These are documents for REGFORM’s Missouri Air Compliance Seminar, November 6, 2024
Download your certificate of attendance here
The agenda is here.
The attendee list is here.
Sponsor slides with sponsors’ contact information are here.
Attorneys: MoBar has approved this seminar for 7.8 hours of CLE. The course ID for this program is 757200.
Presentation Slides
Wednesday, November 6
9:30 a.m. Air Pollution Control Program Update STEPHEN HALL, APCP Director RICHARD SWARTZ, Chief, Compliance & Enforcement Section JOSH VANDER VEEN, Chief, Air Quality Analysis Section
10:30 a.m. Emergence of Air Toxics as a Key Enforcement & Compliance Issue ANDREW BROUGHT, Spencer Fane KELLI DEUTH, Ramboll
11:10 a.m. US EPA Region 7 Update, DANA SKELLEY EPA Region 7
12:40 p.m. Air Pollution Control Program – Air Permitting Update KENDALL HALE, Chief, Permit Section, APCP
1:10 p.m. APCP Air Quality Planning Update MARK LEATH, Chief, Planning Section, APCP, MDNR
1:40 p.m. Navigating Recent Case Law: Implications for Air Policy and EHS Management RICHARD GROENEMAN, Assistant Attorney General, Missouri SEGOLENE RENAZE, Legal Counsel, MDNR
2:35 p.m. Final Changes to RMP and PSM – Implementation Challenges VALERIE GUENTHER, Ramboll, ANDREW BROUGHT, Spencer Fane
3:20 p.m. Risk and Technology Review Process and Application JOSH LEE, Trinity Consultants
4:05 p.m. NAAQS Update: PM2.5 and new SIL – Implementation Issues JEFFRY BENNETT, Barr
Speaker Bios
Jeffry Bennett, Barr
jbennett@barr.com
Jeffry D. Bennett, PE is a Vice President and Senior Air Quality Engineer at Barr Engineering. He has nearly 30 years of experience in air quality regulation and consulting including 17 years with the Missouri Department of Natural Resources, Air Program. Currently, Jeff assists a wide variety of clients with environmental permitting, compliance demonstrations, regulatory negotiations, rule commentary, and expert witness services.
Andrew Brought, Spencer Fane
abrought@spencerfane.com
Andrew Brought counsels manufacturers, industrial clients, and businesses with complex environmental and workplace safety / OSHA matters. He currently serves on the firm’s Executive Committee and has held other leadership positions at the firm including co-chair of the Environment and Energy practice group. Andrew has extensive experience helping companies with workplace safety incidents and industrial accidents that involve the intersection of health, safety, and environmental regulations and government agencies including OSHA, the EPA, the U.S. Chemical Safety and Hazard Board, and the Justice Department. From complex workplace fatalities and injuries to more routine compliance inspections, Andrew is frequently called upon by a variety of industrial sectors to assist in handling crisis management situations, strategic response, and incident investigations. He has a particular focus on chemical accident prevention programs, including EPA’s Risk Management Plan (RMP) program and OSHA’s Process Safety Management (PSM) program and cases involving chemical releases. In connection with his white collar criminal and civil practice, Andrew helps his clients manage and reduce liability through his substantial experience in enforcement matters associated with the Clean Air Act, the Clean Water Act, RCRA, EPCRA, OSHA, and related environmental laws. He also assists his clients by conducting compliance audits and internal investigations as appropriate. And in those situations where win-win outcomes are not achievable, he helps his clients litigate and resolve environmental disputes.
Kelli Deuth, Ramboll
kdeuth@ramboll.com
Kelli Deuthhas managed projects in environmental consulting for over 22 years, with specific expertise in air quality, compliance, and environmental justice. She participates in Ramboll’s cross practice environmental justice task force and co-leads the air quality service line environmental justice workgroup. She has extensive experience in air quality permitting and compliance programs, including Title V, PSD, numerous state programs, NSPS and NESHAP compliance, annual emissions reports, toxic release inventory (TRI), Tier II, and greenhouse gas inventories. She leads projects across the country for corporate groups and individual sites.
Richard (“Ric”) Groeneman, Missouri AGO
richard.groeneman@ago.mo.gov
Mr. Groeneman is an Assistant Attorney General in the Governmental Affairs section, assigned to the Environmental and Agricultural Unit. He handles the full spectrum of environmental cases, across multiple environmental media, from compliance and enforcement to defending regulations promulgated by the Missouri Department of Natural Resources, and representing the interests of Department of Natural Resources and the State of Missouri in bankruptcy proceedings. Mr. Groeneman actively practices before both federal and state courts, bankruptcy courts, and the Missouri Administrative Hearing Commission.
