EHS Platform Developer

TRACY A. DEPUGH

MS, CSP, CHMM, CHST, OSHA **(****/1926)

Chillicothe, Ohio 614-***-**** ******.*****@*****.*** 1 P A G E

Q U A L I F I C A T I O N S S U M M A R Y

Accomplished divisional & regional EHS platform developer, manager and director; backed with business acumen, regulatory expertise and distinguished performance in diverse manufacturing settings as well as chemical production industry sectors. Equipped with more than 20 years of leadership experience in deciphering, analyzing, summarizing and communicating Health, Safety, Environmental and Transportation laws, standards, regulations and/or best practices……crossing regions and spanning continents.

Well versed in the development and administration of health & wellness initiatives such as: Behavioral Based Safety “BBS”, Near Miss/Injury Prevention (leading/lagging indicator tracking & analysis), Industrial Hygiene/Noise & Ergonomics as well as safety programs/plans warranted under: Process Safety Management “PSM” (e.g., MOC, PHA, PSSR, Hot Work), Emergency Action, Fall Protection, Confined Space, LOTO, PPE, HazCom & additionally, NEC (Class I/Div 1) & NFPA (70e).

Experienced in directing compliance programs warranted under CAA, CWA, DEA, FIFRA, RCRA, SARA, TSCA, DHS, REACH and CEPA (Environment Canada), EMAS (Europe) and ISO (14001, 45001 “OHSAS 18001”).

Competent in developing, implementing and administering management systems and procedures to comply with regulatory requirements, business objectives and reporting mandates in respect to SPCC, SWPP, RMP, EPCRA/SARA (311, 312 and 313), TSCA “CDR”, FIFRA and OSHA (300, 300A and 301).

Strategic in the preparation and negotiation of operational/discharge permits, including Part "B"

(RCRA), TITLE V & Synthetic Minor (CAA), NPDES “402” and POTW “307(b)” (CWA) permits. P R O F E S S I O N A L E X P E R I E N C E

DePugh EHS LLC Chillicothe, OH 07/2023 – Present Full-Service “Gate-to-Grave” Regulatory Compliance Consulting

Regulatory Compliance Assessments “Evaluation/Applicability Determination”

Site Specific Program Development “Management Systems/Procedures”

Permitting, Reporting, Auditing & Training

PPG Industries - Pittsburgh, PA 07/2022 – 07/2023 Corporate Manager - Environmental, Health & Safety “EHS” (Automotive OEM Coatings, Circleville, OH)

Oversee all EHS programs for both the Resin Manufacturing/Coating Facility and the Energy Recovery Unit “ERU” Incineration Facility (i.e., PPG North America Captive Facility).

Direct a highly skilled and diverse EHS staff of eight, encompassing both exempt and non-exempt individuals, including: a Safety Engineer, an Environmental Engineer, a Process Safety Engineer, an EHS Specialist, Two Environmental Technicians, a Safety Specialist and an Occupational Nurse. TRACY A. DEPUGH

MS, CSP, CHMM, CHST, OSHA 30(1910/1926)

Chillicothe, Ohio 614-***-**** ******.*****@*****.*** 2 P A G E

PPG Industries Circleville, OH …..Cont.

Provide direction, support and oversight for all critical EHS aspects and regulatory program functions, such as: Title V, MACT, NPDES and RCRA reporting, Incident Command System, Safety & Wellness “One PPG” (e.g., PPG Safety Critical Procedures and OSHA Standards), as well as Management Of Change “MOC”, Process Hazard Analysis

“PHA”, Process Safety Start-up Review “PSSR and ISO 14001 administration, auditing, tracking and closure.

Administer and support development and implementation of: Corporate Industrial Hygiene “IH”, Job Hazard Analysis

“JHA” and Site Security and Emergency Medical Response systems and programs. ENGIE Energy Solutions-North America Columbus, OH 09/2020 – 07/2022 Environmental, Health & Safety Representative “North America” (stationed at “The Ohio State University”)

Direct all EHS environmental, health, safety and transportation programs for natural resource and power system energy demands for client facilities under ENGIE North America contracted responsibility.

