Image: Carlos Moreno
Carlos
Carlos J. Moreno
1001 Fannin Street
Suite 1800
Houston, Texas 77002

Overview

Carlos Moreno is an environmental lawyer advising clients on onshore and offshore regulations, safety requirements and emergency response. He counsels clients on, among other things, water discharge permits, process safety regulations, Clean Water Act, Clean Air Act, handling of waste, offshore regulatory requirements, and litigation.    
 
With more than 15 years of engineering and Health, Safety, and Environmental (HSE) experience in the energy and petrochemical industries, Carlos is able to assist clients with regulatory compliance and permitting concerns in all areas of environmental law. He has experience dealing with federal and state regulations that encompass environmental and process safety aspects of the energy and petrochemical industries. He has assisted clients with emergency response and claims handling. He has also been involved in resolving legal disputes through traditional litigation, as well as alternative dispute resolution. Carlos regularly publishes on process safety and significant changes in the environmental industry.

Some of his recent regulatory experience includes:

  • Key member of legal team providing assistance to OPA Claims Program for largest spill in U.S. history.  During three-month stretch preceding the 3-year anniversary, served as de-facto leader of a team of attorneys and paralegals processing thousands of individual and business claims with minimal supervision.

  • Assisted major oil and gas company in the offshore Gulf of Mexico to determine if it could discharge produced water with elevated levels of contaminants.  The operator had been sending the produced water onshore for disposal at a large expense.  I identified options available under the permit, identified a consultant to help with discharge modeling, and contacted EPA to obtain their input.  The client was able to start discharging produced water and still be in compliance with toxicity requirements.

  • Currently involved in defending a major petrochemical facility from a Clean Air Act citizen suit.

  • Provided advice to petrochemical plant on Process Safety Management (PSM); specifically, implementation of recommendations from Process Hazard Analysis.

Prior to practicing law, he worked as a process engineer, and later as an environmental advisor, for Amoco Corporation, BP Amoco, INEOS LLC, and BP. His experience covers a wide spectrum of the Oil and Gas sector, including upstream operations (onshore and offshore), refining operations, and petrochemical plants.

A native of San Juan, Puerto Rico, he is fluent in Spanish.

Experience

  • Key member of legal team providing assistance to OPA Claims Program for largest spill in U.S. history.  During three-month stretch preceding the 3-year anniversary, served as de-facto leader of a team of attorneys and paralegals processing thousands of individual and business claims with minimal supervision.

  • Assisted major oil and gas company in the offshore Gulf of Mexico to determine if it could discharge produced water with elevated levels of contaminants.  The operator had been sending the produced water onshore for disposal at a large expense.  I identified options available under the permit, identified a consultant to help with discharge modeling, and contacted EPA to obtain their input.  The client was able to start discharging produced water and still be in compliance with toxicity requirements.

  • Provided advice to an offshore operator on the applicability of OSHA recordkeeping regulations to its SEMS-regulated facilities.

  • Assisted a major petrochemical facility with the evaluation of potential environmental liabilities associated with the proposed purchase of land in chemical manufacturing service.  Brought in and supervised contractor performing the Phase 1 environmental site assessment.

  • Provided advice to major offshore operator about their potential decommissioning liabilities after the ATP bankruptcy.  I researched the regulations and case law, and provided the bulk of the legal advice to the client.

  • Prepared a Permitting and Cooperation Agreement for major project involving carbon capture from power plant emissions and CO2 injection for Enhanced Oil Recovery.  I did all the research, prepared all the drafts, and met with clients to discuss; all with minor supervision from Partner in New Orleans.  The Agreement divided up environmental responsibilities and liabilities between the power plant owner and the carbon capture facility owner. 

  • Provided advice to petrochemical plant on Process Safety Management (PSM); specifically, implementation of recommendations from Process Hazard Analysis.

  • Led efforts to document equipment preservation activities and send notices of destructive testing related to a major incident involving construction and installation of an offshore oil and gas facility.

  • Currently involved in defending a major petrochemical facility from a Clean Air Act citizen suit.

  • Provide legal and regulatory advice to Gulf of Mexico operator on a number of environmental issues including NPDES General Permit compliance, air pollution control requirements applicable to offshore facilities, and applicability of MARPOL requirements.

  • Provide advice to terminal facility on applicability of RCRA hazardous waste requirements to their wastewater storage and treatment tanks.

Involvement

Professional

  • Houston Bar Association (Board Member 2014-2016, Section of Environmental Law)

  • State Bar of Texas (Member, Section of Environmental and Natural Resources)

Presentations

  • “Fracking Update for Louisiana and Texas,” 2015 Energy Law Seminar, Liskow & Lewis, Houston, Texas, November 2015 

  • "Current Air Issues: Onshore Oil and Gas Production," Legal Issues in Oil and Gas Production, HalfMoon Seminars, Houston, Texas, April 2011

Publications

After Hours

“I have family in Puerto Rico, so I enjoy visiting them. My daughter and I spend a lot of time together, and we love to try new restaurants. In my spare time I read and watch sports.”

News/Insights