J. Mark Landrum, Pe

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J. MARK LANDRUM, P.E.

Education:

Master’s in Business Administration in Finance - University of Texas at Dallas – 1992 Bachelor of Science in Chemical Engineering - Texas A&M University (summa cum laude) - 1979

Licenses and Certifications:

Registered Professional Engineer, State of Texas, #78584

Professional Affiliations:

American Institute of Chemical Engineers (AICHE) Houston Gas Processors Association (HGPA) Marine Technology Society (MTS) Houston Section Rice Global Engineering & Construction Forum

Professional Experience

Mark Landrum has over 40 years of experience in the US and abroad in plant operations, project management, project engineering, construction management, process/facilities engineering, process technology licensing, and oil & gas facility commissioning. His expertise includes technical safety and loss control engineering, process engineering for processing facilities, pipeline transportation of oil and gas, topsides process and utility systems for fixed offshore platforms and floating production systems, natural gas processing and treating, material handling processes, and synthesis gas conversion technologies. He has related experience in natural gas liquefaction, crude oil and refined products, gas-to-liquids (GTL), coal-to- liquids (CTL), power/ cogeneration, renewable fuels, processing/treating, syngas conversion, underground gas storage, catalyst metals recovery, supply chain logistics, and petrochemicals production. Mr. Landrum’s consulting engagements for clients have involved accident investigations, root cause analyses, feasibility studies, technology assessments, market analyses, project evaluations, contract audits, due diligence reviews for oil and gas asset acquisitions, field development and optimization studies, and construction disputes. Mr. Landrum has served as lead technical expert with claims amounts ranging from $250,000 to over $200 million. Mr. Landrum previously has been a partner or principal at four consulting firms. Prior to his work with Synergen Consulting, Mr. Landrum also managed a small exploration and production enterprise called Syntroleum Gas Resources Company. While at the parent firm, Syntroleum Corporation, he worked to commercialize advanced gas processing technologies as both a lead process engineer and business development manager on offshore floating production systems and onshore projects with emphasis on gas monetization and associated natural gas flaring reduction. Earlier in his career, Mr. Landrum worked for several oil and gas production and transportation companies, including affiliates of Delhi Gas Pipeline and Sun Oil Company. His operations experience includes CO2 removal/injection at a large enhanced oil recovery project in West Texas. Mr. Landrum has testified in courts in the U.S. and Canada, as well as US and international arbitration proceedings. Mr. Landrum holds a Bachelor of Science degree in Chemical Engineering from Texas A&M University and a Master’s in Business Administration from the University of Texas at Dallas.

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Synergen Consulting International, LLC 2010-Present Senior Consultant Houston, Texas

• Provides construction, engineering, and project management services • Performs project assessments and studies for industry standards compliance and methodologies • Manages construction disputes and performs claims evaluation for owners, contractors and subcontractors • Conducts project evaluations, assessments and forensic investigations • Performs due diligence reviews and assists with contractual negotiations and audits • Provides assistance and solutions for engineering, design, construction, installation, operations and management of various facilities

Trident Risk Management, LLC 2009-Present Founder, Chairman Houston, Texas

• Founder and Chairman of a technical safety engineering and loss prevention consulting practice specializing in quantitative risk assessments (QRAs), fire and explosion risk analysis (FERA), toxic gas dispersion modeling, RAM studies, and on-site health, safety and environmental (HSE) advisory services during the engineering, design, fabrication, installation, hookup and commissioning phases of offshore fixed platform, floating production system and subsea tieback projects. • Leads HAZOP/LOPA/SIL verification studies and workshops and provides external audits of Safety and Environmental Management Systems (SEMS) programs, Process Safety Management (PSM) plans, and process hazards analyses (PHA) for owners and operators.

James Square Energy Advisors LLC 2009-Present Co-Founder, President Houston, Texas

• Co-founder and President of a firm providing engineering and construction contract dispute analysis and resolution, litigation/arbitration support, and expert testimony as well as technical and contract due diligence related to oil & gas mergers and acquisitions in the upstream and midstream sectors. • Provides claims prevention services, project and construction management consulting services, project engineering, quantity surveying, schedule risk analysis, and document control services.

Exponent, Inc. 2007-2009 Leader of Houston Energy Team, Engineering Management Consulting Houston, Texas

• Responsible for building and managing a group of professionals in Houston providing proactive project and business consulting services including environmental and safety risks assessments of refinery expansions, technical and economic feasibility studies for proposed petrochemical, refinery and terminal projects, and external audits of natural gas distribution company operations for senior executives and board committees. • Grew the practice to six full-time consulting experts focusing on risk and opportunity analysis, including the risk of natural hazards to offshore facilities in the Gulf of Mexico from tropical storms and hurricanes (wind and surge).