Conduct Industrial Hygiene “IH” and Noise surveys to determine personal exposure levels in comparison to applicable Personal Exposure Limit “PEL” (OSHA), Threshold Limit Value “TLV” (ACGIH) and the Recommended Exposure Limit

“REL” (NIOSH) criteria.

Utilizing IH and Noise survey data; establish hierarchy for targeted areas/activities, evaluate engineering control options, assess and implement Personal Protective Equipment “PPE” requirements necessary to impede health risks.

Perform gap analysis and comparison of Health and Safety programs for both existing Operations & Maintenance

“O&M” facility activities (e.g., OSHA General Industry Standards Part 1910) and large-scale new construction projects

(i.e., Capital Expenditure “CapEx” Construction Industry Standards Part 1926).

Provide EHS oversight for the construction of a >300M Combined Heat & Power (CHP) facility for The Ohio State University. Administer and assess the development of Job Hazard Analyses (JHAs) based on weekly forecast meetings entailing the numerous phases of the project ranging from initial soil classification, excavation activity hazard controls (i.e., sloping, shoring/shielding applications), working at heights (scaffolding/steel erection), utility connections and wire pulls. Not to mention the drill down of job specific tasks for the development of Job Safety Analyses (JSAs) associated w/ portable hand tool use and other interior trade activities/functions such as hot work, electrical and pipe fitting.

Procure iPads for each department engaged in field service activities equipped with direct links to the QCC guidance information. Utilizing gap analysis and QCC data, develop inventory of robust Standard Operating Procedures “SOPs” and training modules for all Health & Safety programs and provide calibration training to all O&M departmental and CapEx project managers.

Working with both agency and ENGIE personnel, refine and streamline Title V Permit reporting program for quarterly, semi-annual and annual reporting obligations to align with both state and federal permit requirements.

Develop protocol and systems to ensure critical Predictive Emission Monitoring System “PEMS” data is automatically communicated to boiler-house control room operators and other essential ENGIE personnel

Ensure timely preparation, completion and submission of Title V Relative Accuracy Testing Audit “RATA” and Relative Accuracy Audit “RAA” and associated Excess Emission Reports “EER” for regulated Boiler Systems.

Monitor & oversee submission of USEPA NOx reporting via the Emissions Collection and Monitoring Plan System

“ECMPS” software program.

Quickly established and rolled-out guidance and management protocol for all waste generation activities, specifically those programs entailing generator storage time constraints (e.g., Universal Waste and Polychlorinated Biphenyl materials)

TRACY A. DEPUGH

MS, CSP, CHMM, CHST, OSHA 30(1910/1926)

Chillicothe, Ohio 614-***-**** ******.*****@*****.*** 3 P A G E

Core Molding Technologies Columbus, OH 09/2019 – 05/2020 Corporate Director - Environmental, Health & Safety – “Americas”

Direct all EHS site personnel managing environmental, health, safety and transportation programs for 7 thermoset/thermoplastic compression and injection molding/assembly sites across the Americas (4 US, 2 Mexico and 1 Canada)

Diagnosed opportunities for cost savings via the hazardous waste treatment exclusion under the “POLYM” (i.e., formation of high complex molecular solids via high TOC “D001” Non-Wastewater monomer polymerization); affording a generator the opportunity to conduct on-site treatment of such hazardous wastes outside the applicability of a RCRA Part “B” Permit saving the entire corporation in upwards to 500K annually in disposal costs annually (i.e., $.05 vs

$2.00 per pound).

Managed City of Columbus Sewer District “OEPA” complaint inspection (i.e., alleging oil contamination of storm water discharge). Worked with agency personnel, specifically in defining and applying regulatory context to the term

“discharge” (i.e., effluent that exits the property and enters a navigable water of the state). Thus, in light of the fact that the oil was retained in the retention pond it was not a discharge off-site, agency personnel concurred and left the site without further issue and ultimately issuing the site a formal letter of compliance and de-validation of the original compliant.

