Key Project Experience, continued:

Air Permitting

• Biofuel Project Support - Supported a major Oil & Gas client with estimating emissions and understanding regulatory requirements for biofuel projects in Texas, Arkansas, and Oregon.

• Consent Decree Pollution Control System Permitting - Managed preparation of Standard Permit registrations, including PSD applicability analysis, for Consent Decree-required replacement incinerators at two Carbon Black facilities in Texas.

Environmental Compliance

• Emission Inventory Assistance - Managed an emissions inventory standardization project for a Power client for 25 facilities in Arkansas, Louisiana, Mississippi, and Texas. Work includes creation of an Excel-based emission calculation template, site-configured workbooks, and training for environmental personnel. Other emission inventory projects included annual reporting for a steel mill, power plants, gypsum wallboard manufacturing facilities, and oil & gas production sites in Texas and Oklahoma.

• Auditing– Led or supported air environmental compliance audits for a refinery, two power plants, gas fractionation plant, polymer manufacturing facility, eight organic and inorganic chemical plants, and over 100 oil & gas production sites. Tasks included review of NSR and Title V permits, PBRs, and associated reports and records including those for NSPS, NESHAP and MACT regulations.

• Regulatory Applicability – For a chemical plant transitioning from an area source to a major source of HAPs, worked as part of a team to assess and document the potential implications for each NSPS and MACT regulation that might potentially apply.

• Advocacy for EPA Methane Rules – Provide ongoing technical support in advocacy efforts in response to federal methane regulations. Advised in meetings with trade group committee members, drafted comments for agency submittal, and conducted relevant data collection and analyses.