm Water Operator, Michigan # 2858
- Licensed Storm Water Operator in Michigan #01132
Professional Affiliations
- National Council for Air and Stream Improvement (NCASI), Northern Regional Steering Committee member
- Technical Association of the Pulp and Paper Industry (TAPPI) :Board of Directors, leading the organization at a time of significant industry change; Chairman of the Leadership Development Forum; Chairman of the Association Strategy Development Committee; Chairman of the Environmental Division
- Wisconsin Paper Council
- Michigan Pulp and Paper Environmental Council
- Menominee Chamber of Commerce – Board of Directors, Chairman
Publications and Presentations
- Numerous presentations at TAPPI Environmental Conference, TAPPI's local section meetings, NCASI regional meetings, and other association meetings.
Buzz Harris is a Chemical Engineer with 45 years experience in industry and consulting. He began his career as a process engineer at the Texaco Port Arthur refinery, where he spent six years rotating through responsibility for all the major refining process categories. He joined Radian Corporation in 1976, and has spent the last 37 years in consulting to the refining, petrochemicals, natural gas, and chemicals industries. Buzz played a lead role in the fugitive emission studies that established the monitoring protocol, correlation equations, and emission factors for refineries, chemical facilities, and natural gas plants. He has been continuously involved in LDAR equipment leaks issues since 1976, in projects ranging from bagging, training, database, regulatory development, equipment evaluation/development, auditing, and expert witness. In recent years, LDAR audits and training have become nearly his full-time job, having completed more than 250 LDAR audits over the last 14 years. He is also a certified FLIR GasFindIR thermographer. Buzz is currently employed by Sage Environmental Consulting as a Project Manager/Principal Engineer.
Key Expertise
- All facets of LDAR and fugitive emissions (including Smart LDAR)
- Air emission measurement, estimation, and control
- PSM/RMP program development, modeling, and auditing
- Shelter-in-place evaluations
Project Experience
Fugitive Emissions/Leak Detection and Repair (LDAR)
In 39 years of work in this field, Buzz has worked on hundreds of projects. The following bullets present a few key projects and categories of LDAR work:
- Lead auditor for more than 250 LDAR audits, including more than 220 third party Consent Decree audits.
- Assisted the American Petroleum Institute with development of comments on the proposed Uniform Standards for Equipment Leaks.
- Served as an expert witness and provided technical support for a number of civil and criminal cases with alleged LDAR issues, including testimony in a deposition in 2012.
- LDAR Essentials and LDAR for Experts instructor for multi-day curricula designed for new through highly experienced environmental professionals.
- LDAR University instructor for "Living with an LDAR Consent Decree" and "Fugitive Emissions Estimating".
- Worked with several companies in negotiating the LDAR portion of a Consent Decree, including extensive research in the low-leaking valve and packing technology.
- Develop measurement techniques and led the field implementation in a measurement of emissions from barges in transport sponsored by the Louisiana Department of Environmental Quality and EPA.
- Has supported most of the demonstrations of SmartLDAR optical imaging through quantification of limits of detection and participated in a major Smart LDAR demonstration project as a Consent Decree SEP.
- Industry consultant for a Beneficial Environmental Project to develop best practices for LDAR. This study for a styrene manufacturing facility, with ethylbenzene as an intermediate product, surveyed best practices at eight facilities and compiled an LDAR code of best practice.
- Led the development of the second generation Hi-Flow™ sampler for GRI, which was a compact instrument system for mass emission measurement.
- Program Manager conducting the LDAR program for a gas plant.
- Program Manager of several projects that provided training and baseline monitoring for international refineries (England, Scotland, Switzerland, Norway, Czech Republic, and Taiwan) to establish their LDAR programs.
- Coordinator of an industry/regulatory steering committee that helped define the path that alternatives to Method 21 would need for approval.
- Expert consultant on leak detection for a series of projects to characterize fugitive emissions from upstream oil and gas production and processing. These projects were sponsored by GRI and API.
- Program Manager and LDAR program consultant for a large Gulf Coast refinery in setting up their LDAR program and tagging to meet Refinery MACT.
- Program Manager for revalidation of petroleum refinery correlation equations for WSPA.
- Program Manager of revalidation of SOCMI factors for ethylene oxide, butadiene, and phosgene funded by CMA.
- Lead technical role in a project to measure inorganic fugitive emissions from compounds such as hydrogen sulfide, ammonia, etc. This work was sponsored by the Tennessee Valley Authority.
- Project Director of the EPA fugitive emission measurements work in gas plants that established the foundation for NSPS KKK. This work involved both monitoring and bagging in a series of natural gas processing plants in the US. Correlation equations and emission factors were developed based on this work.
- Project Director of the EPA SOCMI Screening Study.
- Lead role in fugitive emissions measurement portions of the EPA-funded study "Atmospheric Emissions from Petroleum Refineries". This landmark project developed the leak detection prototype for Method 21, the vacuum bagging method, the emissions correlation equations, and the initial set of fugitive emission factors for refineries.
Air Emissions Measurement, Estimation, and Control
While focused on LDAR, Buzz has also worked on a variety of other air emissions projects:
- Greenhouse Gas – participated in development of the GHG protocol for API focusing on the refinery GHG emission estimating portion; developed inventories for several refineries; and audited GHG inventories for several refineries.
- Environmental Assessments – Project Manager for an overall environmental assessment of a large chemical facility in Korea.
- Emission Inventories – helped with numerous emission inventories and developed the complete hydrocarbon emission inventory for a refinery in Germany as part of the Environmental Impact Report.
- Authored Chapter 7 on hydrocarbon emissions of the API manual Disposal of Refinery Wastes.
- Developed a model of refinery emissions of VOC for EPA.
- Title V – helped several facilities with the development of their operating flexibility sections of Title V permit applications.
- Solvent Recovery – designed a solvent recovery system for Vandenberg Air Force Base to be used if the base was converted to a West Coast shuttle launch site.
- Oil Production Emissions – managed and lead field measurements to determine emissions from steam-enhanced secondary recovery projects.
- BACT and LAER – worked on numerous projects to define BACT and LAER for various emission categories.
Buzz has developed and presented numerous training programs:
- Prepared and presented regular quarterly training sessions for environmental professionals titled LDAR Essentials.
- Prepared and presented regular training sessions for environmental professionals titled LDAR for Experts for the most experienced LDAR staff.
- Prepared and presented two courses for LDAR University: Living with LDAR Consent Decrees and Fugitive Emission Estimating.
- Prepares and presents annual training to meet Consent Decree requirements for a number of petroleum and chemical facilities.
- Prepared and presented advanced LDAR training for a petroleum client.
- Prepared a CD-based slide show with voice-over for LDAR 101 awareness training to all technical employees and contractors of a refinery.
- Prepared, presented, and trained-the-trainer for LDAR concerns for refinery operations and maintenance personnel.
- Co-prepared and co-presented a week-long training program on emergency response to a group of about 40 professionals from a Korean company.
- Lead the development of a comprehensive environmental training program for a group of about 20 professionals from petroleum and chemical companies in India, and presented the materials on LDAR and process safety/risk management.
- Prepared and co-presented a three-day training program on emergency response to a group of US petroleum refinery personnel.
Process Safety, Risk Management, and Emergency Response
Since 1985, Buzz has been involved in a number of studies of process safety and later, risk management:
- Led and/or participated in over 20 PSM/RMP audits.
- Performed testing of air infiltration rates and evaluated the effectiveness of buildings/rooms designated for shelter-in-place for a major metals company and for a Gulf Coast LEPC.
- Handled emergency response aspects of the permitting of the Longhorn pipeline.
- Co-Coordinator of the East Harris County Manufacturers Association (EHCMA) work to develop consistent risk management programs (RMPs) for the 80 plus member companies.
- Developed RMPs for a dozen or more clients outside of EHCMA.
- Assisted with community roll-outs in Houston, Lake Charles, and Point Comfort.
- Lead a comprehensive process safety review of three industrial parks in Taiwan.
- Prepared a series of Prevention Reference Manuals, both generic and chemical specific, for the US EPA.
- Project Director for a chemical plant disaster study for a major chemical company that involved process safety reviews and modeling for more than a dozen plants in the US and abroad.
Refinery Technology
Buzz was a refinery process engineer for six years, rotating through cracking, reforming, crude distillation, sulfur recovery/acid production, alkylation/polymerization, and lube oils manufacturing. He also participated in a number of special studies, such as the design and justification of a central amine regeneration unit and field testing of the first riser-cracker design FCCU in the Texaco refineries. Since becoming a consultant, Buzz has concentrated his work on petroleum refining and closely related petrochemicals and natural gas processing. He has developed a model of refinery VOC emissions for EPA. He wrote the API greenhouse gas protocol sections on estimating refinery GHG emissions. He performed testing to create a mass balance around a proprietary process to recover usable oil from refinery wastes.
Education and Training
B.S., Chemical Engineering, Texas A&I University, Kingsville, Texas, 1970
American Institute of Chemical Engineers (AIChE)
Western States Petroleum Association (affiliate member)
4C Conference: Environmental Lifetime Achievement Award
- FLIR GasFindIR training from the Infrared Training Center
- Basic Plus Refinery Safety from the Association of Reciprocal Safety Councils
- Los Angeles Refinery Safety Overview
- Three Rivers Contractor Safety Orientation
- Advanced Learning Techniques as Applied to Commercial Training
- Basic Statistics, University of Texas, Engineering Institutes Short Course
- Project Management, Harold Kerzner
- Negotiations, Dr. Chester Karras
Buzz has presented dozens of papers at conferences and symposia in the fields of LDAR and PSM/RMP. He has co-chaired conferences on fugitive emissions. He co-authored the section on fugitive emissions in the Encyclopedia of Chemical Engineering. He wrote Chapter 7 of the API Manual "Disposal of Refinery Waste", which covers VOC emissions. He was a contributor to the API greenhouse gas emissions protocol document, focusing on refinery point source emissions and equipment leaks. He has authored or co-authored hundreds of reports associated with the projects described in the experience section.
David has over 27 years experience in a variety of areas within the environmental field. These areas include instrumentation system design, air toxics monitoring, auditing of environmental systems, water monitoring, fugitive emissions monitoring, stack testing using CEMs (Continuous Emission Monitors), design and installation of CEM systems and ambient air monitoring using conventional analyzer systems as well as with FTIR (Fourier Transform Infrared Spectroscopy) technologies. His skills include instrumentation operation, maintenance, calibration, and repair, environmental sampling, technical writing, data processing, report writing, project management, and the auditing of ambient air monitoring systems and LDAR (Leak Detection and Repair) programs. Initially, David provided repair and field service support of microprocessor-based data acquisition systems for Radian Corporation (now part of URS Corporation). He later transferred to Radian's Air Monitoring Department where he provided instrumentation, quality control, reporting and auditing support on a wide variety of projects associated with both ambient and process level emission measurements. Before leaving URS, David worked with the FTIR group in the application of this new technology to environmental measurements as well as participating in numerous EPA Consent-Decree mandated LDAR audits. David moved to Sage Environmental Consulting in December 2005 where he continues to work on LDAR projects as well as to extending Sage's expertise and capabilities in the areas of ambient air and source level monitoring. David's recent activities have included LDAR audits, performing IR camera surveys at both off-shore and on-shore facilities, providing Level 1 Thermography Certification training, conducting direct emission testing (bagging) and the installation of a meteorological system at a landfill site.