Utilizing knowledge of National Electric Code “NEC” (i.e., NEC Article 500 – 506) circumvented Loss Prevention insurance issues and premium increases in respect to insurance carrier concerns regarding the use of non-rated forklifts in the hazardous waste “flammable” storage locations for 3 US sites. Provided clarification to the insurance carrier as to the miss-application of the Class I, Division 1 & 2 Hazard Area Classifications as specified under OSHA

(i.e., 29 CFR 1910.178, 1910.307 & 1910.399) and NFPA 70; ultimately resulting in renewal of policy w/ no additional premium costs.

Re-visited OEPA’s position (i.e., NOV) on past excursions of Title V emission limits, specifically interpretive but realistic application of the agency’s “Malfunction Reporting” rule (i.e., OAC 3745-15-06) enforceable criteria as it relates to the 72 hour exceedance window for written reporting. Specifically, garnered the agency’s concurrence that anomalous individual, intermittent and episodic excursions spanning a 72 hour period do not constitute a single 72 hour solitary event, thus vacating the previous NOV and setting the stage for a more open and admirable dialogue w/ the agency going forward.

Unveiled major gaps in the Columbus preparation plan for their 5 day ISO 14001 Environmental Standard re-cert audit. Took the reins, worked with the auditor and arrived to action plans to suffice all non-conformances and garnered the re- certification under the program for another 3 years.

Managed OSHA Complaint and previous incident follow-up inspection. Met inspectors in lobby; requested copy of and reviewed allegations of complaint. Developed good rapport & controlled scope of inspection. On the fly, quickly diagnosed and led inspectors on an innocuous facility route to complaint area; minimizing risks of negative observations outside the realm of the original complaint. Provided and sufficed all safety and health program document requests albeit innovative and unorthodox methods outside customary formats, greatly reducing potential penalties and fines.

PACCAR “Kenworth Truck Company” Chillicothe, OH 06/2014 – 09/2019 Environmental Engineering Manager – PACCAR “Kenworth” Division

Oversee all environmental and associated regulatory programs encompassing: CAA “Title V Permit”, CWA “NPDES & POTW” Permits, RCRA, SARA, DOT; as well as counselling & support of site OSHA programs.

Managed & developed a staff consisting of 18 reports (i.e., 8 Kenworth “direct”) including: 7 environmental technicians, 1 environmental engineer and 10 contract environmental personnel.

Develop/prepare, submit and/or approve all corporate reporting activities and reports, including: GHG, Edge, Waste and Sustainable Energy reporting.

TRACY A. DEPUGH

MS, CSP, CHMM, CHST, OSHA 30(1910/1926)

Chillicothe, Ohio 614-***-**** ******.*****@*****.*** 4 P A G E

PACCAR “Kenworth Truck Company” Chillicothe, OH….Cont.

Re-tooled ISO 14001 Program. Utilizing past Responsible Care “RC” 14001 program model experience, streamlined and eliminated associative redundancy and duplication of aspects and corresponding impacts as well as created a robust and relevant Operational Control Procedure “OCP auditing program.

Leveraged understanding of NAAQS attainment area criteria with agency negotiation experience to extract OEPA concurrence to modify Chassis Unit Permit without triggering Prevention of Significant Deterioration (PSD) permit requirements. Utilizing RCRA regulatory knowledge, coupled with an understanding of the nuances between EPA and DOT, instituted elimination of 120,000 lbs. from the site’s annual Hazardous Waste Footprint (i.e., annual hazardous waste generation).

Received OEPA Director’s “Encouraging Environmental Excellence” (E3) award…..developed application and lobbied OEPA on site’s behalf…….site received E3 award recognition: 2016, 2017, 2018 & 2019…while under my tenure.