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Baker & O'Brien, Inc. 2005-2007 Senior Consultant Houston, Texas

• Provided fire/explosion insurance services, physical asset appraisals, and analyses of property damage and business interruption claims and reconstruction costs • Provided an expert report on the losses incurred by the owner of a refinery spent resid catalyst processing facility resulting from a covered fire event

Syntroleum Gas Resources Company 2004-2005 Vice President – Operations Tulsa, Oklahoma

• Responsible for technical management, project planning and execution, engineering and construction contractor supervision, permitting, cost estimating, economic analyses, cost and schedule control, procurement, technology partnerships and management reporting for Syntroleum Corporation’s E&P subsidiary focused on drilling and production lease operations in regions with unconventional gas resources • Reporting directly to Syntroleum’s CEO, worked on unconventional gas projects in the U.S. applying advanced gas processing technologies to upgrade sub-quality natural gas to meet pipeline sales specifications

Syntroleum Corporation 1998-2005 Vice President – Business Development Tulsa, Oklahoma Lead Process Engineer

• Managed the work of engineering contractors on the scale-up of Syntroleum’s proprietary gas-to- liquids (GTL) process from the pilot plant stage to demonstration scale, and from small scale to larger commercial scale plants, including floating GTL production systems • Designed and optimized pilot and demonstration-scale units and testing involving proprietary autothermal reforming, FT synthesis and mild hydrocracking processes and low Btu combustor designs for gas turbines • Developed and evaluated improvements to catalyst productivity and the carbon efficiency of the Syntroleum GTL process • Worked on the design of Syntroleum’s GTL demonstration units at the Cherry Point, Washington refinery and on a site at the Port of Catoosa • Completed detailed engineering of the A$600 million Sweetwater GTL Project on the Burrup Peninsula of Western Australia that was designed to produce 11,000 barrels per day (B/D) of synthetic lubricating base oils and other specialty FT products, and on the development of Syntroleum’s mild hydrocracking technology • Negotiated process technology licenses and led technical and economic feasibility studies for stranded gas utilization projects using Syntroleum’s GTL technology in many parts of the world • Responsible for developing staffing, training, operating and maintenance plans for use in new co- production/poly-generation facilities generating electric power and producing synthetic liquid fuels • Managed relationships with government ministers in Perth and Canberra, Australia in the time period after the development phase of the Sweetwater GTL Project development • Negotiated a joint project development contract with the research arm of Gazprom for a preliminary investment analysis of 10 possible locations for GTL plants in Russia

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J. Mark Landrum & Associates, d/b/a Energy Resources 1995-1998 Owner / Principal Dallas, Texas Cambridge, Ohio

• Worked on all aspects of the detailed engineering and design, including configuration and programming of the dual language distributed process control system, and served as on-site Commissioning Manager for the start-up of catalytic reforming and naphtha hydro-treating units at a refinery in the Ukraine • Acted as an independent yield consultant to the Export-Import Bank of the U.S. regarding several refinery modernization projects in Russia • Provided operations optimization services to producers and midstream gathers and processors in Australia, Louisiana, New Mexico and Texas, and engineering services to an underground gas storage (UGS) facility operator in Hungary and UGS project development groups in the U.S. • Senior technical advisor to an Ohio-based engineering firm on gas measurement, compressor station, and gas processing projects in Kazakhstan, Uzbekistan and Turkmenistan • Negotiated a process technology licensing agreement for a polymer project in Russia • Provided expert technical advice on matters involving refinery utility systems, operations of gas plants, NGL fractionators and terminals, and natural gas contracts

Muse, Stancil & Co. 1989-1995 Vice President / Director/ Partner Dallas, Texas

• Worked with various clients on the acquisition of oil and gas assets. These projects included technical, environmental and contract “due diligence” reviews of the assets, preparation of financing models, and the negotiation of agreements to effect the transactions. Examples included the purchase by the Southern Ute Indian tribe of gas gathering, compression, treating and pipeline assets from Public Service of Colorado and the acquisition of the Cities Service NGL division by Hicks, Muse, Tate & Furst into what became Trident NGL • Directed audits of natural gas purchase and processing contracts and developed refinery linear programming models. • Evaluated refinery upgrading projects, crude oil and products markets, and natural gas and petroleum coke-fueled cogeneration facilities for project owners and lenders

Sun Exploration & Production Company 1984-1989 District Gas Engineer / Project Manager Abilene, Texas

• Involved in well production, water injection and pipeline operations in West Texas, and served as Project Manager while based in Dallas for the design, construction and start-up of modular gas plants in Michigan and Texas. • Led teams that conducted safety audits at company facilities around the U.S.

