Sharon Jones
Strategic Regulatory Compliance Planning
Ms. Jones has worked with many facilities in evaluating their applicability under various air quality regulations. If she identifies positive applicability, she also works with interdepartmental teams to develop compliance strategies that align best with each company’s business plans and cultures. She has experience working with a variety of federal rules, including (but not limited to) NSPS Subparts A, D-series, J, K-series, GG, VV, XX, GGG, III, RRR, and NNN, as well as various 40 CFR Part 61 NESHAPs, including Benzene Waste Operations NESHAP (BWON). Additionally, she has experience in evaluating applicability and compliance with various 40 CFR Part 63 (MACT) standards, such as the General Provisions, the Hazardous Organic NESHAP (HON), Pesticide Active Ingredients, Group IV Polymer and Resins, Gasoline Distribution, Marine Loading, and Refinery MACTs. She has also worked with the more recent standards, including the Miscellaneous Organic NESHAP (the MON), Organic Liquid Distribution (OLD) MACT, Coating MACTs, and Combustion MACTs. Further, she has prepared and certified Spill Prevention Control and Countermeasure (SPCC) plans, both under “old” and “new” rules.
At the state level, Ms. Jones has worked with clients to comply with the 1995 VOC RACT provisions of Texas Regulation 115, the 1999 NOx RACT requirements of Regulation 117, and more recently the NOx SIP Mass Emissions Cap and Trade program and the Highly Reactive VOC standards, and cap and trade rules pertaining specifically to the wide breadth of facilities in the Houston/Galveston/Brazoria area. As an example, she has been an integral member of clients’ internal NOx SIP teams, meeting regularly with engineering, maintenance, and environmental department managers and directors; plant managers; and executive management teams to identify cost-effective business solutions that combine physical and operational changes to plant equipment and emissions trading to optimize capital planning and coordinate with core business plans for the future. Ms. Jones also led an effort to develop alternative test strategies for demonstrating the exemption status from HRVOC rules for atmospheric vents in a large polyolefin manufacturing plant in Harris County. She is also participating in the 8-hour ozone SIP development process, attending stakeholder meetings and communicating strategies and potential implications to clients.
As part of her regulatory planning experience, Ms. Jones has also assisted refineries and an ethylene plant in responding to Section 114 requests by the EPA and Department of Justice, as well as provided support in complying with resulting Consent Decrees.
Regulatory and Legislative Reviews
In both her role in industry as well as on behalf of clients, Ms. Jones has reviewed and provided recommendations for comment to various proposed regulations. She has monitored the Federal Register, the Texas Register, and other states’ related documents for rule changes potentially affecting her company while in industry or her clients as a consultant. In several cases, she has been contracted by clients to provide routine updates related to proposed and promulgated rules and how these regulations might affect client operations and within what timeframe(s). Further, she has participated in several industry workgroups, such as the one that worked to develop General Operating Permits in Texas and ones relating to HRVOC rule changes, emissions inventory changes, and 8-hour ozone nonattainment SIP rules. Her participation in the rulemaking process in its early stages helps to keep clients informed and keep her technical skills current to better provide up-to-date advice to her various client partners.
EHS Compliance Auditing
Ms. Jones has applied her regulatory and management systems knowledge by leading and/or participating in environment, health, and safety (EHS) compliance and program/system audits. Throughout 2006, she led seven EHS compliance audits for a major oil and gas company’s exploration and production operations in Texas, Louisiana, New Mexico, Wyoming, Alaska, and offshore in the Gulf of Mexico. Her auditing expertise includes applicable environmental regulations including air quality permitting and compliance; water permitting, management, and discharge; spill prevention control and countermeasures (SPCC); waste management; underground injection control (UIC); and various states’ oil and gas commission regulations. She has also audited offshore platform compliance with Minerals Management Service (MMS) requirements and participated in identifying and recommending solutions for health and safety issues. Ms. Jones has been instrumental in preparing the audit reports for these efforts and presenting findings to Business Unit and Operations Management teams.
Ms. Jones has conducted other compliance and program audits under a variety of direction, including contracted by the client, working for counsel under attorney-client privilege, and/or using the benefits afforded by the Texas Environmental Health and Safety Audit Privilege Act. In some cases, detailed compliance evaluations have been conducted as part of a Title V permitting or deviation reporting effort. In addition to her exploration and production experience detailed above, she also has conducted audits for natural gas and refined products pipelines, gas sweetening and separation plants, refineries and petrochemical plants, secondary metals processing sites, surface coating/manufacturing plants, airports, and universities.
