Rob Gronewold, P.E., P.G., Senior Environmental Consultant
Rob has a BS in Geology from the University of California, Davis and an MS in Geology from the University of Wyoming. He is unique in that he has has degrees in geology, but earned a professional engineer license in Wyoming addition to his professional geologist certification. Prior to joining JBE Mr. Gronewold worked as the Managing Director for corporate environmental affairs for a large independent U.S. refining and marketing company. In that role he provided oversight and guidance for environmental compliance and permitting for all media, with an emphasis on air regulatory programs. He coordinated the firm’s federal Consent Decree compliance programs and responses to Clean Air Act Section 114 inquiries. He designed and implemented the company’s compliance program for a complex multi-refinery Consent Decree that focused on flaring and various hazardous air pollutant compliance programs.
Mr. Gronewold led the transaction due diligence for four refinery acquisitions in the western US, and managed multiple additional transaction environmental evaluations in the UK, Europe, Korea and Australia.
In a related area, Mr. Gronewold was also responsible for developing and maintaining contingent liability reserves for a corporate petroleum refining organization, and presenting those reserve estimates to executive management and internal/external accounting staffs.
The listing below captures some key aspects of those showcase projects where the results of the work were the most valuable.
Key Regulatory Affairs Projects:
- Managed corporate environmental affairs programs for all regulatory programs applicable to seven petroleum refineries. Provided consultation and regulatory support in all media to refinery staffs. Managed corporate environmental oversight program (audit program, compliance consistency, application of corporate environmental guidelines and procedures). Advised facility and corporate management of pending regulatory changes and recommend effective compliance response.
- Developed and implemented corporate Environmental standards and procedures (air permitting, auditing, greenhouse gas reporting, metrics compilation and reporting).
- Developed company EH&S policies and corresponding Management Review policies. Worked with company management to implement and monitor conformance with these policies.
- Managed compilation of environmental information for corporate sustainability reports. Served on corporate task force for climate change strategic planning.
- Served as functional business unit leader for implementation of enterprise-wide Environmental Information Management System (three-year-long, multi-million dollar effort culminating in 2010).
- Took lead role for negotiating resolution of significant enforcement actions. Coordinated Consent Decree compliance for multiple refineries.
- Developed and maintained corporate reserves for environmental contingent liabilities and asset retirement obligations for multiple refineries. Provided input for quarterly and annual SEC filings and supported Executive Management team for reviewing draft filings.
- Managed permitting, compliance and remediation activities for a complex petroleum refinery. Implemented risk-based RCRA Facility Investigation (RFI) for assessment of groundwater, soils, subsurface vapors, surface water and sediment.
- Serve as Project Manager to track and summarize environmental, health and safety, transportation, security, and product stewardship regulatory developments for the federal agencies and 18 state agencies. Provided weekly and bi-weekly reports and developed a secure web-based data collection and archiving site.
- Refinery Sector Rule (refinery) – Designed and implemented a comprehensive compliance program for a West Coast petroleum refinery to assure conformance with the Refinery Sector Rule (RSR) requirements. This entailed preparing detailed rule analyses, determining the implications for the refinery’s equipment, and working with the plants Engineering, Operations and Maintenance departments to develop compliance solutions. Worked directly with Operations supervisory staff to revise operating procedures and trained operators on the new requirements.
- Confidential Client – Addressed allegations of noncompliance brought by the U.S. Department of Justice for historic New Source Review (NSR) and New Source Performance Standard (NSPS). This project included evaluations of the information which the government used as the basis for its allegations and assistance in crafting defenses to the allegations.
- Public Relations (refinery) – Acted as a refinery news media contact during both emergency incidents and routine news media contacts. Received media training in the areas of electronic and print media response. Successfully represented facility at contentious public meetings.
- Various Facilities – Served as Project Manager and technical lead for multiple Toxic Release Inventory (TRI), TSCA Chemical Data Reporting (CDR) and MACT/NSPS compliance reporting projects.
- PSD and Minor NSR Applications (fertilizer manufacturer) – Served as Project Manager for several permitting projects involving significant process modifications for a major fertilizer manufacturer. The projects were complicated by a concurrent national EPA enforcement initiative for this industry sector. These projects included visibility assessments for nearby Class I areas.
- Residual Risk Information Collection Request (refineries) – Served as Project Manager for several refinery Information Collection Request (ICR) responses. These large data collection and management projects required the integration of facility permits, previous modeling efforts, source testing information and emission inventory information.
- Residual Risk Information Collection Request (refinery) – Served as Project Manager for a project which used the Refinery ICR emission data to model off-site cancer and hazard risk using the EPA’s HEM-3 model. The analysis identified individual sources contributing to the receptors modeled as experiencing the maximum risk.
- Compliance Evaluation/Counseling – NSPS/NESHAP Regulations (Multiple Refining Clients) – Evaluated multiple refining and terminal facilities for New Source Performance (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) compliance, and developed compliance strategies to optimize performance. This work included the assessment and/or development of startup, shutdown and malfunction plans (SSMPs) required by these regulations. Participated in regulatory advocacy efforts during refinery NSPS/NESHAP regulation development on behalf of a refining corporation.
- Acquisitions (refineries) – Managed transaction due diligence for four refinery acquisitions in the western U.S., plus multiple other evaluations in the UK, Europe, Korea and Australia. Managed due diligence assessments for terminals and pipelines in multiple U.S. states. Many of these projects included the evaluation of opening balance liabilities used to establish necessary reserves. Provided direct reports to corporate Boards of Directors.\
- Asset Integration (multiple clients) – Served as Project Manager for multiple complex projects to integrate newly-acquired assets into existing corporate compliance programs and company portfolios. This required transferring Environmental permits, making agency notifications, and ensuring that all necessary documentation was in place to allow ongoing operations. These projects involved refineries, terminals, retail fuel stations, and pipelines.
- Acquisition Analysis (terminal) – Served as the Project Manager for the evaluation of material environmental liabilities associated with a terminal system comprised of more than a dozen assets across the United States.
- Asset Acquisition Liability Analysis (food industry) – Conducted Phase I Environmental Site Assessment (ESA) of two Washington State fruit packing facilities to assess potential environmental liabilities. Compiled acquisition liability reserve estimates.
- Compliance – Negotiated risk-based RCRA Facility Investigation work plan using innovative approach to maximize sampling program effectiveness while minimizing costs.
- Permitting – Developed RCRA Part B post-closure permit application for on-site hazardous waste landfill.
- Construction – Served as project manager for construction of on-site hazardous waste landfill.
- Remediation – Implemented multi-phase facility groundwater remediation projects using in-situ technologies, hydraulic barrier systems as well as pump and treat systems.
- Wastewater Support (refinery) – Negotiated settlement of complex NPDES permit appeal with state agency and served as project manager for successful defense of a multi-faceted permit appeal by a coalition of environmental groups.
- TRE (refinery) – implemented a wastewater toxicity identification and reduction program that greatly enhanced both facility compliance and the operating performance of the on-site wastewater treatment plant.
American Fuel & Petrochemical Manufacturers – Chairman, National Environmental Committee
Professional Engineer, Wyoming, Civil Engineering (No. 6203)
Professional Geologist, Wyoming (No. PG-552, retired)