Project Experience
Infrared Camera Experience
Conducted a nine-month infrared camera survey for equipment leaks at a mid-size refinery in 2007-2008. This survey included two passes through the refinery, experimenting with different imaging techniques, evaluating different camera lenses, developing survey methodologies, and characterizing the effects of various environmental factors such as wind speed, temperature, imaging backgrounds, humidity, etc. upon the camera's sensitivity.
Performed an infrared camera survey for 1-3-butadiene emissions at a Gulf Coast refinery in 2009.
Performed an infrared camera survey for leaking equipment at two of Shell Oil's off-shore platforms in 2009.
Completed for Enterprise Products, an infrared survey for equipment leaks at a Gulf Coast natural gas processing plant in 2010.
Developed training materials and provided Level I training in Infrared Thermography to Enterprise Products employees.
Emissions Measurements (Bagging)
Participated in several bagging studies to quantify emissions from equipment leaks detected by the IR camera.
Constructed a bagging cart and presented a 3 day bagging training course for Summit Inspections.
Provided bagging support services of selected components in a study sponsored by the Texas Chemistry Council and the U.S. Environmental Protection Agency in 2008.
Air Toxics Monitoring
- Hazardous Waste Investigations
- Emergency Response Investigations
- Clean Room Monitoring Projects
- Research Investigating Underground Storage Tank Leak Detection Devices
- Ambient Air Monitoring
- Fugitive Emissions
Ambient Air Monitoring
- Temporary operator of ambient air monitoring network.
- Design and construction of a mobile ambient air monitoring station for a client in Mexico.
- Design, construction, and documentation of two mobile ambient air monitoring stations for use in Chad and Cameroon, Africa.
- Participation in auditing programs involving site evaluation and performance and systems audits of continuous ambient air monitors and meteorological systems.
- Conducting training seminars to teach clients auditing principles and techniques.
- Auditing of ambient air monitoring network in Taiwan.
- Conducting quarterly audits of a six station ambient air monitoring network locat4ed offshore in the Gulf of Mexico.
- Auditing of LDAR (Leak Detection and Repair) programs at over 100 nation-wide refineries.
- Participation in numerous fugitive emissions programs involving screening and bagging procedures.
- Conducting client training seminars in screening and bagging techniques.
- Management of an on-site 1-1/2 year emission inventory program.
- Creation and management of an Access™ based emission inventory database.
- Implementation and management of a natural gas plant fugitive emission program.
- Participation in a country-wide LDAR audit program.
- Development of training materials and setup of a pilot LDAR program for a client refinery in Spain.
- Participation in evaluation testing of Smart LDAR technologies.
- Shared presentation of several papers on LDAR topics at annual LDAR symposiums.
- Project Manager for a large LDAR retagging project in southern California.
- Project Manager of a year-long supplemental environmental project to evaluate the application of passive infrared technology to meet LDAR monitoring requirements at a refinery in Texas.
- Participant in a comprehensive evaluation of BP Texas City's LDAR program.
- Project Manager for several consent decree style LDAR audits.
- Project Manager of a facility-wide LDAR stream inclusion project for a chemical facility.
- Writing of technical hardware and software manuals.
- Participation in numerous field projects using FTIR technology for ambient and source level monitoring.
- Installation of two mobile FTIR sampling systems in Saudi Arabia.
- Installation of two FTIR sampling systems at a remote site in Russia.
Instrumentation System Design
- Design and construction of mobile source sampling systems.
- Design and construction of a surface impoundment meteorological and organic sampling system.
- Design and fabrication of an electronic valve controller for use in glove permeation research.
- Design and fabrication of assorted computer interface devices.
- Design, fabrication, and testing of a prototype Continuous Wet Bulb Monitor.
- Design and installation of a vapor well monitoring system.
- Design of large scale continuous emission monitoring systems.
Water Monitoring
- Participation in an extensive ground-water sampling program for the U.S. Air Force.
- Design and use of specialized sampling equipment to determine emissions from surface impoundments.
Continuous Emission Monitoring
- Providing instrumentation support to many projects dealing with source level monitoring and characterization.
- Design and fabrication of source level sampling systems.
- Providing CEMS installation and training services to various clients.
- Writing of technical CEM operations manuals.
- Auditing and evaluation of continuous emission sampling systems.
- Design and installation of a multi-analyzer SO2/O2 CEM system at the EPRI High Sulfur Test Center.
- Project Director for a contract with the U.S. Army to design and install an incinerator stack continuous emission monitoring system.
- Auditing of multiple CEM installations in Spain.
- Evaluation of optical-based analyzer for potential introduction to the U.S. CEMS marketplace.
Meteorological Systems
Installation of a meteorological system at Waste Management's Landfill site in Arlington, Oregon consisting of wind sensors, 10 meter and 2 meter temperature, relative humidity, barometric pressure, solar radiation and rainfall. This project included site evaluation and selection, writing a Quality Assurance Project Plan, equipment installation, operator training, data QC review and quarterly reporting.
Other Training
Individual courses completed at Austin Community College in Chemistry, Organic Chemistry, Physics, Calculus I & II, Basic Computer Programming, Beginning and Intermediate Russian. Self-taught in Microsoft Access™ and Auto-Cad™.
Special Information
Honors and Awards:
Radian Corporation's Annual Outstanding Achievement Award for 1991. Languages
Russian – Intermediate Level
- Electronics Technician Diploma, Southwest School of Electronics, Austin, TX 1978
- Secondary Education Diploma, The University of Victoria, Victoria, British Columbia 1975
- M.A. English Literature, The University of Washington, Seattle, WA. 1972
- B.A. Honors, English Literature, The University of Victoria, Victoria, British Columbia, 1971
George is a Information Technology and Portfolio Finance professional, with hands-on experience in Network (LAN) design, installation, administration, support and security. Some of his finance experience includes; being the controller for a multi-billion dollar hedge fund, where I automated processes to increase productivity and decrease costs; experience in large scale project management, as well as designing and teaching Financial and LT. classes.
Key Expertise
- Train employees on new system software
- Phone System
- Build new Infrastructure
- Watchguard, Cisco and Sonicwall firewall configuration and management
- Sharepoint 2010 and 2012 deployments
- VMware ESX 4.1 deployment and migrations P2V and V2P
- Configure and maintain Storage Area Networks
Project Experience
Specpro Group: Director of Information Technology: Manage the IT department for a group of 8 companies under the umbrella organization, which has 3000 employees and offices around the world. Maintained 99.999% uptime during tenure and advanced total IT asset availability to end users. (San Antonio, TX 2011-2013)
- Manage IT employees globally
- Set direction of company IT initiatives
- Manage IT projects and assist in implementation
- Set and manage IT budget
- Perform Business Case Analysis (BCA) for strategic initiatives and client contracts
- Support sales team in selling IT services
- Build out a new 24/7/365 infrastructure to support new company initiatives
- Implement and manage a new High Availability hot site
- Streamline all current processes and introduce new working standards
- Train employees on new systems and software
- Support, maintain and upgrade infrastructure
- Upgrade infrastructure to Hyper-V 2012, Exchange 2010, Windows Server 08R2 and 2012
- Watchguard, Cisco and Sonicwall firewall configuration and management
- MS Dynamics CRM deployment to Business Development
- Sharepoint 2010 and 2012 deployments
- VMware ESX 4.1 deployment and migrations P2V and V2P
- Samsung phone systems (OfficeServe7400)
- Configured and maintained Dell Blade Chassis and Blades
- Configure and maintain Storage Area Networks
Sirios Capital Management: Director of Information Technology and Finance: Perform portfolio accounting and controller tasks and take charge of financial projects for the CFO. In charge of all information systems and daily financial operations for a multi-billion dollar hedge fund. (Boston, MA 2003-2011)
- Perform finance duties as directed by the CFO, to include supervising daily back office operation and act as controller
- Responsible for all month end reporting, NAV production and approval and review of all released materials to clients
- Perform Business Case Analysis (BCA) to identify company bottlenecks and improve efficiency and output quality of processes
- Continually improve all processes for gaining efficiency and reducing costs
- Continually seek out new opportunities to leverage technology for cost savings or service improvement for internal and external users
- Evaluate new technologies and set I.T direction for the company
- Continually automated the back office (via TQM style process improvement steps), allowing us to run with a streamlined staff that is now more efficient and more accurate as well as less costly
- Automated manually intensive processes for the trade desk, reduced workload by ~20%
- Outlined specifications and managed several multi-year software projects for custom internal applications and helped create proprietary business critical processes and system.
- Created and Implemented the company DR plan with a hot site
- Manage local IT personnel as well as outsourced personnel
- Manage 3rd party vendor relationships for the technology and finance divisions and leverage those relationships to gain increased service and lower costs to the company.
- Supervise and mentor ancillary staff in IT, marketing and Finance roles
- Reworked all Marketing processes and automated them to cut workload and increase accuracy of external reporting.
- Maintained and improved documentation for preparation to register with the SEC
- Administer Windows 2008 LAN
- Administer WAN and Firewalls
- Assist the external Auditors of the Fund
- Give classes to the Technology analysts on LT. subjects and trends
- Managed multiple domain upgrades
- Managed the cross city move for the company, with zero business impact
Eze-Castle Integration: Sr. Network Engineer Team Leader: Acted as a network administrator for multiple small to medium sized financial companies. Trained and mentored Jr. Engineers and Help Desk personnel. Integrated new financial industry software for users as well as maintained the networks. (Boston, MA 2001-2003)
- Maintain the highest standards of client satisfaction
- Administer multiple WIN 2000 and Win NT LAN's as a Sf. Team leader
- Train and mentor Jr. Engineers and help desk personnel
- Coordinate and perform Domain migrations, Mail migrations and IP cutovers
- Design and install new Domain architectures
- Install and Manage accounts with Exchange 5.5 and Exchange 2000
- Conduct Network Audits and prepare the Audit reports for clients
- Design, set up, maintain and test Disaster Recovery sites
- Configure and maintain CISCO switches
- Design and implement network architectures
- Install and maintain Financial industry specific programs (Bloomberg, Bridge, Routers, Instinet, etc)
- Use Intuity Audix voicemail to set up and administer voicemail boxes
- Use Definity phone server to add, remove and customize users extensions
- Set up VPN's with Intel Netstructure Firewall and Client software
- Migrate users to new hardware with no data loss
- Setup and maintain Norton Antivirus Enterprise and Veritas Backup Exec servers and clients
- Installed and troubleshoot Blackberry Enterprise Servers, Internet and Enterprise editions
- Install, use and troubleshoot MS Office 97, 2000, XP as well as PC Anywhere
US ARMY: Sr. Information Technology Officer: Designed, installed and maintained (3) LAN's (with HDSL links to parent organization's WAN), created security policies, provided 3rd tier helpdesk support, created email and user accounts and built & repaired PC's in a Windows 2000/9x environment. Trained users on financial software for Tax Preparation. (Ft. Sill, OK 2000-2001)
- Developed and implemented a security policy for all users
- Managed user accounts for High Profile Business Operations Group
- Maintained and troubleshot all computer equipment, HP Jetdirect & Minolta PNP printers, Windows NT workstation and server and Windows 98/95 desktops and laptops PC's.