Mr. Groeneman also defends the State of Missouri in federal § 1983 cases, litigates enforcement cases against dog breeders, represents the Director of Department of Public Safety in peace officer licensing cases, and the Missouri State Highway Patrol in sex offender cases.
Mr. Groeneman graduated from Saint Louis University School of Law with his Juris Doctor and Vermont Law School with a masters in Environmental Law. Mr. Groeneman completed a clerkship with the United States Environmental Protection Agency Office of Enforcement and Compliance Assurance, Office of Criminal Enforcement, Forensics and Training, Legal Counsel in Washington D.C. After completing his EPA clerkship, he was an Assistant Prosecuting Attorney in the Office of the Prosecuting Attorney for Franklin County, Missouri. Prior to becoming an attorney, Mr. Groeneman was a Conservation Agent (Game Warden) with the Missouri Department of Conservation. Mr. Groeneman is also an adjunct professor for both Maryville University and Webster University.
Valerie Guenther, Ramboll
vguenther@ramboll.com
Valerie Guenther is a licensed professional engineer in Michigan and has worked in environmental consulting for the past 30+ years, with specific expertise in air quality permitting, compliance, EHS auditing, and RMP/PSM. She has worked on RMP plans and programs since the promulgation of the regulation and has continued to perform 3-year audits, general duty clause consulting, off-site consequence analyses (OCA) and HAZOPs for all program level sources and a variety of toxics and flammables. Her sector experience ranges from municipal water/wastewater treatment, manufacturing, oil & gas and power generation. Valerie has implemented PSM programs for various facilities, including development of management of change procedures and systems.
Kendall Hale, MDNR
kendall.hale@dnr.mo.gov
Kendall Hale is a graduate of Westminster College in Fulton, Missouri with a degree in Chemistry and Mathematics and the University of Missouri-Columbia with a degree in Chemical Engineering. He is a licensed Profession Engineer in the State of Missouri since 2004. He has been with the Missouri Department of Natural Resources’ Air Pollution Control Program for 26 years, the majority of the time has been spent in the Permit Section. He served as the New Source Review Unit Chief from 2004 until 2011. Since 2011 he has severed as the Air Pollution Control Program’s Permit Section Chief since 2011.
Stephen Hall, MDNR
stephen.hall@dnr.mo.gov
Steve Hall became director of the Air Pollution Control Program on Aug. 25, 2021. He oversees approximately 90 full-time team members whose duties range from permit writing and rulemaking to evaluating emissions and helping stakeholders comply with their permits.
Stephen has worked for the department for 22 years and for the Air Program for the last 12 years. Most recently, he served as the chief of the program’s Air Quality Analysis Section. Before working for the State of Missouri, Stephen taught high school Algebra I and Physics. Stephen holds a Master’s of Business Administration from Franklin Pierce College, Rindge NH, with undergraduate double majors in Physics and Mathematics from Gordon College, Wenham, MA.
Michael Hutcheson, Ameren
MHutcheson@ameren.com
With a Bachelor degree in Nuclear Engineering from the University of Illinois, Michael Hutcheson has spent the last 33 years working on solutions to environmental issues including contaminated site characterization and remediation, emission inventories, modeling, permitting, environmental compliance and regulatory advocacy. Mr. Hutcheson, as Manager, Environmental Services, leads a group of engineers and scientists who are responsible for air quality compliance, monitoring, recordkeeping and reporting for all Ameren Missouri facilities. Mr. Hutcheson also has responsibility for regulatory advocacy activities and maintains leadership positions in multiple industrial environmental advocacy and research organizations. Mr. Hutcheson has a passion for the research on the causes and contributors to air quality problems and for seeking out cost effective solutions.
Mark Leath, MDNR
mark.leath@dnr.mo.gov
Mark is the Air Quality Planning Section Chief with the Missouri Department of Natural Resources’ Air Pollution Control Program. He is licensed as a professional engineer in the State of Missouri and he holds a Bachelor of Science degree in Civil Engineering from the University of Missouri Columbia. He has been with the Department for nearly 17 years, all of which have been with the Air Quality Planning Section. In those 17 years, he has authored, contributed, or overseen the development of Missouri State Implementation Plans (SIPs) for every type of criteria air pollutant, numerous Missouri air regulations, amendments, and rescissions, and has served as a technical project manager or contributor for several EPA grants administered by the Air Program.