Sun Gas Transmission Company 1982-1984 Senior Project Engineer Dallas, Texas

• Managing pipeline, compressor station and condensate stabilization unit construction projects in Texas, Oklahoma and Louisiana • Managed the gas gathering and processing operations in the Snyder Gas Plant complex (part of the SACROC Unit now operated by Kinder Morgan) in Scurry County and surrounding counties in West Texas

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Texas Oil & Gas Corporation / Delhi Gas Pipeline Co. 1981-1982 Process Engineer Dallas, Texas

• Responsible for process design, flow sheet preparation, equipment specifications, and bid evaluations on modular gas compression and conditioning units • Managed the installation and commissioning of new gas processing plants in Oklahoma and a sour gas treating facility in Arkansas

Sun Gas Company 1979-1981 Senior Gas Engineer Lafayette, Louisiana

• Responsible for optimizing the NGL extraction operations in five existing gas plants in Louisiana using the refrigeration and refrigerated lean oil processes, and assisted with the start-up of a cryogenic nitrogen rejection unit (NRU) in South Louisiana and an amine acid gas treatment unit handling lease production in southern Mississippi • Managed a project to relocate to and refurbish a modular gas plant and compressors at a site near English Bayou in Calcasieu Parish, Louisiana

Selected Representative Project Experience: • Refinery Fire Incident, Louisiana – Testified as an expert on the causes and sequence of events which led to a pool fire following a loss of primary containment incident resulting in extensive property damage to a crude oil distillation unit in a joint-venture refinery in South Louisiana.

• Post-Construction Disputes, Houston Ship Channel – Engaged as a technical expert on a variety of claims issues involving the engineering standard of care and duties of the engineer to the Owner, fabrication quality assurance/quality control (QA/QC), completeness of packaged equipment, and plant automation and safety shutdown systems on behalf of the Construction Contractor on a Steam Methane Reformer (SMR) Hydrogen Plant and on a separate matter, the Owner of a Propane Dehydrogenation (PDH) plant.

• FPSO Topsides Process Module Design and Operations, Offshore Africa – Testified as a facilities engineering expert in federal court on behalf of a gas compressor supplier in a matter involving the design and operations of packaged equipment modules installed on the deck of a floating production, storage and offloading (FPSO) vessel handling the production from an oilfield offshore Mauritania.

• Grassroots Petrochemical Complex Feasibility Study, Kuwait – Led a technical and economic feasibility study for an investment group, including the Industrial Bank of Kuwait, of a proposed project to build a purified terephthalic acid (PTA) and bottle-grade polyethylene terephthalate (PET) plant near the Port of Shuaiba.

• Subsea Tie-back Feasibility Study, Deepwater Gulf of Mexico – Evaluated riser options and required modifications to topsides process modules and utilities for the operator of an existing floating production system with the opportunity to serve as a ‘host facility’ and process / handle production from third-party wells on adjoining blocks.

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Representative Project Experience (continued): • Topsides Process Module Fabrication, Malaysia – Analyzed design changes and assembly delays in the engineering and fabrication of the topsides process and utility system modules for an FPSO contracted to Petrobras in the Espadarte Sul field in the Campos basin offshore Brazil. Provided expert testimony in the international arbitration resulting from a construction dispute on the topsides modules and equipment.

• Safety and Environmental Risk Assessment, Venezuela – Performed an assessment of safety and health hazards to workers and the general public, and potential for damage to the environment, on behalf of PDVSA in connection with a heavy crude oil upgrading project at the Puerto la Cruz refinery.

• Methanol Pipeline Operations, Texas – Deposed as an expert on the operations, maintenance and inspection of a pipeline that transfers methanol from a petrochemical manufacturing plant to storage tanks in a terminal in connection with a litigation matter involving external damage to the line.

• Renewable Natural Gas Facilities, Texas and California – On behalf of the bondholders, recommended design modifications and changes in operating procedures in order to attain the minimum performance levels in facilities using anaerobic digesters to produce pipeline quality natural gas from dairy cattle manure.

• Fuel Grade Ethanol Plant Litigation, New York – Performed an engineering analysis of alleged design flaws in a corn-based biofuels manufacturing facility for the attorneys retained by the EPC Contractor.

• Biodiesel Plant Arbitration, Pennsylvania – Testified at arbitration as a technical expert on issues related to deficiencies in the engineering, design and construction of a renewable fuels facility producing biodiesel from soybean oil and used cooking oil.

• Co-Generation Project, Russia – Engaged by the project sponsor as Independent Engineer to conduct technical due diligence on behalf of the financial advisor, BNP Paribas, related to bridge financing for a gas turbine combined-cycle power station and district heating project in West Siberia. • Grassroots Crude Oil Refinery Utility Island, South Dakota – Coordinated a technology assessment and a reliability, availability and maintainability (RAM) study for a petcoke IGCC unit as part of a proposed 450,000 barrels per day grassroots refinery being developed by an investment group. The utility island would gasify 7,400 tons per day of petroleum coke from delayed coking units and return purity hydrogen, electric power and steam to the refinery.

