Doug Price, P.E. (Texas), Senior Environmental Engineer
Doug has a BS in Chemical Engineering and a BBA in Finance from the University of Texas at Austin and thirty-three years of experience in the environmental field, with a strong emphasis in air quality issues. He has twelve years of industry experience in petroleum refining, including six years in a corporate environmental group. His industry assignments have included Environmental Manager for Air Quality, Environmental Director, and Senior Consultant, Environmental. In addition he has twenty-one years of experience as an environmental consultant. He provided environmental consulting services to clients in the refining, petrochemical, oil & gas, and other industries. He also managed the financial aspects of the consulting firm and held positions from Staff Graduate Engineer to Principal Engineer.
Doug’s experience covers a broad spectrum of industrial facilities including: petroleum refineries, synthetic organic chemical manufacturing industry production sites, oil and gas gathering system and production sites, crude oil pipelines, bulk liquid terminals, chemical distribution terminals, ceramic tile manufacturing, electric utilities, mineral wool manufacturing, cogeneration facilities, metal product coatings operations, copper refining, and satellite launch vehicle manufacturing and testing.
The listing below captures some key aspects of those showcase projects where the results of the work were the most valuable.
Compliance And Enforcement:
- Consent Decree (multiple refineries) ‐ Lead negotiator for a refining company dealing with U.S.EPA, U.S. Department of Justice and six state agencies for a variety of permitting, New Source Performance Standards (NSPS), and National Emission Standards for Hazardous Air Pollutants (NESHAP) allegations. Successfully reduced cost of proposed injunctive relief by several hundred million dollars.
- Inspections – Provided on-site compliance support during numerous state and federal agency inspections. Negotiated with state, local and federal agency staff to limit inspection scope and data requests. Managed document production and review process to ensure confidential business information (CBI) and site security information (SSI) was properly identified and labeled.
- Compliance Programs – Implemented compliance programs for new NESHAP rules including Refinery MACT II and Heater/Boiler MACT rules.
- Emissions Calculation – Implemented improved emission calculation procedures for air permit applications, emission inventories and release reporting.
- Root Cause Investigation – Improved Consent Decree root cause investigation reports resulting in reduced assessments of stipulated penalties
Over 26 years of auditing experience in multiple states and industries. Completed formal auditor training provided by Arthur D. Little Company. Audits have ranged from individual work to leading a team of auditors. Most audits were done under attorney-client privilege with confidential reporting. Some selected examples include:
- Power and Refrigerations Systems Due Diligence Audit (potential acquisition by private energy management company) – Visited a sampling of sixteen sites and reviewed compliance programs for all environmental media.
- New Source Review Permitting Compliance Audit (Texas ethylene plant) – Reviewed nonattainment and prevention of significant deterioration (PSD) permitting history for two Ethylene Units, one Butadiene Unit, and associated utilities. Identified audit findings, including both regulatory and Best Management Practice items.
- Compliance Audits (Louisiana ethylene plant) – Multiple audits over several years to cover all aspects of environmental compliance and management systems. Examples of areas reviewed included:
- CERCLA/EPCRA Release Reporting Programs
- Emergency Response Planning and Notification (SARA Sec. 301 and 302)
- Safety Data Sheet Reporting and Management System
- Emergency and Hazardous Chemical Inventory Reporting (Tier I/II Reporting)
- Toxic Substances Control Act Reporting
- 40 CFR 61 Subpart FF (Benzene Waste Operations NESHAP)
- Due Diligence Audit (Texas, New Mexico, and Oklahoma Natural Gas gathering and processing sites – potential acquisition) – Provided air regulatory interpretations, reviewed files, visited selected sites in West Texas region, and identify items of significant concern to address prior to sale.
- Continuous Emission Monitoring Systems (CEMS) Audit (Texas refinery) – Reviewed data acquisition systems, calibration gases, CEMS ranges, and other aspects of CEMS compliance with federal rules.
- Air Compliance Audit (Utah refinery) – Multiple audits to reviewed compliance with federal and state air quality regulations.
Due Diligence, Acquisitions and Divestitures:
- Acquisition (refinery, pipelines, land & marine terminals, and retail outlets) ‐ Led the environmental, health, safety, and security (EHS&S) team for a multi-billion dollar acquisition in California. Performed and coordinated third-party due diligence of multiple sites. Planned and executed transfer of assets and compliance tasks to ensure uninterrupted operations at the sites. Project required the transfer of permits from federal, state, county and local jurisdictions.
- Acquisition (refinery) ‐ Led the environmental, health, safety, and security (EHS&S) team for a refinery acquisition in North Dakota. Performed due diligence. Planned and executed transfer of assets and compliance tasks to ensure uninterrupted operations at the sites.
- Divestiture (refinery) – Led the environmental, health, safety, and security (EHS&S) team for a refinery divestiture in Hawaii. Planned and executed transfer of assets and compliance tasks to limit future liability.
Registered Professional Engineer in Texas (PE 73350)
Life Member, American Institute of Chemical Engineers (Vice-Chair (1992/1993), Chair (1994/1995) Balcones Fault Section)
American Fuel & Petrochemical Manufacturers Environmental Committee (Vice-Chair 2015/2016; Chair 2017)
The Auditing Roundtable (Environmental Health and Safety)