- Designed and maintained LAN, and Oversaw the implementation of WIN 2000 upgrade
- Trained users on equipment and software
- Developed procedural Manuals for future years' ITAC operations
US ARMY: Information Technology Officer: Performed system administration duties for 150 users, Managed and staffed third-tier help desk Supporting 1200 users and acted as Project manager for multiple long and short term projects. One of a four-member team who helped run the secret/secure UnixlNT network for the armed forces in Korea and received a medal of achievement and two coins for recognition from the Chief of Staff and CINCPAC (Commander In Chief of Pacific Area Command)
- Created and maintained inventory control databases for the brigade and maintained web page for the brigade
- Managed Cisco switches and routers
- Administer Domain and Exchange Accounts
- Managed migration of the 1200 user network to Windows 2000
- Designed, documented and tested Disaster Recovery Program for an environment of 1000 users.
- Designed and installed network for both existing and new buildings as well as updating present offices
- Created and maintained documentation for Standard Operating Procedures for IT department
- In charge of monthly training and continuing education for automations personnel
- Responsible for research and approval of all hardware and software purchases for the brigade
United States Army: Information Technology Officer/ Asst. Mgr. of Medical Lab: (1996-1999 - Hanau Health Clinic, Hanau, Germany)
- Information Management Officer of Han au clinic, as well as 4 clinics under our jurisdiction
- Expanded initial network of two stand-alone computers to Windows '95 and Windows NT mixed network containing fifty plus nodes.
- Managed second-level help desk and created and maintained clinic web page: Created a database of all unit personnel including each individual's certifications and dates of expiration, along with other pertinent information; Ran a Joint Commission on Accreditation of Health care Organizations team, which was responsible for researching standards for accreditation and testing and adjusting our clinic's policies and procedures in order to keep within the standards and was awarded a service medal for performance above and beyond.
- Total Quality Management Director for the Hanau clinic, which required the running of quarterly classes to all new personnel and well as run weekly TQM workshops
- Helped deploy Composite Health Care System (CHCS) hospital wide
- Responsible for initial deployment and training of users on CHCS system
- Performed initial troubleshooting of CHCS system for laboratory
- Managed microbiology and hematology sections, as well as lab budget
- Responsible for creating and maintaining documentation necessary to run the above sections
- In charge of weekly training of technicians in laboratory medicine
United States Army: Information Technology Lead: Weed Army Community Hospital- (Fort Irwin, CA F (1993-1996)
- Terminal Area Security Officer acting as first line of network trouble-shooting for entire staff
- Responsible for the budget to run the medical lab Chemistry section
- Helped deploy Composite Health Care System (CHCS) hospital wide
- Responsible for initial deployment and training of users on CHCS system
- Performed initial troubleshooting of CHCS system for laboratory
- Advised lab management on computer and chemistry equipment purchases
- Chemistry Section Chief was responsible for maintenance, ordering supplies, and repairing all chemistry equipment
- Swing Shift supervisor in charge of training and counseling of personnel
- Received award for saving an infant's life by taking the initiative to research and identity what was needed in order for our under-equipped lab to quickly identify a life-threatening fungus in the cerebral spinal fluid
Education/Professional Affiliations
- Masters of Science in Telecommunications, University of Maryland
- Bachelor of Science in Business; Minor in Computer Science
- International Council on Systems Engineering (INCaSE) - San Antonio, TX Vice President/President-Elect 2011- Present
The International Council on Systems Engineering (INCaSE) is a not-for-profit membership organization founded to develop and disseminate the interdisciplinary principles and practices that enable the realization of successful systems
Igor has over 19 years experience in the environmental compliance and permitting field. He has prepared minor and major New Source Review air permit applications, Title V operating permit applications, emissions inventories, and air quality computer modeling. He also prepared MACT Start-up, Shutdown, and Malfunction Plans; Title V Notification of Compliance Status and Deviation reports; storm water construction and general permit applications; and Spill Prevention, Countermeasure, and Control Plans. Igor is knowledgeable in state and federal environmental regulations and has extensive knowledge in word processing, spreadsheet and CADD applications.
Key Expertise
- New Source Review Air Permit Applications
- Title V Operating Permit Applications
- Emission Inventories
- Air Quality Computer Modeling
- MACT Start-up, Shutdown, and Malfunction Plans
- Storm Water Construction/General Permit Applications
- Spill Prevention, Countermeasure, and Control Plans
Project Experience
Title V Permits:
Title V General Operating Permit (GOP) Applications: Prepared Title V GOP applications for gas compressor stations and processing plants in seven different locations. Developed a compliance manual to assist the company in preparation of GOP applications for other stations. (Lone Star Pipeline Company (Texas).
Title V Permit Application: Prepared emission calculations, regulatory analysis, and application forms for a Title V permit application for a natural gas plant. Scope of work included emission calculations for the ethylene glycol dehydration units using the Gas Research Institute's GRI-GLYCalc computer model. (Magic Circle Corporation, Carmen, Oklahoma)
Title V Permit: A full operating permit application was prepared. The scope of work included extensive regulatory analysis, completion of all required forms, and application preparation. (Huntsman Corporation, Longview, Texas)
Title V Permit Application and Modifications: Prepared an operating permit application and subsequent modifications for the synthetic organic chemicals manufacturing facility. Scope of work included emission calculations and preparation of application forms for seven chemical manufacturing units and utilities within the facility. (Chicago Specialties Corporation Chicago, Illinois)
Title V General Operating Permit Application: Prepared a Title V GOP application for a gas compressor station. (Northern Natural Gas, Hemphill County, Texas)
Title V Permit Applications: Prepared emission calculations, regulatory applicability, and application forms for a Title V permit applications for natural gas booster compressor stations, sulfur recovery units, and gas processing plants in four different locations in Oklahoma. (Texas Exploration and Production Inc. Oklahoma)
Air Quality
Start-up, Shutdown, and Malfunction Plans (SSMPs): Prepared over a dozen SSMPs for gas plants in Texas and Oklahoma in compliance with 40 CFR 63 (MACT) Subparts HH and A. The facilities covered glycol dehydrators, tanks with potential flash emissions, piping fugitive components in HAP service, flares, and monitoring systems. (Duke Energy Field Services (Texas and Oklahoma)
Notification of Compliance Status (NCS) Reports: Prepared seven annual reports to comply with the State of Texas Title V Operating Permits program. Developed a template to address MACT HH requirements in an easy manner. The template allowed automating the report preparation and significantly reduced the time for individual reports preparation. (Duke Energy Field Services (Texas and Oklahoma)
Environmental Training: Prepared training materials and conducted a Environmental Compliance 101 training for the company personnel. The training covered MACT Subparts HH, HHH, and A applicability and compliance strategies. (Data Systems and Solutions, Texas)
Risk Management Programs and Plans and RMP Audits: Prepared RMPs and conducted follow-up mandatory audits for three gas processing and storage facilities. The scope included an identification of the RMP chemicals, development of Program 2 and 3 Prevention programs, and preparation of submittal documents. He implemented a compliance program to meet the requirements of 40 CFR Part 68 and conducted off-site consequence analyses for flammable substances. (ExxonMobil Corporation, Texas)
Prevention of Significant Deterioration (PSD) Permits: Prepared air dispersion modeling in support of PSD Permit applications for two facilities using ISCST3 model followed by refined modeling to demonstrate to the state authorities that the projects can meet applicable requirements and to minimize company capital expenditures for additional control equipment. (Diamond Shamrock, A Valero Company, Texas)
Air Dispersion Modeling: Conducted extensive air dispersion modeling in support of over five minor NSR permits to demonstrate compliance with the State Health Effects Review guidelines, State Property Line Standards, and State NAAQS Analyses requirements. (ATOFINA Petrochemicals, Port Arthur Refinery, Texas)
1997 – 2004 Emissions Inventories: The facility is a polypropylene plant utilizing a gas phase, fluidized bed reaction system. The project included identification of individual emission units, development of emission factors, and correction of discrepancies between the state point source database and the facility permits. Application of correlation curves instead of average emission factors allowed the facility to lower fugitive emissions approximately 30 tons per year for the emissions inventory. (Huntsman Corporation, Longview, Texas)
NSR Permit Amendments and Flexible Permit: New Source Review Permit Amendments and a Flexible Permit application were prepared to allow the facility to modify the product finishing area units. The scope of work included identification of state requirements, emissions estimation, preparation of the application, and extensive follow-up with the TCEQ to establish Flexible cap and Federal PAL and to negotiate the permit Special Conditions. (Huntsman Corporation, Longview, Texas)
Construction Permit: Prepared a TNRCC Construction Permit Application for the VA-5 Unit. The scope of work included emissions estimation for tanks (using EPA TANKS3 modeling and special spreadsheets), flares, cooling towers, process vents, etc. and the application preparation. (Union Carbide Corporation, Texas City, Texas)
Construction and Operating Permit Applications: Prepared emission calculations, CAD drawings, and application forms for construction and operating permit applications for dye and pigment manufacturing facilities. (Chicago Specialties Corporation Chicago, Illinois)
Risk Management Programs and Plans and RMP Audits: Prepared Program 3 RMPs for three chemicals. The scope included an identification of the RMP chemicals, development of Prevention programs, and preparation of submittal documents. Conducted off-site consequence analyses for sulfur dioxide, sulfur trioxide, and anhydrous ammonia including extensive dispersion modeling to estimate the worst-case and alternative release scenario end-point distances. Recommended strategies to reduce the endpoint distance and for communicating the risks to the public. (Chicago Specialties Corporation Chicago, Illinois)
Emissions Reduction Marketing System Application: Prepared emission calculations and ERMS forms for the facility. Scope of work included comparative analysis of the facility emissions and regulatory applicability for seven years and estimation of the baseline emissions for the ongoing years. (Chicago Specialties Corporation Chicago, Illinois)
Emissions Inventories: Prepared the emissions inventory for the petrochemical facility including emission unit identification, emission factor development, emission calculations, and completion of forms. (Petrolite Corporation Kilgore, Texas)
Permits by Rule: Prepared several dozens TCEQ Permit by Rule registrations for many companies in 1993 – 2004. (Various Clients – Various Locations, Texas)
Education/Professional Affiliations
- M.S. Meteorology and Climatology, Moscow State University, Moscow, Russia, 1979
- Air and Waste Management Association
- American Foundrymen's Society
- AutoCAD Drawings; Carter & Burgess, Fort Worth, Texas, 1994
- Air and Waste Management Association Workshops and Seminars, 1995 – 1999
- Texas Title V and Air Permitting Seminars, 1996 – 1998
- American Foundrymen's Society Texas Chapter Seminars, 1997 – 1999
- EPA's SARA 313 Reporting Workshop, 1999
- AFS Foundry Environmental Seminar 101, 2000
- BREEZE AERMOD and AERMET Training, 2002
- RTP Environmental Advanced NSR Workshop, 2004
- TCEQ Modeling and Environmental Compliance Workshop, 2004
Parmley, R.D., I. Shnayder, and S. Dillard, "Strategies for Modeling Facility Maintenance Emissions," to be presented at the National Air and Waste Management Association Conference, June 2004.
Larry has more than 17 years experience in the environmental compliance and permitting field with the majority of that experience in environmental consulting. Larry also served as the environmental solutions manager at one of the largest refineries in the United States where he managed costs, prioritized projects, and provided guidance to the refinery engineering and project groups on environmental aspects of capital projects. In this position, he also tracked and managed resolution of multi-media environmental audit findings generated during a multi-million dollar, multi-year audit. The remainder of Larry's experience was with the Texas Natural Resource Conservation Commission (predecessor to the Texas Commission on Environmental Quality, TCEQ) in the Office of Air Quality. He is a registered professional engineer in Texas, Louisiana, New York, Oklahoma, Montana, and New Mexico.