• Gas Plant Equipment Failure Analysis, Canada – Rendered an expert opinion in a litigation matter involving loss of marketable hydrocarbon liquids production due to operating upsets and corrosion damage in an amine acid gas treating unit in a natural gas processing plant in Alberta.

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Representative Project Experience (continued): • Technical Review of Hurricane-Related Property Damage Claims, Louisiana – Assisted the adjuster in a review of insurance claims data submitted by Entergy related to property damage suffered by the electric utility and local gas distribution company as a result of Hurricanes Katrina and Rita.

• Economic Feasibility Studies, Middle East – Directed teams analyzing proposed projects to utilize GTL technology to co-produce synthetic liquid fuels, electricity, and desalinated water from stranded natural gas resources.

• Preliminary Investment Analyses, Russia – Assessed prospective locations for reducing associated gas flaring, extracting NGL and producing synthetic liquid fuels using GTL technology for private oil companies and the state-owned natural gas company, Gazprom.

• LNG Supply-Demand Study, United States – Analyzed the future competitive price structure and demand for LNG delivered to receiving and regasification terminals in the U.S.

• Underground Gas Storage Facility, Hungary – Advised MOL on the expansion of surface plant and equipment, including flow measurement for an underground gas storage facility.

• Operations Optimization Review, South Australia – Recommended ways to improve reliability and reduce costs, and best undertake a capacity expansion, for Benfield and amine gas treating units and cryogenic liquids extraction facilities at the Santos-operated Moomba Plant in the Cooper Basin.

• Gas Gathering Business Acquisition, Colorado – Advised a partnership comprised of an Indian tribe and a major investment group in the successful purchase of the stock of the gas gathering subsidiary of a Colorado public utility. The company formed provides gathering and treating services to producers of coal seam and conventional gas reserves in the San Juan Basin.

• Audit of Gas Purchase Agreements, Texas - Determined the proper monthly heat content reduction on wellhead gas deliveries over a period of several years attributable to third-party compression, gathering, and processing facility operations in Southeast Texas for a utility’s fuel purchasing arm. The audit resulted in a $65 million settlement in favor of the client. • Gas Processing Agreement Audit, Texas – Evaluated the accounting procedures utilized by a gas plant operator processing a major producer’s gas, with deliveries averaging over 200 million standard cubic feet per day, to ensure that settlement was being made in accordance with the contract terms. Calculated the value of the adjustments required to retroactively correct for systemic errors discovered, and negotiated the terms of a resolution between the parties.

• Gas Treating Plant Incident, Texas – Rendered an opinion on safety standards, industry best practices, and the sequence of events surrounding an operational upset at an acid gas removal facility in connection with a personal injury lawsuit. A failure to properly maintain analyzers resulted in the delivery from the gas treating plant, during the period of the upset, of gas containing excessive quantities of hydrogen sulfide (H2S) into a local gas distribution network.

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Project Experience – By Industry Sector:

Oil & Gas Production Facilities

Project Description

• FPSO, West Africa – Testified in U.S. federal court as a facilities engineering expert on behalf of a gas compressor manufacturer in a matter involving the design and operations of packaged equipment modules installed on the deck of a floating production, storage and offloading (FPSO) vessel handling the production from an oilfield offshore West Africa. Reviewed documents generated by the FPSO owner, the topsides detail engineering contractor, the compressor packager, and the supplier of the reciprocating compressor frame, cylinders and lubrication system. Analyzed the design of the oil and gas production handling and gas flaring systems, data on the installed instrumentation for liquid level and pressure control, commissioning reports, operator log sheets, and reports by the offshore installation managers (OIMs) and engineers for the various parties to reach conclusions on factors that contributed to compressor rod and rod packing failures resulting in extended gas flaring events and the assessment of liquidated damages and penalties against the owner of the FPSO by the field operator and the government of Mauritania.

• FPSO, Brazil – Analysis of engineering and design changes impacting the assembly process during the fabrication of topsides process and utility system modules for a floating production, storage and offloading vessel (FPSO) contracted to Petrobras for handling oil and gas production from the Espadarte Sul field in the Campos basin offshore Brazil. Directed the preparation of presentation graphics depicting the results of the delay analysis including affected work sequencing in the fabrication yard in Malaysia. Provided expert testimony in the international arbitration resulting from a dispute between the owners of the FPSO and the fabrication yard involving delays in shipping topsides equipment and modules to Singapore for mounting on the vessel deck.