Josh Lee, Trinity Consultants
Joshua.lee@trinityconsultants.com
Josh Lee is a consultant in Trinity’s St. Louis office. He graduated from the University of Missouri – Columbia with a Bachelor of Science in Chemical Engineering and began his career in environmental consulting. Since joining Trinity, Josh has supported clients representing a variety of industries including chemical manufacturing, oil and gas, cement, and grain handling. His focus areas are air permitting and compliance, air dispersion modeling, SPCC, and SWPPP/NPDES.
Kevin Perry, REGFORM
kperry@regform.org
Kevin is Assistant Director at REGFORM, a Missouri association focused entirely on State and Federal environmental regulations & policies. He is a registered lobbyist & holds a BS degree in biology. He has over 30 years of experience, including work as a biologist at US EPA Office of Water. He sings in the choir at church.
Segolene Renaze, MDNR
segolene.renaze@dnr.mo.gov
Ségolène joined the Missouri Department of Natural in 2022 as the Air Pollution Control Program’s legal counsel. Prior to joining the department, Ségolène worked as an attorney in family law and as legal counsel for an international software company. Ségolène received her master’s degree in environment and law from the University of Rennes, France, after which she received my law degree from Washington University in St. Louis School of Law. During her time at Washington University, Ségolène was involved with the Interdisciplinary Environmental Clinic as well as other environmental organizations in the St. Louis area.
Dana Skelley, EPA Region 7
skelley.dana@epa.gov
Dana Skelley has been with U.S. EPA Region 7 since 1997, and currently serves as the Director of the Air and Radiation Division. The Air and Radiation Division handles standards implementation, review and approval of state implementation plans, air modeling and monitoring, air toxics, permitting, delegations, indoor air and grants. She began her EPA career with the Office of Regional Counsel and has served in a variety of roles. Dana received a Bachelor of Science in Animal Ecology and Environmental Studies from Iowa State University and a Juris Doctorate from Drake University.
Richard Swartz, MDNR
richard.swartz@dnr.mo.gov
Hi, I’m Richard Swartz, Compliance & Enforcement section chief in the Air Pollution Control Program with the Missouri Department of Natural Resources. I’ve been in this position for 6 years. I’ve been with the Department 22 years. Prior to that I worked in private consulting mainly dealing with site characterization work prior to implementation of remediation strategies. In my free time my wife and I enjoy spending time on our hobby farm taking care of various livestock including sheep, chickens, and bees.
Josh Vander Veen, MDNR
josh.vanderveen@dnr.mo.gov
I was born in Grand Rapids, Michigan and spent my early years in life being fascinated by the weather (particularly winter weather). I further pursued my interest by attending and graduating from the University of Missouri-Columbia with a Bachelor of Science degree in Soil and Atmospheric Science in 2006. I started working for the Missouri Department of Natural Resources with the Air Pollution Program in 2008 as a permit modeler. Since that initial role, I worked in the Department maintaining ambient air monitoring equipment and the associated data, auditing stack tests, managing state vapor recovery requirements in Kansas City and St. Louis, and working in the Gateway Vehicle Inspection Program. I am currently the Air Quality Analysis Section Chief with the Department’s Air Pollution Control Program. The Air Quality Analysis team is responsible for managing the Program’s files, small business assistance, emissions inventories, and the ambient air monitoring network. In my free time I enjoy being with family, being outside, watching pretty much any movie, and watching the weather.
Roger Walker, REGFORM
rwalker@regform.org
Roger has a private legal practice focusing on permitting, compliance, and enforcement, but spends most of his time managing REGFORM, a business association in MO that works on numerous regulatory matters. He has a JD from UMKC and LLM from Lewis & Clark School of Law.
Chris Weber, Trinity Consultants
Chris.Weber@trinityconsultants.com
Chris Weber serves as the new Operations Manager of Trinity’s Kansas City, Kansas office. After graduating from Vanderbilt University in 2000, Chris began his career in environmental consulting in Texas supporting the electric utility, petroleum refining, and chemical production industries. He joined the Environmental Compliance team HOVENSA, once the largest refineries in the Western Hemisphere, in 2011, then returned to consulting while based out of Washington state and Colorado. Immediately prior to joining Trinity in 2024, Chris was the corporate Air Quality Lead for Seminole Electric Cooperative, a G&T utility serving 2 million customers in Florida with a generation mix of coal-fired boilers, combined and simple cycle combustion turbines, and solar. At Seminole, he contributed to NERC compliance programs, participated in NRECA and other industry trade group committees, managed complex air permitting for a new combined cycle facility, and led efforts to address challenges from the MATS Rule and the ACE Rule.