Peyton & Associates Consulting

Business - Environmental - Public Affairs

Environmental Project Summary

  • Texas  - Chemical Manufacturer - BIF compliance program.  Performed audit, identified deficiencies, formed operating team, created training program, trained staff, created environmental compliance check system.
  • Texas - Formosa Plastics – Technical.    Managed spill clean up.  Dredging project.  Developed work plan, performed site investigation, risk assessment, and met with TNRCC for clean-up plan approval.  Selected subcontractor for field activities. 
  • Texas  - Formosa Plastics.  Site investigation to determine subsurface extent of a light-end hydrocarbon spill and impact to groundwater.  Developed work and sample plan, field supervised sample activities, produced final report and presented it to TNRCC for final approval.
  • Texas  - Industrial Client.  Environmental audit, Waste classification, Site assessment.  Client was operating without permits since start of operations (approximately 17 years).  Worked with agency to enter into volunteer audit program to correct environmental findings including operating without a permit for an abrasive cleaning facility, a paint application booth and storm water control.  Corrected sanitary discharge deficiencies and successfully classified and removed approximately 9000 yards of unregistered waste.  
  • Texas  - Chemical Manufacturer - RCRA Tank closure.  Cleaned and closed an above ground RCRA storage tank.
  • Texas - Industrial Client - RCRA Tank Certification.  Inspected facility, corrected deficiencies and certified RCRA tank installation as a result of an NOV received by client from an unannounced TNRCC inspection. 
  • Louisiana - Natural Gas Supplier.  Expert Witness for Personal Injury Litigation.  Injured claimed that poor quality natural gas caused injury.  Represented client as operations expert relative to reasonable and normal operating practices for process operation and maintenance.
  • Texas – Chemical Manufacturer – Fugitive Emissions Program Management.  Managed the fugitive emissions program protocol, data accumulation, data management and report generation.  Client expanded the program after 6 months to include fugitive emissions monitoring.  Facility operates under HON guidelines and has approximately 150,000 monitored components. 
  • Texas – Industrial Manufacturer – Tank Demolition.  Client required the removal of a temporary storage tank to allow for plant expansion.   Used hydraulic shear subcontractor to destroy tank.  Tank was recycled to local smelter for reuse as reinforcing steel.
  • Texas – Industrial Manufacturer – Asbestos Remediation.  Removed and disposed asbestos from locker room facilities. 
  • Texas – Industrial Manufacturer – Tank Decontamination.  Transferred residual materials, cleaned and decontaminated storage tanks so client could use them for other purposes.
  • Texas – Industrial Manufacturer – Surplus equipment investigation.  Inspected surplus equipment, made recommendations for decontamination and transfer. 
  • Texas – Industrial Client. Performed RCRA audit at their pharmacutical recovery facility.  Made recommendations to handing, labeling and storage practices for prescription and non-prescription pharmaceuticals.
  • Texas – Industrial Client Group.  Expert Witness for local industries to determine normal and reasonable operating practices associated with an odor claim by local residents. 
  • Texas – Wellmann Thermal. Phase I inspection for property transfer.
  • Texas – Marathon Ashland Petroleum.  Fugitive emissions program audit. 
  • Texas – Industrial Client – Leak Determination and Repair Program.  Participated with client in cost saving program to include first attempt leak repair as part of the overall fugitive emissions management program.
  • Texas – Industrial Client. Reviewed and revised facility procedures for the accumulation, classification, storage, transfer and disposal of facility generated waste. 
  • Texas – Industrial Client. Audit water and wastewater sampling methods for EPA compliance.  Reviewed and revised existing procedures.  Produced new procedures where applicable.
  • Texas – Industrial Client.  Audited waste manifesting system.  Investigated internal procedures.  Recommended reassignment of responsibilities and centralized and consolidated the database.  Revised procedures to include final inspection of documents and containers before release from facility. 
  • Texas – Industrial Client.  Audited drinking water system.  Made corrections in data accumulation system.  Made recommendations to bring system in compliance with current quality and treatment standards.  Met with TNRCC to revise reporting system. 
  • Texas - Industrial Client. Audited internal waste handling system.  Made recommendations for upgrade and revision to container cleaning facility.  Revised drawings.  Generated training program and control system to protect against improper disposal and handling.  
  • Texas – Industrial Client. Audited barge and ship loading and unloading compliance with air permits and USCG requirements.  Revised procedures and made recommendations for modifications in vent gas incinerator control logic.  Updated training material and trained operating staff.
  • Texas – Industrial Client. Air permit compliance audit of process unit.  Identified deficiencies, recommended corrective action, instituted follow-up program and filed final status report. 
  • Texas – Industrial Client.  Compliance audit for refrigerated ammonia storage, transfer and distribution system.  Reviewed and updated existing operating procedures and training documents.  Corrected and revised testing documentation.
  • Texas – Industrial Client. Developed and implemented a CEMS daily audit and inspection program to include inspection format data accumulation and reporting.  System generates trend information for early detection of problems.  Reports include quarterly and annual NSPS reporting. 
  • Texas – Industrial Client.  Revised and produced QA manual for facility CEMS system in compliance with all EPA and TNRCC requirements for each operating unit.  The manual will be maintained and used as historical documentation as well as a training guide.
  • Texas – Houston Advanced Research Center. Co-authored article on sustainability (with Jim Blackburn). 
  • Texas – Industrial Client. Audited benzene (NESHAP) wastewater vent control system.  Identified deficiencies and implemented recommendations for correction.  Revised operating procedures, changed out activated carbon in regeneration unit.  Updated operating procedures and created a new training program for the operating staff.
  • Texas – Industrial Client.  Established HRVOC Fugitive Monitoring Program. 
  • Texas – Industrial Client.  Investigated HRVOC Flare system.  Performed field investigation, up-dated process and engineering single line drawings, identified deficiencies and made recommendations for compliance.
  • Texas – Industrial Client.  Established procedures for continuous HRVOC monitoring for cooling towers and monthly monitoring for VOC.  Developed procedures for heat exchanger leak monitoring and corrective action.  
  • Texas – Industrial Client.  Managed LDAR program for 160,000+/- component system using LeakDas.
  • Texas – Industrial Client. Managed Stack testing program including preparation of bid packages, bid analysis, test scheduling and field oversight


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Peyton and Associates Consulting
23012 Landrum Village Dr.
Montgomery, TX  77316

Houston Metro 936-449-5511
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Larry G. Peyton

Barbara Peyton

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