• Processing Facility, South Texas – Provided project management and project/process engineering services on a contract basis to the EPCM contractor on the expansion of a central processing facility in the Eagle Ford Shale region of South Texas. The facility was being expanded to handle over 25,000 barrels of oil per day (BOPD), up to 85 million standard cubic feet per day (MMSCFD) of associated gas, and 7,000 barrels of produced water per day (BWPD) from 28 horizontal wells, 17 of which had recently been drilled and hydraulically fractured. Managed the preparation of a project schedule in collaboration with the owner’s construction group, and developed project control procedures. Finished the process design including the P&IDs and safety flow diagrams. Oversaw the development of computer graphics for facility layout and piping design, and the shop fabrication of piping spools following piping isometric drawing generation. Prepared the commissioning plan for review by the owner’s facilities engineers and operating staff to resume operations at the existing wells and commence full well stream production from the new wells through new high-pressure flowlines.

• FPS, Gulf of Mexico – On behalf of the owner/operator, performed a subsea tieback feasibility study for an existing floating production system (FPS) in the deepwater Gulf of Mexico. Evaluated riser options and required modifications to topsides process modules and utilities on the tension leg platform (TLP) in conjunction with the opportunity to serve as a ‘host facility’ and handle oil & gas production from third-party discoveries on adjoining blocks.

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Petrochemical Complexes, Oil Refineries, and Gas Processing Plants

Project Description

• Crude Oil Refinery – On behalf of the EPCM contractor, evaluated the claims of the Operator of crude fractionation units, a depropanizer, a sour water stripper, and various utility systems related to alleged design deficiencies relating to product quality and yield when processing off-specification crude feed. Among the issues considered were guaranteed performance criteria, crude assays as a basis for design of a refinery, mechanical warranty claims, use of H2S scavengers, corrosion and fouling in refinery equipment, and best practices in refinery operations.

• LPG Storage Facility, Ohio – Assessed whether the engineering standard of care was met by a detailed engineering contractor responsible for facility layout and piping design in a refrigerated liquefied petroleum gases (LPG) storage facility in the Utica Shale play in eastern Ohio, including a review of the relevant contracts, Requests for Information (RFIs) submitted by the shop fabricator and the field construction contractor, piping isometric drawings (ISO’s), and approved change orders.

• Ethylene Cracking Heating Project – Advised an owner during the pre-execution phase of an ethylene cracking heater project to identify design, material supply and construction risks, opportunities and exposures, and to formulate a risk management strategy to prevent delays, control costs and mitigate the potential effects of disruptions to the project. Reviewed and commented on the Request for Proposal (RFP) and, after a preliminary bid evaluation was completed by owner, reviewed the preferred contractor’s commercial and technical proposals. During negotiation of the final agreement for engineering and supply of the ethylene cracking furnace addition to the company’s olefin production operations, recommended changes and clarifications to the contract language relating to rights to improvements in the licensed process, the extent of technical information and know-how being transferred, the scope of work and supply, responsibility for correcting errors and omissions, pre-commissioning and start-up support, payment of import duties, project control procedures, change order management, and acceptance testing.

• Steam Methane Reformer, Texas – Analysis of a number of issues related to a construction contractor’s claims against the owner of a grassroots hydrogen plant based on steam methane reformer (SMR) technology located in Pasadena, Texas including the completeness of fully- engineered and dimensioned, approved for construction (AFC) drawings; the level of oversight and coordination by owner of the work of detailed engineering and design contractors; the adequacy of dynamic modeling and structural steel reinforcement for the “tabletop” concrete foundation for a steam turbine-generator (STG) package; discontinuities in piperack interfaces at the boundaries between plant areas that were designed by different firms; deficiencies in high pressure steam piping design and fabricator certifications requiring field engineering and corrections; the specification and procurement of piping specialty items; provisions for a temporary source of steam for an initial “steam blow” during preparations for STG start-up; the impacts on cost and schedule of design changes during construction to correct defects and deficiencies in detailed engineering and on owner-supplied equipment packages; and the number, substance and timing of RFIs from the field. The scope of work included deposition support and the preparation of a Certificate of Merit regarding the engineering standard of care.