Mr. Darcey specializes in air quality permitting and compliance and is a nationally recognized expert on the BWON rule. He has worked BWON compliance issues at more than two-dozen refineries, including a wholesale re-development of a refinery TABs and uncontrolled benzene quantities, assistance with the negotiation and implementation of the Consent Decree BWON requirements, BWON sampling and sampling plan development, development of BWON compliance programs, and preparation of a BWON Consent Decree gap analysis for a refinery considering consent decree. In addition, Mr. Darcey has assisted multiple refineries in BWON enforcement negotiations with the Environmental Protection Agency. Mr. Darcey served as the BWON moderator at the 2006 National Petrochemicals and Refining Association (NPRA) Workshop, and has published and presented BWON related papers, including "BWON Compliance Benchmarking" at the NPRA Environmental Conference in September 2009, and 2003 Air & Waste Management Association Conference entitled "Documenting, Evaluating and Sustaining Compliance with the Benzene Waste Operations NESHAP". Larry has also led the training of over 200 environmental engineers from US petroleum refineries and petrochemical plants as a senior instructor for EnviroMod University's coursework, "BWON Essentials" and "BWON for Experts".
Larry also has the expertise in using approved EPA air dispersion models, such as the industrial source complex models, SCREEN3 and BPIP. He has completed multiple air dispersion modeling analyses from model execution to interpretation of modeling results and preparation of air dispersion modeling reports for TCEQ state health effects review, state property-line analyses, and PSD air quality analyses. Other expertise for Larry includes development of NOx SIP compliance plans, preparing air emissions inventories, preparing and reviewing Spill Prevention Control and Countermeasure (SPCC) Plans, performing site assessments, hazardous and solid waste management and NPDES permitting. His industry background encompasses a wide variety of facilities including refineries, petrochemical plants, crude oil and petroleum product pipeline facilities, manufacturing facilities, power plants, cogeneration facilities, and carbon black plants.
Key Expertise
- Personnel and Project Management
- Benzene Waste Operations NESHAP (BWON)
- PSD Air Quality Analyses and PSD/NNSR Permitting Strategies
- Environmental Compliance Auditing
- Environmental Compliance Program Development
- EPA/TCEQ Negotiations
- Litigation Support
- Air Pollutant Modeling
- Texas Title V Operating Permits
- New Source Review Permits
- Regulatory Analysis/Compliance
- Soil Sampling/Spill Site Assessment
- Emission Calculations/Inventories
- NPDES Permitting
- Solid and Hazardous Waste Management
- Spill Prevention Control and Countermeasure (SPCC) Plans
- Texas Railroad Commission Closures
Project Experience
Benzene NESHAPS FF Compliance
BWON Consent Decree Support: Managed the completion of all aspects of the BWON Enhancement portions of the Consent Decree, including Review and Verification, amended TAB Reports, development of management of change and control device standard operating procedures (including carbon canisters), development of waste/slop/off-spec oil management schematic, and End-of-Line Sampling Plan. Larry currently manages the development of a comprehensive compliance program for the refinery and the performance of end-of-line and other Consent Decree required sampling. (Sunoco Refining and Marketing, Inc. – Westville, New Jersey)
TAB Evaluation and Compliance Program Development: Managed the development and implementation of a compliance program for the ATOFINA Port Arthur Refinery. The program included a review of historical information and P&IDs. The points of generation were identified and highlighted on the P&IDs and the comprehensive sampling program was conducted, including full health and safety plans. A TAB report and quarterly report procedure were established. The report for the first year was completed. A comprehensive program was implemented for the monitoring, reporting, and recordkeeping requirements. (ATOFINA Port Arthur Refining L.P. – Port Arthur, Texas)
TAB Evaluation and Control Strategy Development: Managed a review of historical information and P&IDs to identify points of waste generation. The points of generation were highlighted on the P&IDs and the comprehensive sampling program was conducted, including full health and safety plans. The refinery TAB was developed and controls were evaluated to identify a cost effective control scheme to comply with the BWON under the 2 BQ compliance option. (Premcor Refining Group Inc. – Memphis, Tennessee)
General BWON Consulting Support: Assisted Premcor Port Arthur staff in identifying potential compliance issues and provided general question and answer support regarding BWON implementation and compliance. (Premcor Refining Group Inc. – Port Arthur, Texas)
Maintenance TAB Development and Organic Waste Identification: Developed the Ultramar Diamond Shamrock/Valero Three Rivers Refinery TAB for maintenance events including pump maintenance, filter change outs, and exchanger cleaning. Larry used mean time between failure records and SAP maintenance records to identify the maintenance frequencies. In addition, assisted the Refinery in identifying organic waste streams and developed a control scheme for those waste streams requiring control under the 6 BQ compliance option. (UDS/Valero – Three Rivers, Texas)
Consent Decree Support: Performed a documentation and verification of BWON waste streams and developed TAB and 6BQ reports required by EPA Consent. This effort included identifying waste streams, performing confirmation sampling, and recalculating total annual benzene quantities. (Marathon Ashland Petroleum, L.L.C. – Texas City, Texas)
Turnaround TAB Development: Assisted two refineries in New Mexico in estimating their Total Annual Benzene (TAB) from turnaround operations. This included performing the sampling of waste streams during turnarounds and calculating associated benzene quantities. (Navajo Refining Co. – Artesia/Lovington, New Mexico)
Air Quality Permitting
Larry specializes in air quality permitting and has prepared or assisted in preparation of over twenty new source review permit applications in Texas, Louisiana and Montana and several Title V permit applications, permits-by-rule, standard permits, voluntary emission reduction permits (VERPs) and changes-to-qualified facility (SB 1126) applications. His agency experience has allowed him to cultivate relationships with key agency personnel, thus making him proficient in agency negotiations.
NSR Permit Application with Emission Caps: Prepared a permit application utilizing site-wide emission caps. Prepared netting calculations related to establishing site-wide caps that also demonstrated the proposed caps and related projects did not require PSD review. (CENEX Harvest States Refinery – Laurel, Montana)
PSD Permit Application under Agreed Order: Assisted two carbon black facilities in developing a basis for retro-active PSD permit applications to explain why historical allowable emission rates were underestimated by the facility. Expedited permit application preparation to meet Agreed Order deadlines. (Engineered Carbons, Inc – Texas facilities)
Title V Program Development/Permit Review: As a member of the TNRCC Office of Air Quality was Project Lead for Title V forms development and reviewed several Title V permit Applications.
Other Air Quality Services
General Air Dispersion Modeling: Completed multiple air dispersion modeling analyses, including model execution, interpretation of modeling results and preparation of air dispersion modeling reports. (Various – Texas and Oklahoma)
Event Modeling: Provided air dispersion modeling support for evaluating actual impacts at an ambient air monitoring site in Texas, including the development of the actual meteorological data files used in running the EPA's ISCST3 model. (Confidential Client – Beaumont, TX)
Petroleum MACT Compliance Checklist: Prepared a checklist for implementation at a Texas refinery to evaluate compliance status with the Petroleum Refinery MACT. (Crown/La Gloria Refinery– Tyler, Texas)
PSD Air Quality Analysis: Performed a detailed PSD air quality analysis in order to estimate the maximum allowable emission increase without exceeding the PSD Increment or NAAQS for a source triggering PSD review. (Rohm and Haas – Deer Park, Texas)
Air Quality Modeling Design: Identified the required design stack parameters (i.e., stack height, stack diameter, flow rate, and exhaust gas temperature) to meet the NAAQS and PSD increment for a proposed cogeneration facility in Louisiana using an iterative modeling approach. (Degussa Corporation – Ivanhoe, Louisiana)
Air Emissions Inventories: Completed multiple emission inventories for a complex chemical plant in southeast Texas. (ATOFINA Chemicals, Inc. – Crosby, Texas)
BACT Analysis: Prepared a BACT analysis for carbon black operations. (Degussa Corporation – Aransas Pass, Texas)
HSE Management Systems
Environmental Management System: Managed the development and implementation of an environmental quality management system and powerful compliance tool for a major southwest Louisiana chemical manufacturing complex. (Vista – Lake Charles, Louisiana)
Air Source Authorization Management: Developed a database that codifies a chemical facility's air permit authorizations, exemptions, emission rates and regulatory applicability. (Chemical Plant – Texas Gulf Coast)
Auditing and Assessment
Refinery Multi-Media Compliance Audit: Assisted in managing a comprehensive multi-media compliance audit at a major Gulf Cost refinery under the Texas Audit Privilege Act. This included coordinating the development and utilization of audit checklists, performing auditing activities, and developing portions of and publishing the audit report. (Confidential Client – Texas Gulf Coast)
Post-Acquisition Compliance Support: Managed multi-media, post-acquisition, compliance assistance activities for a client that purchased numerous facilities. This multi-media compliance assistance included air permitting strategies, development of Spill Prevention Control and Countermeasure (SPCC) and Storm Water Pollution Prevention (SWP3) Plans, and evaluating waste management activities. (Hanson Brick America – Multiple Facilities)
Texas Railroad Commission Site Assessment: Performed sampling and site assessments at crude oil spill sites for crude oil gathering and transmission pipelines. Projects included interpretation and preparation of over 25 remediation and closure reports as required by the Texas Railroad Commission's Rule 91. In addition, prepared cost analyses required for spill remediations and tank firewall rebuilds. (FINA/Holly Corp – Big Spring and Vicinity, Texas)
Air Permit Audit: Performed an extensive air permit and continuous emissions monitoring system audit under the Texas Audit Privilege Act. (AES Deepwater – Pasadena, TX)
Spill Prevention Control and Countermeasure Plans
Larry has prepared or assisted with the preparation and/or review of multiple SPCC Plans under the provisions of 40 CFR Part 112. In addition, he consulted with the EPA on the development of the amended rule and has become familiar with the intricacies of the rule changes. Prior to the extension to the SPCC revision date in the amended rule, he had updated and certified several Plans pursuant to the rule changes.
SPCC Plan Development: Developed the SPCC Plan for a manufacturing facility in Texas. Performed a site assessment to identify oil storage and handling facilities and developed a plot plan identifying the locations and contents of each container and indicate a prediction of spill directions. (Trane, A Division of American Standard – Tyler, Texas)
Plan Updates for Rule Changes: Amended and certified the SPCC Plans for multiple iron production facilities in Texas. Larry provided guidance to the facilities to assist in the development of procedures to perform tank inspections. (EBAA Iron – Texas facilities)
Refinery SPCC Plan Review: Performed a review and quality assurance/quality control of a modified SPCC Plan for a West Texas refinery. Larry assisted in developing documentation to demonstrate that sufficient containment was available in the event of a catastrophic spill. (Alon – Big Spring, Texas)
- B.S. Engineering, Environmental and Natural Resources Specialty, Texas A&M University, 1997
- Air and Waste Management Association
- American Academy of Environmental Engineers
- National Petrochemical and Refiners Association
License Registration
Professional Engineer in the following states:
- Texas No. 90118
- New Mex. No. 15979
- Montana No.: 15667
- Louisiana No.: 30470
- Oklahoma No.: 20971
- NY No.: 080747
Darcey, Larry G. "Integration of the Texas Title V and New Source Review Programs, the Consequential Effect on Permittees, and Related Systemic Compliance Strategies." Air and Waste Management Association's 95th Annual Meeting and Exhibition, June 24, 2002, Baltimore, Maryland, USA.
Darcey, Larry G., P.E.; and Steven M. Probst, P.E. "Documenting, Evaluating and Sustaining Compliance with the Benzene Waste Operations NESHAP." Air and Waste Management Association's 96th Annual Meeting and Exhibition, June 26, 2003, San Diego, California, USA.