Provided EHS oversight for the construction of a >400M new Cab and Chassis Paint Facilities. Provided technical expertise and consultation in daily morning briefing meetings. Administer and audit Job Hazard Analysis (JHAs) and Job Safety Analysis (JSA) programs, specifically excavation activity hazard controls (i.e., sloping, shoring/shielding) and scaffolding/steel erection, and portable hand tools. Complete and report assessment findings and review corrective actions w/ General Contractor (GC) in daily wrap-up meetings.

Constructed and developed electronic compliance determination tools for entire PACCAR Americas organization, specific to both the Reciprocating Internal Combustion Engine “RICE” (i.e., MACT) and New Source Performance Standards “NSPS” Internal Combustion Engine (ICE) Compression Ignition “CI” and Spark Ignition “SI” regulatory initiatives.

Via thorough knowledge of USEPA RCRA BB program and the avenues for regulatory exclusion; counselled site on opportunity for the utilization of portable Tote-tanks for managing waste purge solvent in bulk (e.g., 6000 gallon Tanker Shipments) vs. management in drums (e.g., 5200 gallon/100 Drum “Box Trailer” Shipments)………first year ROI

>250K.

As part of both Corporate and Ohio EPA’s Encouraging Environmental Excellence “E3” Sustainability initiatives; elevated the Division’s community awareness persona via the administration of various philanthropy projects (e.g., Sleeper Mattresses donation to community homeless shelters, donation of non-chemically contaminated wooden pallets to pollinator habitats and arranging and hosting periodic Prescription “Rx” Drug “take-back” programs with local law enforcement authorities)

DePugh Environmental Corporation Chillicothe, OH 09/2012 – 06/2014 Full-Service “Gate-to-Grave” Regulatory Compliance Consulting Dayton Superior Corporation “DSC” Miamisburg, OH 12/2013 – 06/2014 Corporate Consulting/Director – Environmental, Health & Safety

Refined and re-instituted the corporation’s EHS-Compliance Management System “EHS-CMS” for 35 manufacturing, rental and distribution facilities, spanning the north, central and south Americas.

Re-developed Title V permits as synthetic minors for two chemical processing plants, leveraging re-calculation of product (VOC Contained-In) organic emissions and particulate collection system efficiency.

Developed KPI-M (Key Performance Indicators-Metrics) data development, gathering, tracking & reporting in correlation with DSC objectives and BOD strategies.

Implemented Hazard Identification/Risk Assessment “HI/RA” process/survey (e.g., Machine Guarding, LOTO, Fall Protection, PPE, etc.) for all 35 manufacturing, rental and distribution facilities. Prepared HI/RA findings report for Corporate Legal Counsel, detailing a risk rank prioritization and mitigation plan for all surveyed risks. TRACY A. DEPUGH

MS, CSP, CHMM, CHST, OSHA 30(1910/1926)

Chillicothe, Ohio 614-***-**** ******.*****@*****.*** 5 P A G E

AkzoNobel Coatings Inc – BUs “IF & ICo” (Coil sBU) Columbus, OH 08/2004 – 08/2012 Director – Health, Safety, Environmental & Regulatory Affairs “Coil Americas & Europe”

Research, evaluate, and convey health, safety, environmental, transportation and security regulations, standards and directives impacting the AkzoNobel Coil Americas and Europe “A/E” sites. Mentor, guide, and lead A/E site HSE Managers throughout the development of HSE&S programs in association with country regulatory obligations and AkzoNobel’s HSE objective requirements.

Provide oversight and guidance on all HSE&S regulatory and AkzoNobel compliance development strategies warranted via REACH and GHS legislation impacting A/E sites. Counseled A/E sites in the development and institution of universal waste categorization (i.e., definition specific) classification system in support of Key Performance Indicator

“KPI” (NASDAQ Sustainability) data reduction initiative, encompassing Waste Generation, Carbon Footprint & Energy Conservation reporting criteria.

Developed and instituted both, Behavioral Based Safety “BBS” and Performance Incentive (i.e., PIP) Programs across A/E sites coupled with development of Health and Safety Plan (HASP) protocol for on-site contractor and remote off- site employee project activities, greatly influencing a heightened level of safety awareness and ultimate reduction in injury incidence rates across A/E region.