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• LNG Terminal, US East Coast - Managed the Process Hazards Analysis (PHA) review of hazards to personnel, the general public and the environment for Dominion Gas Transmission’s US$3.8 billion Cove Point LNG Terminal Liquefaction Expansion Project on the U.S. East Coast. PHAs were conducted using the Hazard and Operability Study (HAZOP) methodology for all process sections in the APCI proprietary technology process cycle for land-based LNG production, and for the entire new feed gas treatment facilities and Power Block plus the modified utility systems at the LNG terminal, during the detailed engineering phase for the new liquefaction facilities. Project economic risks (extended downtime and significant financial exposure) as well as reputational risks to the owner were also considered in the HAZOP. A risk ranking was performed and the highly-ranked risks (cause- consequence pairs) were subjected to further evaluation in a Layer of Protection Analysis (LOPA) that considered administrative controls, operator response/intervention, and the configuration of the plantwide distributed control system (DCS). In addition, safety integrity level (SIL) verification workshops were held for the Safety Instrumented System (SIS). Vendor packaged equipment HAZOP/LOPA workshops were performed as vendor data and drawings were received by the project team. Action items that were the responsibility of the EPC contractor were tracked to resolution. Earlier, led the vapor dispersion modeling studies to screen for credible release (loss of containment) scenarios that could impact the surrounding communities near Lusby, Maryland on Chesapeake Bay to support the owner’s permit application to the U.S. Federal Energy Regulatory Commission (FERC) as lead agency and to the U.S Coast Guard. Construction on the LNG export facilities commenced in October 2014.

• Propane Dehydrogenation Plant - On behalf of the owner, performed an assessment of EPC contractor performance related to inspections in overseas fabrication shops, the effectiveness of the main reactor manufacturer’s quality assurance/quality control (QA/QC) program, the completeness of packaged equipment and plant automation and safety shutdown systems, the adequacy of the design of burner management systems on a charge furnace and switching valves on the exhaust of a gas turbine, suitability of material selections for severe service conditions anticipated during process unit start-up, the impact on schedule and construction costs of improper nozzle orientations on delivered pressure vessel equipment, and the duty of the engineer to the owner on a world-scale Propane Dehydrogenation plant project. Dispute resolved prior to trial.

• Chlor-alkali Project, Louisiana- On behalf of a petrochemical concern’s senior management, conducted an assessment of project risks associated with a proposed chlor-alkali project in South Louisiana. The owner wanted to make a corporate decision regarding a strategic investment in chlorine production as feedstock for its polyvinyl chloride (PVC) manufacturing operations so as to offset merchant market purchases. Assessed internal and external risks to the company that could arise if the project went forward using the ion exchange membrane process for producing chlorine gas and caustic soda. The internal risks assessed qualitatively related to technology risk, completion/schedule risk, management risk, and environmental and safety risks. Among the external risks evaluated were currency risk associated with purchase of a technology license, detail design services and proprietary equipment from Asian suppliers; construction market risk related to demand for PVC products, in particular PVC pipe, in the U.S.; commodity market risk that could arise if the owner was forced to make short-term chlorine purchases because of delays in bringing the chlor-alkali project online; feedstock supply risk corresponding to brine transport and supply security; and infrastructure risk related to the availability of third party terminal storage capacity for byproduct caustic material.

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• PTA and PET Manufacturing Plant, Kuwait - Analysis of the technical and economic feasibility of a grassroots petrochemical complex for the project developer, an investment group including the Industrial Bank of Kuwait, to be located on a site near the port in the Shuaiba Industrial Area. The project developer was proposing to build a world-scale purified terephthalic acid (PTA) plant for internal consumption and the merchant market and bottle-grade polyethylene terephthalate (PET) manufacturing facilities. The feasibility study work included an assessment of available process technologies for the production of PTA and PET, development of a financing (economic) model for the project, a preliminary cost estimate and schedule.

• Gas Processing Complex, Oklahoma - After initially facilitating the HAZOP/LOPA workshops for the expansion of a gas processing complex in the Woodford Shale area of Oklahoma, was contracted by the owner to become the Project Manager for the US$230 million expansion project after a tornado struck the original plant and the owner’s project and facilities engineers were needed for the reconstruction effort. Managed two engineering contractors performing design work for integration of the new process and compressor units including a new NGL extraction train during the project definition and detail engineering phases. In addition, managed the re-design and re- configuration of the new NGL extraction train by the process module fabricator to match the expected raw gas composition from the field. Assisted the owner’s supply chain manager in negotiating detail engineering, procurement and fabrication contracts, and the cost reimbursable plus fee at risk construction contract with the general contractor. Recruited and assembled a team of people to support the owner’s construction manager during the gas plant construction phase including on-site job cost analysts, quantity surveyor, QA/QC inspector, schedule analyst, document control specialists, and safety advisors.

• Gas Processing Complex, Ohio - On behalf of the owner, assessed construction contractor performance on a grassroots gas processing complex project in the Utica Shale region in eastern Ohio. The project was well behind schedule and significantly over budget. Inspected the construction progress at the site; met with the union construction contractor’s home office and site management personnel to discuss the labor contract with the local shop; reviewed the cost reimbursable plus fixed fee contract signed by the owner and contractor and the log of project scope changes; and analyzed project cost data and the work remaining to reach mechanical completion. Developed and presented recommendations to the owner’s chief operating officer to accelerate the work while minimizing the cost to complete and commission the facilities. Implemented a plan to more closely monitor project costs and track construction progress and labor productivity.