Darcey, Larry G., P.E., Moderator, "Managing Facility SSMMU Activities Under the Clean Air Act: Benzene Waste Operations NESHAP", National Petrochemical and Refiners Association, 2006 Environmental Workshop, September 17, 2006, San Antonio, Texas, USA.
Randy has over 33 years experience in air quality consulting. His experience encompasses almost every aspect of air quality in the petroleum industry. Randy has worked extensively with the refining, petrochemical, and terminals industries and has a strong reputation preparing and negotiating large and complex Flexible, PAL, PSD, Maintenance Startup and Shutdown (MSS) and Title V permitting Projects as well as providing Consent Decree support. He has conducted regulatory, permitting, and modeling seminars in North America, South America, Europe and Asia. Randy's expert witness experience includes contested permit hearings, serving as a neutral mediation expert in merger and acquisition disputes, disaster/event modeling evaluations and testimony, and a variety of health-effect related toxic tort support efforts. He has provided deposition support to numerous legal clients, been disposed on several occasions, and testified in court for several industrial clients. His engineering and air quality background enable Randy to evaluate and communicate complex emission release and modeling concepts in an understandable and credible manner. As a result he has been used by such firms as Fulbright & Jaworski, Baker –Botts, Jones-Day, Morgan-Lewis, Curtis, Mallet-Provost, Benchenstein & Oxford, Rodriquez, Colvin & Chaney and numerous other firms for expert witness support.
Randy's experience in working with capital project design teams to develop environmental analyses, NOx SIP evaluations, air regulatory compliance assessments, toxic risk evaluations, control strategy applications, and a variety of air-related and interdisciplinary environmental consulting applications complete his professional profile.
Randy currently services as Executive Vice President of Sage Environmental. In this role, he is responsible for developing and managing a group of dedicated air quality consultants serving client needs both in Sage's Gulf Coast offices and at client facilities.
Key Expertise
- Air Permitting – Large Facility PSD Expansion Projects, Complex Bubble (i.e. PAL and Flexible) Permitting, MSS Permitting
- Dispersion Modeling
- Air Control Strategy Applications
- Air Monitoring and Sampling
Executive Vice President, Gulf Coast Marketing Leader, Sage Environmental Consulting, August, 2001 through Present
Manager, On-Site Business Services, URS Corporation Houston, 1999-2001
Principle Engineer, URS Corporation, 1998 - 2001
Senior Consultant, McCulley, Frick, and Gilman, April,1998 - September, 1998
Senior Staff Project Director, Radian Corporation, 1994- April, 1998.
Section Head, Air Regulatory Analysis, Radian Corporation, 1993-1994.
Group Leader, Atmospheric Sciences, Radian Corporation, 1991-1993.
Senior Engineer, Radian Corporation, 1989-1994.
Consultant/Environmental Engineer, Austin, TX, 1984-1988.
Staff Engineer, Radian Corporation, Austin, TX, 1983.
Environmental Engineer, Radian Corporation, 1981-1982.
Environmental Engineer, U.S. EPA, Region 6, 1980-1981.
Environmental Engineer, LACE Engineering, Austin, TX, 1979.
Environmental Engineer, University of Texas Center for Energy Studies, 1978.
Project Experience
Air Permitting, Emission Inventory, and Modeling
Randy's recent technical responsibilities include preparing, negotiating, implementing and providing compliance support for existing permits and pending permits for several large Gulf Coast refineries and chemical manufacturers. Randy has served as principal in-house consultant for large capital projects involving refinery coker units, fluid catalytic cracking units, low sulfur motor gasoline units, and sulfur conversion units as well as the development and implementation of complex bubble concept permitting, and Title V permitting. Randy's responsibilities during
these assignment included working closely with refinery economic planners and field operation managers as well as with environmental staff. Through this multi-year effort, Randy gained a detailed and working knowledge of refinery operations and applicable regulations affecting refinery operations. Randy was the Project Manager and Lead Negotiator for the only Refinery Federal Plant-wide Applicability Limit (PAL) permit yet issued in the United States (ExxonMobil Baytown Refinery). He has also negotiated PAL permits including MSS activities for the Chemical clients.
Randy served as Project Director of the largest permitting project in EPA Region 6 history, the multibillion-dollar expansion of a complex plastics manufacturing complex on the Gulf Coast. The project included extensive dispersion modeling and BACT analyses. For this client, Randy also served as project manager for conducting the only point-source ozone modeling effort completed in Texas.
Randy has extensive experience in data development and prerequisite information to run EPA-approved atmospheric dispersion models. Randy is proficient with AERMOD, the Industrial Source Complex models, various Episodic and Climatological models, and several disaster models. Randy has served as Project Director on numerous special studies modeling projects ranging from model comparisons projects to radioactive disaster modeling.
Randy has served as an expert witness in dispersion modeling for contested permit hearings, event simulations, toxic risk evaluations, and a variety of toxic tort cases. He has used his modeling experience and biological background to perform toxic risk assessment for the refining, synthetic organic chemical metallurgical, pharmaceutical, and refining industries for both regulatory and legal purposes.
Randy has served as Project Director for several international modeling application projects involving neural net technology for predicting next day ozone pollution episodes. Randy has served as Project Director and key modeling contact on several Department of Energy RCRA permit projects involving open burning/open detonation activities. Randy served as Project Director for a Clean Air Act Amendment Title V permitting effort for one of the largest refineries in the United States. For this effort, Randy utilized his Title V expertise to direct the permit strategy, emission inventory development, air audit, compliance demonstration, and permit application tasks for this extensive permitting project. Randy has also completed other Title V strategy manual projects addressing site-specific considerations for SOCMI and refining clients. Randy has directed numerous Title V permit applications for various petroleum marketing and pipeline clients. Randy has played a key role in assisting clients with Section 114 issues and has developed numerous alternative monitoring procedures (AMPs) for submittal to EPA.
Air Control Strategy Applications
Randy served as a key engineer in the development of a streamlined permitting approach for selective catalytic reduction technology as part of a joint refinery/TNRCC task force.
Extensive knowledge of air pollution abatement technology and engineering principles to evaluate air pollution controls strategies for Lowest Achievable Emission Rate (LAER), Best Available Control Technology (BACT) and Reasonably Available Control Technology (RACT) for permitting and process modification studies.
Consulting services to the Texas Air Control Board (predecessor agency to TCEQ) involving the characterization, control options, and costs of controlling VOC sources in the Harris County area as part of the Texas SIP development process. Randy served as an EPA Region 6 Control Technology Specialist for State Implementation Plan applications. Randy has prior experience with Flue Gas Desulfurization (FGD). Published technology reviews for both United States and Japanese Processes. Analyzed and presented papers on market resource recovery potential for various FGD processes.
Air Monitoring and Sampling
Randy has experience with the establishment and management of local and regional ambient air monitoring networks. He designed the air monitoring network in Monterrey, Mexico and Alba Iulia, Romania. Randy served as data editor and coordinator for Houston Regional Monitoring (HRM) and PSD monitoring Networks. Prepared Radian's in-house PSD Ambient Air Monitoring Operator's Manual. Randy has experience with the design of field measurement studies to quantify emission factors for the open burning of explosives. Randy was assigned Project Director for several efforts to define and establish continuous emission monitoring and reporting requirements for industrial sources in Thailand and Chile. He served on a TNRCC working group to define and develop appropriate continuous monitoring and parametric monitoring protocols for a wide range of industry types.
Education/License Registration
- B.S. Environmental Engineering, University of Texas, Austin 1979
- B.S. Natural Science/ Chemistry, 1976
- State of Texas Professional Engineers License No. 75280
Professional Societies
- Awardee U.S. EPA Pollution Fellowship, 1978-1979
- Air and Waste Management Association
- Parmley, R.D., I. Shnayder, and S. Dillard, "Strategies for Modeling Facility Maintenance Emissions," presented at the National Air and Waste Management Association Conference, June 2004
- Parmley, R.D., "An Evaluation of the Flexible Permit/PAL Program in Texas", Presented at the National Petrochemicals and Refiners Association Annual Environmental Conference in New Orleans, Louisiana, April 2003.
- Parmley, R. D. "Recommendations for a Continuous and Parametric Monitoring and Reporting Program for Chile", May 1998.
- Parmley, R.D., T.DeFries, "Development of a Neural Net Model to Predict Next Day Ozone Concentrations in Bangkok, Thailand." Presented at the Pollution Control '97 International Conference in Bangkok, Thailand.
- Parmley, R.D., G.Baker, "Feasibility Study for the Modernization of the Air Quality Monitoring Network in Venezuela", Presented at the Pollution Control '97 International Conference in Bangkok, Thailand.
- Parmley, R. D. "Recommendations for an Industrial Monitoring and Reporting Program to Comply with Section 80 of the National Environmental Quality Act", March 1996.
- Parmley, R.D., D. Schmitt, "Calculation Methodologies for Refinery Flexible Permit Applications", June 1995.
- Parmley, R.D., S.A. Smith, "Comparison of ISC and HEM Modeling Approaches and Evaluation of Other Toxic Risk Uncertainties", Radian Corporation, presented at the National Air and Waste Management Association Conference, 1992.
- Hunt, M. and R.D. Parmley, "Predicting Ozone Concentrations with RPMIISS," Radian Corporation, presented at the National Air and Waste Management Association Conference, 1991.
- Parmley, R.D., Site-Specific Evaluation of Potential Cancer Risk Associated with Ethylene Oxide Emissions from the Texaco Chemical, Port Neches Facility. Radian Corporation, December 1990.
- Smith, S. and R.D. Parmley, Site-Specific Evaluation of Potential Cancer Risk Associated with 1, 3-Butadiene Emissions from the Texaco Chemical, Port Neches Facility, Radian Corporation, April 1990.
- Parmley, R.D., Handbook of Chemical Analyses for FGD Operators. Prepared for the Electric Power Research Institute, San Jose, CA, 1983.
- Gates, N. and R.D. Parmley, "NOx and SOx Flue Gas Removal Technologies in Japan," Radian Corporation, Austin, TX, 1982.
- Parmley, R.D., Radian's PSD Operating Manual. Austin, TX, 1982
- Parmley, R.D. and P. Murin, "Characterization of VOC Emission Sources and Potentially Applicable Emission Control Technologies," Radian Corporation, Austin, TX, 1981.
- Parmley, R.D., "Cost of Controlling Previously Uncontrolled Sources of VOC Emissions in Harris County," Radian Corporation, Austin, TX, 1981.
- Parmley, R.D. and H.R. Parish, "Resource Recovery Cost for the Electric Power Industry," presented at the Electric Power Industry Conference and at the American Chemical Society Conference, 1980.
- Parmley, R.D. and H.R. Parish, "Present Status of Development of Flue Gas Desulfurization in the United States," Center for Energy Studies Press, 280 pages, 1979.
Scott has over 20 years of experience as an environmental specialist, senior project manager, client service manager, and division manager. Scott specializes in Clean Air Act consulting, providing regulatory analysis and technical assistance in all aspects of air quality permitting, environmental agency relations, compliance and due diligence auditing, permit flexibility, regulatory applicability, rule compliance strategy, environmental data management and compliance enhancement. Experience includes international Environmental Impact Assessment permitting for a major petrochemical complex development, HSE due diligence for a multi-site international petrochemical acquisition, state and federal New Source Review (NSR) permitting of expansions and modifications, Title V permitting, compliance auditing, compliance systems development, agency negotiations, emission reporting, and air dispersion modeling. Scott is a graduate of Washington University in St. Louis with a B.S. in Engineering and Public Policy. He also holds a B.A. in Mathematics from Austin College.