Environmental Permitting
Ms. Jones has prepared over 150 air quality new and modified source authorization requests, including state and federal preconstruction permit applications, permit by rule (PBR) and standard permit registrations, and voluntary emissions reduction permit (VERP) applications. Additionally she has prepared the air quality addendum to several RCRA permits. Throughout her career as an air quality engineer, she has developed all aspects of these documents, including onsite data collection, emissions estimation, control technology analyses, regulatory applicability and compliance discussions, process descriptions, and various agency-required graphics, forms, and tables. For these many projects, Ms. Jones has served in capacities including project engineer, project manager, and senior technical and quality assurance reviewer. As part of the permitting process, she has negotiated permit conditions with the Texas Commission on Environmental Quality and other state agencies, both on behalf of clients and while working for a pipeline company. Additionally, she has presented to executive management at several client facilities on current permitting requirements and associated risk/benefit scenarios of various permitting options.
In addition to her new source review permitting experience, Ms. Jones has also led Title V permit application and compliance demonstration efforts for various petrochemical plants, natural gas and refined products compressor stations and pipeline terminals, metal parts surface coating plants, and gas plant facilities in Texas, Louisiana, and Oklahoma. In this capacity, she provided project management and senior technical leadership to develop both General Operating Permit registrations and Site Operating Permit applications, as well as assisted clients in reviewing and commenting to draft permits and conducting compliance evaluations for semiannual deviation reporting and annual compliance certifications.
Much of Ms. Jones’ permitting experience has been in the petrochemical, refining, upstream and midstream oil and gas, heat and power combined cycle systems, and surface coating markets; however, she has also served a variety of other industries including carbon black processing, metals processing, and miscellaneous manufacturing facilities. She has permitted facilities in numerous states, including Texas, New Mexico, Louisiana, Arkansas, Missouri, Illinois, Indiana, Ohio, Pennsylvania, and New York.
Emissions Inventories
Throughout her air quality career, Ms. Jones has developed emissions inventories both for reporting actual emissions in annual emissions inventory questionnaires and SARA reports and for establishing potentials to emit for permitting and regulatory applicability purposes. She has used measured data, materials balance, vendor guarantees, AP-42, process knowledge, and emissions models (such as EPA’s TANKS 4.09 and WATER9) to evaluate emissions from client facilities. In come cases, these emissions estimates were used for retroactive netting evaluations, tort litigation, and contested case hearings, in addition to the more routine use in air permit applications and periodic emissions reporting. Her emissions experience spans numerous source types, including process vents, piping fugitives, combustion devices (e.g., flares, boilers, heaters, oxidizers, compressors, turbines), product transfer, tanks, wastewater collection and treatment, surface coating, material transfers (e.g., hoppers, conveyors), wind erosion, vehicular road dust, and maintenance/startup/shutdown events.
Education and Professional Certification
Bachelor of Science, Chemical Engineering (with Honors), University of Oklahoma
Licensed Professional Engineer:
- Texas
- Louisiana
- Arkansas
- Illinois
- Indiana
- Missouri
- Ohio
- New York
- Pennsylvania
- Kentucky (inactive)
Publications and Presentations
Jones, S.P., “Strategic Compliance Planning in Eight-Hour Ozone Nonattainment Areas,” Paper #ENV-06-172, presented at the National Petrochemical and Refiner’s Association Annual Environmental Conference, September 2006, San Antonio, Texas.
Jones, S.P. and V. R. Tino, “Eight-Hour Ozone Standard: Opportunities for Facility Permitting,” Paper #192, presented at the Air and Waste Management Association 2006 Annual International Meeting, June 2006, New Orleans, Louisiana.
Hampton, S.P. and A. Castaño, “Miscellaneous Metal Parts Coating Maximum Achievable Control Technology (MACT) Overview and Application,” Paper #1163, presented at the Air and Waste Management Association 2005 Annual International Meeting, June 2005, Minneapolis, Minnesota.
Hampton, S.P., “Air Quality: Houston/Galveston SIP Update,” presented at the Texas Association of Business’ Annual Environmental Update Workshop, October 20, 2004, Houston, Texas.
Hampton, S.P. and D.D. Bradley III, “Refinery Air Quality Enforcement Issues,” Hydrocarbon Processing, August 1999.
Hampton, S.P., “Self Audits as an Environmental Assessment Tool,” presented at the South Texas Environmental Conference, March 26, 1997, Corpus Christi, Texas.
Hampton, S.P., “Emerging Issues: Self-Audits vs. Enforcement,” presented at the National Association of Environmental Professionals annual conference, June 4, 1996, Houston, Texas.
Professional Associations
Air and Waste Management Association:
- International Member (1991 to present)
- Gulf Coast Chapter Member (1994 to present)
- Chapter Board member (1999 to 2001, 2004 through 2005)
- ”Hot Air Topics” Conference Chair (1999 through 2002)
American Institute of Chemical Engineers:
Tau Beta Pi
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