• Oil Refinery, Venezuela - Analysis of risks to workers, the environment and the community near an oil refinery in Venezuela. Managed a safety and environmental risk assessment for the EPC contractor on behalf of the owner in connection with a heavy crude oil upgrading project. The project entailed the addition of new facilities and infrastructure within the refinery boundary including a hydrogen plant and a heavy crude oil cracking process unit using PDVSA’s HDH Plus® technology. Performed consequence modeling and provided a report to refinery and project management.

• Oil Refinery, Louisiana - Forensic analysis of a fire incident in an oil refinery in Louisiana on behalf of an insurance company that provided liability coverage to a contractor alleged to have removed a small-bore valve and blind in error while working for the refinery owner on a demolition project. Investigated the root cause of the incident initiated by maintenance work during start-up following a turnaround that resulted in a release of off-specification naphtha and kerosene products and a subsequent pool fire in a crude oil distillation unit. Testified as an expert on the causes and sequence of events that led to the fire following the loss of primary containment. Extensive property damage in excess of US$15 million was sustained in the crude distillation unit and adjacent facilities.

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• Gas Plant, Saudi Arabia - On behalf of the owner, assisted with the analysis of delays to mechanical completion and substantial completion and increased costs associated with an EPC contractor’s $138 million claim on a gas plant project in Saudi Arabia. The work involved travel to the Kingdom to organize project files and documents related to the contractor’s baseline and schedule updates, and to begin developing a chronological database. Assessed impacts allegedly due to change orders, welding defects, late drawing deliveries by the owner, and contractor performance problems. Assisted the international law firm representing the owner with witness statements and document disclosure requests. Began an evaluation of the EPC contractor’s project radiography records and weld maps associated with rejected pipe joint welds as compared to the results that were developed from the owner’s welding and non-destructive testing expert’s interpretation of the films. The dispute was resolved prior to arbitration.

• Cryogenic Gas Processing Plants, USA - Analysis of a number of issues related to the engineering on two large cryogenic gas processing plants, both owned by the same midstream company and each with a capacity of over 750 MMSCFD. One of the plants is located in the Piceance Basin in western Colorado and the other is near Opal, Wyoming. The detail engineering and procurement for both projects was executed in sequence by the same contractor. Reviewed the expert reports prepared at the owner’s request and the claims by owner against the contractor totaling over US$200 million. Evaluated in detail the effects of late delivery of vendor data and drawings for owner-supplied equipment on engineering progress, including plant layout and 3D model development, and the production of piping isometric drawings for shop fabrication of piping spools. Assessed the impact of contemporaneous sources of delay in the construction and mechanical completion of the projects including the establishment of man camps for construction in the remote locations, the lack of qualified craft labor in the Rocky Mountains region available to the general contractor, and late delivery of owner-supplied equipment. Prepared expert reports describing the conclusions reached. The case settled for an amount equivalent to around US$16 million.

• Petrochemical Complex - Assessment of loss of production income and costs to repair equipment damage resulting from an unscheduled outage of utility power for the owner of a petrochemical complex manufacturing acrylonitrile (AN) and hydrogen cyanide among other specialty products. The power outage caused critical devices to shut down in the AN units and led to an auxiliary boiler tube failure. Provided deposition support and the case was settled with a cash payment to the owner.

• Propane-propylene Splitter Project, Texas - Rendered an opinion on the proper installation of tower internals in propane-propylene splitter columns on behalf of the EPC contractor. An internal inspection of the erected towers revealed numerous loose or missing nuts on the fractionation trays indicating that the clamp and bolt assemblies had not been properly torqued at the fabrication shop. An expert for the vessel manufacturer postulated that transportation of the splitter columns caused the nuts to loosen and come off, so a transportation experiment was devised to test the hypothesis that vibration transmission from the road surface during delivery of the columns with trays inside from the yard to the PDH plant site in Mont Belvieu, Texas causes actual bolt assemblies to come loose. In the first phase of the experiment, field data was collected along the transportation route, followed by a second phase of laboratory testing on an electro-dynamic shaker table. Provided deposition testimony on two occasions. The case settled before going to trial.

• Investment Project - Advised a partnership comprised of an Indian tribe and a major investment group in the successful US$60 million purchase of the stock of the gas gathering subsidiary of a Colorado public utility. The company formed provides gathering and treating services to producers of coal seam and conventional gas reserves in the San Juan Basin.