Key Expertise
- New Source Review Permitting
- Benzene NESHAP FF Compliance
- Title V Permitting
- HSE Due Diligence and Transaction Support
- Compliance Auditing
- Risk Management Program
- Environmental Data Management Systems
- MACT Standard Implementation
- Project Management
- Air Dispersion Modeling
- TCEQ Agency Negotiations
Project Experience
New Source Review Permitting
New Source Review Permitting: Refinery Modification: Client Service Manager/Project Manager: Responsible for developing permit strategy to obtain a Prevention of Significant Deterioration (PSD) permit in four months for a major refinery expansion/modification project to produce low sulfur gasoline and ultra-sulfur diesel. Project required:
Review and re-calculation of emission inventory information to accurately estimate prior two-year average actual emissions, complete contemporaneous netting review for multiple compounds (no PSD permits issued within the last five years at the site).
Scott performed air dispersion modeling for multiple compounds to demonstrate compliance with the PSD Increment and National Ambient Air Quality Standards (NAAQS), including first-time construction of modeling files and resolving problematic TNRCC retrieval information for neighboring facilities.
Resolution of BACT issues for multiple sources, including heaters, fugitives, the Sulfur Recovery Unit and the Fluid Catalytic Cracking Unit.
Documentation of TNRCC health effects review for emission increases of hazardous air pollutants (HAPs) and hydrogen sulfide.
Project involved permit strategy development with legal counsel, interface with TNRCC to facilitate permit review, permit condition negotiation, and start of construction issues. (Ultramar Diamond Shamrock — Three Rivers, Texas)
Fluid Catalytic Cracking Unit Expansion: Project Manager: Scott managed the completion of an air quality permit to expand the FCCU capacity greater than 5,000 barrels/day. The project required upstream/downstream affects determination, PSD permitting and associated air dispersion modeling, resolution of BACT issues (including negotiation of no additional controls on the FCCU), permit condition negotiation, and compliance assistance. (Ultramar Diamond Shamrock — Sunray, Texas).
Numerous Air Quality Permitting Projects: Division Manager: Scott managed an air quality division, including oversight of up to fifteen air quality engineers and professionals. In this capacity, Scott interfaced with air quality staff, project managers and clients to provide permitting strategy, issue resolution, environmental agency representation and project leadership. (Representative clients include AES, Union Carbide Corporation, Valero Refining, WR Grace, GNB Technologies, Fina Oil and Chemical, Ashland Chemical Company, Ultramar Diamond Shamrock, Cabot Corporation, Witco Corporation)
Refinery Expansion: Project Engineer: Prepared a permit application for grass roots crude unit to process heavy sour crude at the Houston refinery. Permitting flexibility issues addressed construction unknowns and future plant operations. He provided guidance on standard exemption authorization for process changes at an existing crude unit. Project required several site visits and meetings with key Lyondell-Citgo personnel. (Lyondell-Citgo Refining Company, Ltd. — Houston, Texas)
Air Permitting: Task Manager/Project Engineer: Prepared permit amendments simultaneously for four major production units at a specialty chemical company's Bayport Plant. Permit amendments consolidated existing permits and standard exemptions into one permit for each unit. Permitting resolved historical permitting discrepancies and addressed future operational flexibility. Responsible for guidance on permit strategy, permit organization, emission calculations and permit preparation. Permitting required documenting standard exemptions for immediate equipment installation, addressing common emission abatement for multiple units, developing flexible unit throughput representations and worst-case emission estimates, resolving health effects concerns, and negotiating permit provisions for each production unit. (The Lubrizol Corporation — Houston, Texas)
Benzene NESHAP FF Compliance
Subpart FF Compliance Plan – Petroleum Refinery: Project Manager: Sampled waste streams that accounted for approximately 90% of TAB quantity, completed the refineries 1997 TAB report, standardized reporting procedures, and developed proper compliance documentation.
Subpart FF Auditing – Petroleum Refineries: Project Manager/Technical Lead: In conjunction with Title V, Scott has audited two petroleum refineries for compliance with the 40 CFR Part 61, Subpart FF requirements, including review of waste streams, point of generation determinations, waste flowrate determinations, benzene concentration sampling and process knowledge determinations, and maintenance/turnaround planning.w
Numerous Title V Permitting Projects: Division Manager: Scott managed an air quality division, including oversight for fifteen air quality engineers and professionals. In this capacity, Scott interfaced with air quality staff, project managers, and clients to provide permitting strategy, issue resolution, environmental agency representation, and project leadership. (Representative clients include BP Chemicals, Union Carbide Corporation, Valero Refining, GNB Technologies, Fina Oil and Chemical, Ultramar Diamond Shamrock, BASF Corporation, Cabot Corporation, Witco Corporation)
Title V Application – Multiple Chemical Complex: Client Service Manager/Project Manager: Responsible for client and project management of all aspects of the Title V application preparation for two major chemical facilities. Project management required Title V application oversight for greater than 25 process units and 10 project engineers. Scott assisted in developing the Title V application for multiple process units and each facility, including completion of the following Title V tasks: Data Analysis, Emission Unit Reconciliation, Applicable Requirement Identification, Application Strategy Development, Application Preparation and Database Population. In addition, Scott tracked regulatory developments throughout the Title V project, such as state and federal Title V rule changes and the Compliance Assure Monitoring (CAM) rule.
Title V Application – Petroleum Refinery: Technical Lead: Responsible for reviewing the regulatory citations for all Title V applicable requirements for all affected emissions units at a petroleum refinery. The Title V review included applicability and compliance evaluations of all emission standards, and monitoring, recordkeeping, and reporting requirements, for all Federal and State SIP regulations. Project also included detailed evaluation of General Provisions, future MACT requirements, and CEMS requirements (40 CFR Appendix Band F). Project required auditing current compliance with Title V applicable requirements based on on-site inspections, personnel interviews and records review.
Title V Applications – Metal Industries: Task Manager/Project Engineer: Responsible for complete Title V permit application preparation and issue management, including initial data gathering, operating scenario identification, air emissions calculations, applicable requirements evaluation, compliance status determination, and proposed compliance monitoring preparation. Scott specialized in Title V applicable requirement identification and compliance status determinations. Recent clients within this industry include the following:
- Eljer Manufacturing, Gray Iron Foundry (Cupola Process), Salem, Ohio
- Commercial Intertech, Gray Iron Foundry, Youngstown, Ohio
- Ohio Cast Products, Gray Iron Foundry, Canton, Ohio
- Wabash Alloys, Secondary Aluminum Production, Cleveland, Ohio
- ML-KS, Inc., Brass Production Plant, Greensburg, Indiana
Title V Application – Chemical Complex: Project Engineer: Responsible for the evaluation of the draft Title V permit application developed by Ashland environmental staff, to verify applicable requirements, identify compliance issues, and assure administrative completeness for a specialty chemicals plant. Reviewed Federal and State applicable requirements, and evaluated compliance issues based on application representations and proposed operating scenarios. He helped develop proposed compliance monitoring methods to minimize future recordkeeping and reporting requirements of the Title V permit. (Ashland Chemical Company — Ashland, Ohio)
Title V Application – Automotive Manufacturing: Project Engineer: Responsible for complete Title V permit application preparation and issue management at a heavy-duty truck assembly plant for Navistar International. Project work included on-site identification of sources, review of Federal and State permits, calculation of air emissions, regulatory evaluation of applicable requirements, evaluation of compliance status, preparation of compliance demonstration methods, development of model Title V permit and presentations to Navistar corporate and environmental personnel. (Navistar International — Springfield, Ohio)
Title V Application – Automotive Manufacturing: Project Engineer: Responsible for the complete evaluation of the final Title V permit applications for three automotive assembly plants and motorcycle assembly plant. Scott reviewed Title V applicable requirements, compliance demonstration methods, emission calculations, and application completeness issues. He helped client correct applicable requirements and revise proposed compliance methods to minimize Title V permit requirements. (Honda of America Manufacturing)
Title V Application – Consumer Products Industry: Project Engineer: Responsible for identification of applicable requirements and evaluation of compliance status for consumer product manufacturing operations and polystyrene manufacturing operations at S.C.Johnson's Racine, Wisconsin facility. Established proposed compliance monitoring, recordkeeping, and reporting methods for all affected emission units, developed a compliance evaluation document to record the basis for each applicable requirement citation and proposed monitoring method. (SC Johnson and Son, Inc. — Racine, Wisconsin)
Risk Management Program
RMP Compliance Plan – Multiple Chemical Plant: Project Manager: Responsible for developing a comprehensive guidance document for Risk Management Program (RMP) implementation at guidance 15 major petrochemical and polymer manufacturing facilities for Huntsman Corporation. At seven of these facilities, developed detailed RMP rule implementation plans and assisted with RMP Applicability, Hazard Assessment, Prevention Programs, Emergency Response Program, Risk Management Plan, Risk Communication, Regulatory Background and General Duty Clause Implications.
Compliance Auditing
Compliance Auditing: Project Engineer: Performed an extensive compliance audit on the marine loading, tank farm, chlorine unloading, caustic/chlorine production, utilities and wastewater units located in Point Comfort, Texas facility. Audit included review of compliance with applicable Federal and State regulations, permit requirements, compliance manuals, recordkeeping, reporting, and management practices. Scott conducted on-site inspections and interviews with plant personnel for each unit. He summarized applicable regulations, compliance performance and recommendations for each unit. (Formosa Plastics — Point Comfort, Texas)
Compliance Auditing: Project Engineer: Participated in a multi-media audit to determine compliance with all applicable Federal and State regulations at a cement kiln hazardous waste combustion facility. Scott analyzed compliance with applicable air regulations. Reviewed facility operations, permit provisions, standard exemptions, recordkeeping, performance tests, and reporting requirements. Specific RCRA regulations also reviewed for applicability and compliance. Summarized audit findings and provided recommendations. (Confidential Client — Texas)
Muller, S. and S. Dillard, "MACT Implementation at Iron Foundries: Lessons Learned," presented at the 18th AFS Environmental, Health & Safety Conference, Nashville, Tennessee, September 2006.
Sage Environmental Consulting, "Managing Facility Startup Shutdown, Maintenance, Malfunction and Upset (SSMMU) Activities Under the Clean Air Act"; National Petrochemical and Refiners Association; Annual Environmental Conference; Sunday Workshop; 2006. Sage Environmental Consulting, "Leak Detection and Repair"; National Petrochemical and Refiners Association; Annual Environmental Conference; Sunday Workshop; 2004.
- B.S. Engineering and Public Policy, Washington University, St Louis, Missouri, 1992
- Minor - Environmental Engineering, Washington University, St. Louis, Missouri, 1992
- B.A. Mathematics, Austin College, Sherman, Texas, 1992
Tom is a degreed chemical engineer with experience in a variety of compliance areas, with his knowledge-base in air-related environmental compliance. Tom started with Sage in 2011, and has worked in over 25 facilities and two countries since started. In addition to normal engineering work, Tom has spent the last two years in an executive leadership development role in which he split time between engineering and business with Sage's leadership group, working throughout the various departments and learning the models Sage runs on. Tom currently serves in the roles of a project manager and a project technical. Tom's areas of technical expertise include Leak Detection and Repair (LDAR), flare system analysis and compliance, reciprocating internal combustion engine (RICE) compliance, Title V permitting, Illinois EPA construction permitting, EI/TRI Reporting and emissions calculations, as well as NESHAP compliance, particularly HON, MON and BWON.
