Evan Tullos

Mr. Tullos is a compliance specialist with 14 years of experience in Clean Air Act (CAA) permitting and compliance, Clean Water Act (CWA) permitting and compliance, Resource Conservation and Recovery Act (RCRA) compliance, and multimedia environmental compliance audits.  Mr. Tullos has worked with facilities in numerous states, as well as international locations.  These industries have included petroleum refining and storage, oil & gas exploration and production, power generation, chemical manufacturing, aerospace manufacturing, and various other manufacturing industries.  

Clean Air Act Permitting and Compliance

Evan has extensive experience with CAA requirements, directing the completion of projects in Alabama, Georgia, Ohio, Mississippi, Nevada, New Mexico, North Carolina, Texas, Tennessee, and West Virginia. In addition to the projects below, Evan has prepared NSR and Title V permit applications for industries such as steel manufacturing, cement manufacturing, natural gas storage, natural gas processing, and metal products manufacturing.

Confidential Chemical Industry; Mississippi
Located emission points, determined insignificant activities, quantified emissions from each emission point, prepared application forms, evaluated the compliance status for each emission point, and developed strategies to maintain compliance with New Source Performance Standards (NSPS) and National Emissions Standards for Hazardous Air Pollutants (NESHAP). Work also included drafting of the Title V Permit, with comments provided by the state regulatory agency. The facility also underwent several modifications which required construction permits and point-specific limitations to avoid PSD permitting.

Master Design Furniture; Mississippi
Developed Work Practice Implementation Plan for compliance with 40 CFR 63, Subpart JJJ. Work included development of workplace procedures and record-keeping forms to ensure compliance with the standard.

Confidential Utility Agency; Mississippi
Prepared application for and negotiated terms of a construction permit for six, 2,000 kilowatt engines. Work included development of emissions inventory, completion of permit application, and negotiation of permit terms and conditions with the state regulatory agency.

Confidential Utility Agency; Mississippi

• Prepared Title V Application for electric-generating plant in north Mississippi. The plant included coal-fired steam boilers greater than 100 MMBtu/hr and a 235 MMBtu/hr combustion turbine. Evaluated insignificant activities, quantified emissions from each emission point, prepared application forms, evaluated the compliance status for each emission point, and made applicability determinations for developed NSPS and NESHAP.
• Prepared construction permit and Title V Modification applications for the construction of six-1,825 kilowatt engines. Work included development of emissions inventory, completion of permit application, and negotiation of permit terms and conditions with the state regulatory agency.
• Long-term environmental compliance work conducted for this client includes development of annual emission inventories for Title V fees, Title V Compliance Certifications, multimedia compliance audits, and spill prevention, control, and countermeasures (SPCC) plans.

Confidential Petroleum Refinery; Mississippi
Prepared Title V Application for the facility, which included evaluation of insignificant activities, quantification of emissions from each emission point, preparation of application forms, evaluation of the compliance status for each emission point, and applicability determinations for NSPS and NESHAP.

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Multimedia Environmental Compliance Audits and Strategy

Confidential Petroleum Refining and Storage Corporation (2001 - 2004) - U.S. Facilities
Project Manager and Lead Auditor responsible for performance of multimedia environmental compliance audits for petroleum refining, asphalt manufacturing, and bulk storage terminals. The audits were performed to assess each facility's compliance status with federal, state, and local environmental laws and regulations, specifically covering three major program areas: CWA, including wastewater and storm water; CAA, including NSPS and NESHAP, and solid waste, including RCRA, Hazardous and Solid Waste Amendments (HSWA), and underground storage tanks (USTs). Responsibilities included review of facility documents and background information to determine permit compliance, onsite visual inspections, personnel interviews, and generation of the audit report. Dakota software was used to document the findings of the audits. During the project, audits were conducted in Arizona, Louisiana, Mississippi, Nevada, Ohio, Pennsylvania, Tennessee, Texas, and West Virginia.

Confidential Manufacturing (1999 - 2006) - U.S. and International Facilities

Served as lead auditor, auditor, or Project Manager for multimedia environmental compliance audits throughout the U.S. The audits typically included onsite visual inspections and personnel interviews; reviewing all facility documents, background information, and permits; determining local, state, and federal regulatory compliance; and generating reports of findings, which included suggested corrective action. The audits specifically covered Solid Waste (RCRA, HSWA, and USTs), the Safe Drinking Water Act (SDWA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the CWA, CAA, and the Emergency Planning and Community Right-to-Know Act (EPCRA). During this project, audits were conducted in Alabama, Arizona, California, Colorado, Connecticut, Massachusetts, Minnesota, Mississippi, Missouri, New York, North Carolina, Nevada, Ohio, Tennessee, Texas, Virginia, Washington, Wisconsin, Brazil, and Mexico.

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Clean Water Act Permitting and Compliance

Confidential Petroleum Refinery; Mississippi
Developed permit application and strategy for a petroleum refinery, subject to categorical standards for process wastewater and storm water discharges.  Work involved calculation of effluent limitations established for Best Available Technology Economically Achievable (BAT) and Best Conventional Technology (BCT) and negotiation of the permit terms and conditions.

• Developed permitting strategies under the U.S. Environmental Protection Agency's (USEPA's) NPDES for storm water and industrial wastewater for industries subject to categorical effluent guidelines such as chemical manufacturing, wood products, steel mills, metal products manufacturing, and bulk storage terminals.
• Developed Storm Water Pollution Prevention Plans (SWPPP) for various industries such as a marine fabrication facility, an airport, oil-field service facilities, chemical manufacturing, bulk petroleum storage facilities, and various manufacturing facilities. The SWPPP included identification of potential pollution sources, development of Best Management Practices (BMP) to control storm water contamination, spill prevention and response procedures, employee training procedures, and sample forms for administering the plan.

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Emergency Planning

• Developed Risk Management Programs for an electric motor manufacturer, a grain elevator, propane storage facilities, a fertilizer manufacturer, bulk storage facilities, and water treatment facilities. Work included performing a hazard assessment (documenting five-year accident history and establishing a worst-case and alternative release scenario), development of a prevention program, conducting a process hazard analysis, development of audit and incident investigation procedures, and development of an emergency response program.

• Developed an Integrated Contingency Plan in accordance with the National Response Team Guidance for a chemical manufacturer and numerous petroleum storage terminals. Work involved the preparation of a functional emergency plan used as a mechanism for incorporating multiple plans required by various regulatory agencies, in particular, USEPA regulations 40 CFR Part 112.20 (Spill Prevention, Control, and Countermeasures), 40 CFR Part 68 (Risk Management Program), 40 CFR Parts 264 and 265, Subpart D (RCRA Contingency Planning Requirements), and OSHA regulations 29 CFR 1910.38 (Emergency Action Plan), 29 CFR 1910.119 (Process Safety Management), and 29 CFR 1910.120 (HAZWOPER).
• Developed numerous SPCC plans in accordance with 40 CFR 112. Also developed emergency plans designed to meet Oil Pollution Act of 1990 (OPA 90) requirements.