Via interpretation and utilization of Ohio “Air” De Minimis rule, leveraged an additional production capacity increase in Columbus (US) Permit To Install “PTI” by 265,000 gallons, without altering existing PTI nor solicitation of new PTI application relevant to a major modification NSR or PSD permitting constraints and/or requirements.

Successfully negotiated US sites (Columbus & Huron–Ohio, Birmingham–Alabama, Clinton–Mississippi) reclassification of alike hazardous waste paint debris streams with Ohio Environmental Protection Agency “OEPA”, Alabama Department of Environmental Management “ADEM” & Mississippi Department of Environmental Quality

“MDEQ”, bringing about significant annual reduction in hazardous waste generation for Coil US region 200K lbs total combined reduction).

Veolia Environmental Services, Midwest Region West Carrollton, OH 10/2000 – 08/2004 Regional Regulatory Affairs Manager – Environmental, Health, Safety & Transportation

Oversaw and directed entire spectrum of regulatory compliance programs spanning a (6) state region and encompassing: 5 DOT Transfer/Field Service Facilities, 1 Hazardous Waste Collection/Consolidation Facility, 1 Hazardous Waste (i.e., Mercury) Retorting Facility and 1 Part “B” Hazardous Waste Treatment, Storage & Disposal Facility “TSDF”.

Oversaw and directed all regional Health & Safety activities specific to Industrial Hygiene and Medical Surveillance Program implementation as well as development and review of all remote activity Health & Safety Plans “HASP”.

Oversaw, administered and monitored all regional (i.e., multi-state) Workmen’s Compensation Programs.

Significantly restructured 1997 TSDF Title V Permit Application, resulting in re-classification of the facility as a Minor Opt-In Title V source, as well as revision to facility & agency’s previous position associated w/ NESHAP Sbprt. FF

“Benzene Waste”; negating capital expenditure, purchase and installation of additional air pollution control equipment

(i.e., flare).

Via proof to agency that site was a Minor Source of “HAPs”, negated latent and future regulatory constraints and potential USEPA enforcement issues surrounding implementation of MACT standards (i.e., NESHAP sbprt. DD, FF and HON), creating opportunities for the following:

Afforded initial capital expenditure reallocation for the Title V Permit emission control equipment to be re- directed to the renovation of the on-site laboratory, as well as installation of new drum dispersion/pumping station in addition to tanker wash process station.

Afforded strategic negotiation and ratification of agency approved non-permit (i.e., permit exempt) treatment techniques; allocating the Ohio facility more operational flexibility and assurance of Veolia’s competitive niche in the chemical waste treatment market.

TRACY A. DEPUGH

MS, CSP, CHMM, CHST, OSHA 30(1910/1926)

Chillicothe, Ohio 614-***-**** ******.*****@*****.*** 6 P A G E

E D U C A T I O N

Warren National University Cheyenne, WY

Master of Science “Environmental Engineering”

Iowa Wesleyan College Mount Pleasant, IA

Bachelor of Science “Environmental Science”

Ohio University Chillicothe, OH

Associate of Science “Natural Science”

C E R T I F I C A T I O N S

Institute of Hazardous Materials Management Rockville, MD Certified Hazardous Materials Manager “CHMM” (#16133) Board of Certified Safety Professionals Indianapolis, IN Certified Safety Professional “CSP” (#45856)

Board of Certified Safety Professionals Indianapolis, IN Associate Safety Professional “ASP” (#38588)

Board of Certified Safety Professionals Indianapolis, IN Construction Health & Safety Technician “CHST” (#17897) Board of Certified Safety Professionals Indianapolis, IN Safety Trained Supervisor “STS” (#18287)

Occupational Safety and Health Administration “OSHA” Washington, DC 30-hour General Industry Safety and Health Certification (#21-900******) Occupational Safety and Health Administration “OSHA” Washington, DC 30-hour Construction Industry Safety and Health Certification (#34-602******)

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