Key Expertise
- LDAR Program QA/QC, Inventory QA/QC, Procedural Review, and Auditing
- Low-Leaking Valve and Valve Packing Technology and Enhanced LDAR Program (ELP) Implementation
- Flare System Compliance and Analysis
- Reciprocating Internal Combustion Engine (RICE) Compliance
- Benzene Waste Operations NESHAP (BWON)
- Title V Air Permit Renewals
- Continuous Emissions Monitoring System (CMS) QA/QC and Maintenance
- NSPS/NESHAP/MACT Compliance
Project Experience
Leak Detection and Repair (LDAR)
Chinese LDAR Program Implementation: Engineer/Project Manager: Provided a technical support and QA/QC role on the implementation of one of the first cutting-edge LDAR programs in China for a 175,000+ component facility. The implementation effort covered a fugitive emissions rule in China for one of the largest facilities in the north. This required detailed review of facility piping and instrumentation diagrams (P&IDs) and process flow diagrams (PFDs), followed by field work including flagging, tagging, documenting, and monitoring of LDAR applicable components and lines. Additionally, a cutting-edge Environmental Intellect (Ei) software was employed with a GuideWare database to deliver a maximum quality program to the client. Sage had a team of two Chinese LDAR engineers with local management accompanied by a fleet of Sage's US LDAR experts in the business unit to provide top-notch experience from industry leaders such as Bronson Pate and Buzz Harris. (Petrochemical Client)
Consent Decree ELP Low-Leaking Technology Implementation: Engineer/Project Manager: Assisted the refinery client with the implementation of the Enhance LDAR Program as outlined by their Consent Decree. Throughout the last half of the project, transitioned into providing project management support (More than $200,000 revenue – including tracking task status and providing weekly updates) to the Client Service Manager. Interfaced with five (5) departments (i.e. Environmental, Engineering, Maintenance, Procurement, Operations) to ensure procedures were in place such that every valve brought onsite and installed on a hydrocarbon line was considered "low-emissions", per the Consent Decree. This effort involved interviewing several individuals, including department management, to discuss communication practices and areas to integrate new practices and improve upon current practices. LDAR-applicable P&IDs were reviewed and field verified for proper tagging, LDAR procedures were updated to the Consent Decree standards, training for separate disciplines was updated, and compliance assurance checks were created and followed pursuant to the CD. (BP Corporation – Whiting, IN)
Consent Decree ELP Implementation: Project Manager: Assisted the client with the implementation of the Enhanced LDAR Program as outlined by their Consent Decree (CD). Specifically, performed a thorough "Least Likely to Leak" connector analysis in order to identify the connectors (e.g., flanges, threads, etc.) that served the process conditions and performed the best. Additionally, worked with Solutia and INEOS personnel to ensure every valve in hydrocarbon service that leaked above 250 parts per million (ppm) was re-installed in accordance with the definition of "low-emissions valve (and valve packing) technology" (or "Low-E"), as per the Consent Decree. During this "least likely to leak" review and the Low-E program development, interfaced with five (5) departments (i.e., Environmental, Engineering, Maintenance, Procurement, Operations) to ensure procedures were in place to meet the CD requirements for each, respectively. This effort involved interviewing several individuals to discuss communication practices, improve current practices, and integrate new practices where possible. Finally, training for separate disciplines was created to satisfy the new CD requirements, and compliance assurance checks were created and followed pursuant to the CD. (Solutia Incorporated/INEOS Melamines LLC - Springfield, MA)
Consent Decree ELP Implementation: Project Manager: Acted as project manager and tracked the scope, schedule and budget for the implementation of the Enhanced LDAR Program at the chemical plant client. Managed the execution of onsite LDAR program QA/QC, CD-required Quarterly QA/QC, and 3rd Party Audit. In addition, generated weekly progress reports with budget updates and action items, and interfaced with the client on a weekly basis. Performed a LDAR program QA/QC at the facility that consisted of reviewing P&IDs for LDAR highlighting, walking down lines for LDAR tagging, reviewing LDAR program records, and the program manual. (BASF Chemical Corporation – Wyandotte, MI)
Consent Decree LDAR Audits: Engineer: To date, has assisted Mr. Buzz Harris and Mr. David Ranum in three (3) LDAR audits, as required by LDAR Consent Decrees (CDs) for several different companies. Performed comparative monitoring with Buzz Harris on the various component types (i.e. valves, pumps). Shadowed several LDAR technicians and provided feedback on monitoring technique. Reviewed calibration records and assisted in close-out meeting. (Multiple Refinery Clients)
LDAR Speciation/Support Services: Engineer: Characterized PFDs and P&IDs based off of NSPS Subpart VV applicability and highlighted accordingly. Field-verified the P&IDs and isometrics based off of LDAR highlighting. Helped develop a site-specific speciation workbook detailing LDAR highlighting assumptions. (SABIC Innovative Plastics – Ottawa, IL)
Consent Decree ELP Implementation and HON/MON Support: Engineer: Acted as lead engineer for the update of the facility LDAR plan and HON/MON Notification of Compliance Status (NOCS). Traveled onsite to collect data and interview site personnel. Assisted in development of trainings, review of MOC process, and general LDAR compliance support. (Dover Chemical Corporation -Dover, OH)
Refinery LDAR Program QA/QC: Engineer: Performed overall QA/QC of refinery LDAR program. This included a gap assessment of LDAR-applicable P&IDs and isometrics, field verification of suspected gaps, shadow monitoring on Method 21, database review for compliance gaps, and various other aspects of the LDAR program. (ExxonMobil Corporation – Joliet, IL)
Flare Systems and Compliance
Corporate Flare Consent Decree Compliance Review: Engineer: Interfaced with three (3) refinery environmental departments and engineering to track the status of compliance with flare systems (NSPS Ja, Consent Decree). The review consisted of an interview environment where various topics were discussed, including: flare and waste gas mapping, waste gas minimization, instrumentation and monitoring systems, flare management plans, flare gas recovery assessments, emissions calculation methodology and basis, etc. Generated and updated a Frequently Asked Questions (FAQs) document to share and clarify various issues for Marathon refineries and provide corporate guidance. (Marathon Petroleum Company – Findlay, OH)
Flare Compliance Program Development and Implementation: Engineer/Project Manager: Provided project management and onsite technical engineering support for eight refinery flares subject to both NSPS Ja and a Flare CD. The project support included the review of monitoring systems chosen for the systems, creation of NSPS Ja FMPs for each flare system, creation of a Data and Monitoring Systems Protocol (DMSP) Report, training development to address flare operation, amongst other day-to-day flare compliance tasks. Throughout the entire project, incorporated each project deliverable into a site "Flare Compliance Plan", which overviews and covers the compliance requirements the flares are subject to and how to maintain initial and continuous compliance. Additionally, managed two onsite engineers in day-to-day flare compliance tasks as related to both NSPS Ja and the Consent Decree. (BP Corporation – Whiting, IN)
NSPS Ja Flare Management Plan (FMP: Engineer: Reviewed a refinery cascaded flare system for header tie-ins (PRVs, blowdowns, etc.), monitoring systems, ignition systems, and flare tip schematics for a newly constructed Secondary flare. Used the information taken from the review and drafted a Flare Management Plan (FMP), in accordance with NSPS Ja. The flare system, including flare tip, knockout drum, monitoring and control valve seal were characterized in the plan, as well as flare minimization efforts, sulfur and flow monitoring, and corrective action plans. (Wyoming Refining Company – Newcastle, WY)
CEMS and Flow Meter QA/QC Manual Development: Engineer: Served as the primary technical resource for the analysis of Appendices B and F of 40 CFR Part 60 against the facility Consent Decree for CEMS QA/QC requirements as related to flare systems. The CEMS manual was developed as a template for six (6) refineries and provided applicability determinations for CGAs, RAAs and RATAs on both routine flow flares and non-routine flow flares. In addition, provided QA/QC support for the creation of a template Flow Meter manual for the same flare systems. (Marathon Petroleum Company – Findlay, OH)
Sage Flare Essentials Training Development: Engineer: Assisted Troy Boley, Herman Holm, and Derick Kopp in the development of training slides for Sage's first Flares Essentials Class in November of 2012. Focused on regulatory background behind NSPS Ja, programmable logic and control schemes on flare systems, and waste gas and flare header mapping. (Sage Environmental Consulting, L.P. – Atlanta, GA)
Distributed Control System (DCS) Calculations Manual for Refinery Flare System: Engineer: Served as the primary technical resource for the creation of the flare system calculations manual and the integration of the calculations into the DCS control logic scheme. The calculations described in the manual are the basis for the control scheme of the flare system. The base data set used for the calculations (i.e., vent gas flow rate, molecular weight of vent gas, temperature, pressure) is collected by the instruments online the flare header. The results of the calculations feed into the control logic and regulate the steam and supplemental fuel addition to the flare stack accordingly. (Refinery Client)
Reciprocating Internal Combustion Engine (RICE) Compliance
RICE Program Development and Implementation: Project Manager: Built the refinery RICE program from the ground up by assessing initial applicability of RICE determined to be "stationary" from a field walk, in accordance with the RICE regulations. Developed a site specific program manual, focusing on RICE tracking and determining applicability in the long term. Throughout the whole project, provided miscellaneous regulatory support for RICE questions, including additional RICE applicability determinations, emissions reductions options under MACT ZZZZ, and continuous monitoring systems (CMS) applicability. (P66 Corporation, Wood River IL)
RICE Compliance Manual Development: Engineer: Aided in development of Sage-issued compliance manual detailing the three RICE regulations (NSPS IIII/JJJJ, MACT ZZZZ). Worked on development of defining "Location" in the RICE rules, which consisted of a discussion with Marathon Corporate and EPA representatives. Generated location example for engine application in current manual following determination. (Marathon Petroleum Company – Findlay, OH)
RICE Program Development and Implementation: Engineer/Project Manager: Tom has been the primary project manager for the implementation of the RICE program at Robinson for the last three years. Activities performed include field-walking the Robinson refinery to perform an initial survey of the number of engines on-site and potential areas of concern. Tom also utilized the initial inventory and data provided by site to make applicability determinations based off of fuel used, model year and horsepower. Identified potential compliance concerns and communicated with environmental, process and contractors on compliance options and path forward. Developed a site specific program manual to ensure long term management and compliance of the RICE program. Provided miscellaneous regulatory support for RICE questions, including RICE applicability determinations, testing configurations, and continuous monitoring systems (CMS) applicability. (Marathon Petroleum Company, Robinson IL)
Corporate RICE Compliance Review: Engineer: Managed and coordinated the effort of reviewing the status of seven (7) refinery RICE compliance programs, as related to NSPS IIII and MACT ZZZZ primarily. Upon completion of the reviews, helped to revamp and draft several final deliverables including the RICE manual and several regulatory guidance memorandums. (Marathon Petroleum Company – Findlay, OH)
Title V Permit Renewal: Engineer: Acted as the lead engineer in the preparation of the facility Title V Permit update. Tasks associated with the update of the facility permit included: review construction permits and incorporation into Title V, regulatory determination and applicability review, preparation of permit, preparation of permit application, and update of CAAPP forms. This project included the incorporation of approximately eight (8) years of facility changes and the re-arrangement of the current permit format to the 2012 IEPA format. (LyondellBasell - Morris, IL)
Addition of Natural Gas to Flares: Engineer: Performed the role of primary engineer for the preparation of a permit application for a refinery client who was permitting additional natural gas to the flare to supplement heating value. This involved emissions calculations, Federal and state regulatory applicability review, and other supplemental information. (Refinery Client)
Loading Rack Construction Permitting: Engineer: Field-walked the plant and surveyed the location for the loading rack construction permit. Worked with the site environmental group to review P&IDs and reports associated with the construction project. In addition, NSR/PSD applicability was reviewed, determined to be not applicable, and included in the report. Drafted the final permit, permit application, CAAPP forms to be submitted to the site, and assisted in correspondence with the IEPA. (LyondellBasell - Morris, IL)
Title V Permit Renewal: Engineer: Assisted in the preparation of the facility Title V Permit update. Tasks associated with the update of the facility permit included: review construction permits and incorporation into Title V, regulatory determination and applicability review, preparation of permit, preparation of permit application, and update of CAAPP forms. This project included the incorporation of approximately six (6) years of facility changes and the re-arrangement of the current permit format to the 2012 IEPA format. (Marathon Petroleum Company - Robinson, IL)
Air Emissions Modeling from Cooling Tower Leak: Engineer: Assisted in the estimation of the emissions and resultant risk from the release of excess emissions associated with the leak from a cooling tower system at the refinery. This involved preparing a report summarizing the emissions modeled over the release period using AERSCREEN. (Refinery Client)
Benzene Waste Operations NESHAP (BWON) and NSPS QQQ
Carbon Canister Modeling Breakthrough Analysis: Engineer: Acted as lead engineer to develop engineering models and assumptions on vapor headspace composition and flow rate on a sump pump hooked up to two (2) carbon canisters in series. Made contact with Calgon Corporation to model the carbon consumption rate by the carbon canister. Provided QA/QC on the final report with the modeling results and final Design Carbon Replacement Interval (DCRI) for the client. (Marathon Petroleum Company – Canton, OH)
BWON DACT User Manual Development: Engineer: Assisted in the development and QA/QC of a BWON Documentation and Compliance Tool (BWON DACT) User Manual for a refinery client. This work involved comparing the User Manual against the facility BWON DACT, assessing the manual for potential gaps, and updating to meet the client standards. (Marathon Petroleum Company – Detroit, MI)
POG Revalidation and BWON-DACT Update: Engineer: Evaluated refinery P&IDs for BWON applicability, by identifying POGs, DBL CNTs, SWS, and IPRE via process knowledge. Marked up drawings with questions to be followed-up on during operator interviews and updated the data for stream applicability in the BWON-DACT. (Phillips 66 Corporation – Wood River, IL)
NSPS QQQ Training Development: Engineer: Reviewed site specific questions for NSPS QQQ applicability and assisted in the generation of training slides on QQQ control schemes, regulatory applicability, best management practices (BMPs), and site-specific QQQ questions for onsite training at facility. (Phillips 66 – Wood River, IL)
Miscellaneous Compliance Areas
Streamlined Mercury Variance (Wastewater) Permit Implementation: Project Manager: Tom was the project manager for the implementation of systems at the refinery to comply with the SMV permit provisions. This included communication with SMEs at the refinery with respect to mercury content in equipment, chemicals, and other materials. Other parts of the project were interviews of different department leads, SOP development, training course development, database development, and systems integration of all items. Process areas and non-process areas were accounted for. Tom was the primary trainer for over 100 refinery staff on the systems and roles and responsibilities of various departments and staff to drive compliance. (BP Corporation – Whiting, IN)
Heat Exchange MACT Audit Protocol: Engineer: Assisted in auditing for Refinery MACT compliance at the Canton refinery, including MEPM sampling, records review and calibration shadowing. Aided in developing final audit report with BMPs and compliance suggestions. (Marathon Petroleum Company – Canton, OH)
NSPS OOOO Implementation: Engineer: Assisted in the quality assurance (QA) / quality control (QC) process for the implementation of NSPS OOOO, including performing field spot checks of inventory at several wellpads, review of database that stored all information, drafting of field and database checklists, and guidance to Sage and Shell team on NSPS OOOO interpretations. Additionally, regulatory interpretation and analysis of a new facility under NSPS Kb and associated LDAR regulations during the project. (Shell Upstream Americas – Permian Basin, TX)
HON Semiannual Report Generation: Engineer: Collected the necessary information from the HON to generate data needs list for the semiannual report. Went onsite and collected data associated with the HON systems at the refinery and assembled into report, in accordance with the regulations. Requested a "change in reporting" period (in accordance with the NESHAP General Provisions) to the EPA to line up with normal reporting periods, for the facility's convenience. (Marathon Petroleum Company - Robinson, IL)
2012 EI/TRI Reporting: Engineer: Utilized the PI system and data collected from site to update emissions calculations for all emission sources in the refinery. Identified catalyst and chemical MSDS needs based off of EPA 2012 TRI Chemicals list and updated accordingly. Estimated tank emissions using tank temperature, contents and internal specifications and managed delegation of work to Sage interns on emission calculations. (Marathon Petroleum Company, Robinson IL)
Education/Professional Affiliations
- B.S. Chemical Engineering, University of Illinois, Urbana, Champaign, 2012
- Air and Waste Management Association Member – Chicago, IL
- Transportation Worker Identification Credentials (TWIC) Certifications
- Three Rivers Manufacturing Association (TRMA) Safety Certification
- Sage LDAR Essentials – Instruction by Mr. Buzz Harris, February 2012
- MPC NSR/PSD Permitting PATH Training: Instruction by Mr. Colin Campbell, September 2012
- Sage Flare Essentials: Instruction by Messrs. Troy M. Boley, Herman Holm, and Derick Kopp, November 2012
- Sage BWON Essentials: Instruction by Mr. Larry Darcey and Mr. Ryan Atkinson, February 2013
- Boaz Rauchwerger "Tiberias Success Formula: How to Supercharge Your Business and Yourself" – Austin, January 2014
- Dale Carnegie "How to Communicate with Diplomacy and Tact" Training – Chicago, July 2014
- Steven Snyder "Mind Matters - Brilliance, Passion, And The Nature Of Mastery" Training – Austin, September 2014
- Dean Minuto "Yescalate: Your System To Get To Yes" – Austin, November 2014
Aaron has more than 23 years of small business/commercial lending industry experience. His experience includes 14 years of leadership and management experience, excellent credit and financial analysis skills. He has held senior level management positions of increasing responsibility as Vice President, Business Development, Chief Financial Officer and Chief Operation Officer.
Key Expertise
- Executive leadership experience in operations and finance
- 23 years of small business/commercial lending industry experience
- 14 years of leadership and management experience
- Excellent credit and financial analysis skills
- Relationship driven fostering strong communication and loyal clientele
- Goal-oriented individual with strong leadership capabilities, maintaining high ethical standards, consistently responsive and reliable
- Strong communicator, highly organized, self-motivated, and competitive spirit
Project Experience
Sage Environmental Consulting and Family of Companies: Chief Operating Officer: Operations and organizational leadership, departmental leadership for Accounting, Finance, and Human Resources. Strategic decision making for business vesting matters, corporate governance and responsibilities as to legal matters and outside Counsel and financial management and strategy. (Austin TX)
North Valley Bank: Department Manager of Government Guaranteed Lending/Senior Vice President: Producing manager of new department generating SBA and USDA B&I loans for Bank, Interim regional business banking manager for Roseville/Woodland area, Developed policies & procedures for new department to support SBA lending. Hired new staff to support department including sales, underwriting and processing roles. Developed internal referral channels for branch and business banking network. Expanded lending platform to include SBA & USDA loans as a profit center. (Roseville, CA)
Rocky Mountain PSI, Inc. (affiliate of Sage Environmental Consulting): Chief Financial Officer: Responsible for key aspects of financial management of corporation, prepared & reviewed financial statements on a monthly basis. Provided management reporting to Senior Management team and owners. Supervised accounting functions and managed key operational and financial management activities.
Santa Cruz County Bank: Vice President/Business Development Officer: Responsible for originating SBA and USDA B&I loans throughout the State of California. Manage existing referral relationships and developed new relationships with a variety of referral sources including commercial brokers, loan brokers, and various business networking activities. Maintain very positive relationships with the SBA and USDA government agencies. Help expand USDA B&I lending to the Bank. Achieved 3rd largest USDA B&I lender status in the State of California and 13th largest B&I lender in the Nation. (Roseville, CA)
Excel National Bank: Senior Vice President/Business Development Officer: Responsible for new business development of government guaranteed loans, including SBA 7(a), SBA Express, 504 and USDA Business & Industry loans. Managed existing referral relationships and developed new relationships with a variety of referral sources including commercial brokers, loan brokers, and various business networking activities. Generated loan production with efficiency, submitting complete loan packages, and forged positive working relationships with Underwriters and Loan Processors. Enhanced knowledge and understanding of loan programs throughout the Bank. (Roseville, CA)
Umpqua Bank: Vice President/Business Development Officer: Responsible for new business development of government guaranteed loans, including SBA 7(a), SBA Express, 504 and USDA Business & Industry loans. Developed new relationships with a variety of referral sources including commercial brokers, loan brokers, and various business networking activities. Enhanced community bank customer relationships through cross-selling opportunities of bank products. Up-leveled knowledge and understanding of SBA loan programs with commercial lenders and marketed commercial loan products as a team. Mined business through branch network.
Sage Environmental Consulting: Chief Financial Officer: Responsible for overall financial operations with revenues of $4 million annually and 36 employees. Developed profitable business model with profit margins exceeding 12%. Managed all accounting systems, including G/L, account receivables, account payables and payroll. Managed capital, including lines of credit and terms loans. Supervised Human Resources, Information Technology and Vendor services. (Dallas, TX)
Bank United: Vice President SBA Underwriting & Closing Department: Responsible for the SBA production staff overseeing all SBA production centers. Managed new loan production and portfolio quality for SBA 7a and 504 lending. Exercised credit authority for loans up to $1 million. Improved cycle times for underwriting and closing and developed new credit policies and production performance levels. (Irving, TX)
Career with First Union Small Business Capital: multiple positions held as described below. Credit Operations Coordinator: Managed production levels for the credit operations department. Responsible for production, efficiency levels & cycle times. Coordinated collaborative communications with Sales, Credit, Processing, MIS and Legal departments. Assisted with integration after acquired by First Union. Up-leveled knowledge and understanding of SBA loan programs with commercial lenders and marketed commercial loan products as a team.
Regional Production Manager: Achieved $250 million of loan volume. Supervised 6 production teams in credit and processing. Managed production, efficiency levels and cycle times. Supervised national Franchise and Wholesale markets.
- Credit Operations Manager/Senior Credit Officer:
- Credit Manager supervising a team of loan officers.
- Loan Officer underwriting SBA 7a and 504 loans.
Farm Credit Services: Loan Officer II: Managed a profitable loan portfolio of $30 million. Portfolio included agricultural loans for farm real estate, machinery and lines of credit. Specialized in lending to corporations and multiple entities.
AEC/Centrec Consulting: Associate Consultant: Prepared case study materials for seminars to agricultural lenders. Assisted with litigation support for various agricultural banks. Developed PC based spreadsheet templates for financial analysis.
Education/Professional Affiliations
- Master of Science degree in Agricultural Economics, University of Illinois at Champaign, Illinois, 1993
- Bachelor of Science degree in Agricultural Economics, University of Illinois at Champaign, Illinois, 1989
- Board of Advisors member of South Placer Business Group
- Co-owner of online business networking site California Business Link
- NAGGL member
- Roseville Chamber of Commerce member