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• Due Diligence Project, Pennsylvania - Analysis of records including well permits and drilling/completion reports, regulatory reports and filings with the Pennsylvania Department of Environmental Protection (DEP) as part of the technical and environmental due diligence performed in connection with an acquisition of working interests in leases in the Marcellus Shale region. Inspected well pad site surface facilities and lined water impoundments, and the gas gathering, compression and measurement facilities that handle gas production from the wells. Led a team of engineers and environmental specialists in a review of documents on behalf of the company, the non-regulated subsidiary of a gas utility, making the acquisition of a working interest in existing Marcellus Shale and Oriskany sandstone production and future drilling locations in Tioga County, Pennsylvania.

• Pipeline System, Peru - Served as Independent Engineer for the Inter-American Development Bank (IADB) monitoring operations of the Camisea Pipeline System in Perú over a two-year time span. During this period, Transportadora de gas del Perú (TgP) completed a $300 million expansion, funded by lenders, of its gas pipeline from the Amazon region over the mountains in order to increase deliveries to the city of Lima, provide gas to fuel power plants, and supply feed gas to a new gas liquefaction plant. Reviewed design documents and cost estimates for pipeline loops and a new compressor station in the Andes Mountains. Provided reports to the bank on these projects and on the right-of-way soil stabilization and pipeline integrity management program. Periodically traveled to Perú to inspect the expansion facilities during the building activity, including construction on the Peru LNG export project, which also was funded by a loan from IADB. He also reviewed plans and budgets for several debottlenecking projects completed by TgP at pumping stations on the separate NGL pipeline terminating at the Pisco NGL fractionator on the Pacific coast.

• Methanol Pipeline, Texas - Deposed as an expert on the operations, maintenance and inspection of a pipeline that transfers methanol between a petrochemical manufacturing plant on the Texas Gulf Coast and storage tanks in a nearby terminal in connection with a litigation matter involving external damage to the line.

• Crude Oil Refinery, USA - On behalf of the developer, performed a technology assessment and reliability, availability and maintainability (RAM) study for a utility island in a proposed 450,000 barrels per day grassroots crude oil refinery in the U.S. The utility island consisted of an integrated gasification combined cycle (IGCC) unit that would gasify petroleum coke from the refinery’s delayed coking units and would return purity hydrogen, electric power and steam to various process units.

• Amine Acid Gas Treating Project - Analysis of gas plant equipment failures involving operating upsets and corrosion damage in an amine acid gas treating unit. Prepared a damages report for the owner regarding gas plant balances and the loss of marketable hydrocarbon products. Provided expert opinion in the litigation matter related to the engineering, design, operations and maintenance of gas plants. Testified in the bench trial in Alberta on the pertinent technical issues.

• Loading Terminal, Texas - Assessment of risks to personnel in occupied buildings in an oil truck loading terminal in the Eagle Ford Shale area of South Texas. The terminal facility also stabilizes condensate and handles significant quantities of LPG. Coordinated vapor dispersion modeling and explosion studies related to credible release scenarios of flammable gas and liquids to estimate blast loads on temporary construction trailers, a guard house and a permanent office building.

• Investment Studies, Russia - Led preliminary investment analyses of prospective locations in Russia for plants to reduce associated gas flaring, extract NGL, and produce synthetic distillate fuels using GTL technology for both private companies and the state-owned natural gas company, Gazprom.

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• Gas Plant and Storage Facility, Hungary - On behalf of the owner, performed a study covering the expansion of surface plant and equipment including flow measurement equipment for an underground gas storage facility in Hungary.

• Amine Gas and Cryogenic Facilities, Australia - Analysis of operations at Benfield hot potassium carbonate and amine gas treating units and cryogenic NGL extraction facilities in the Cooper Basin of Australia. Recommended ways to for the owner to optimize operations, improve reliability and reduce costs, and provided recommendations on the best approach for debottlenecking the facilities and undertaking a proposed capacity expansion.

• Processing Facility Audit, Texas - On behalf of a utility’s fuel purchasing arm, analyzed the heat content reduction on wellhead gas deliveries over a period of several years attributable to a midstream service company’s compression, pipeline gathering and processing facility operations in Southeast Texas. The audit work resulted in a US$65 million settlement in favor of the client.

• Gas Plant Accounting Project - Evaluation of accounting procedures utilized by a gas plant owner processing a major producer’s gas with deliveries of over 200 MMSCFD to ensure that settlement was being made in accordance with the contract terms. Calculated the value of adjustments required to retroactively correct for systemic errors discovered, and negotiated the terms of a resolution between the parties.

• Acid Gas Removal Facility, Texas - Rendered an opinion on safety standards, industry best practices, and the sequence of events surrounding an operational upset at an acid gas removal facility in Texas in connection with a personal injury lawsuit. A failure to properly maintain online analyzers prior to the upset resulted in the delivery from the gas treating plant of natural gas containing excessive quantities of H2S into a local gas distribution network.

Fertilizer Plants and Ammonia Plants:

Project Description

• GTL Plant – Lead Process Engineer on the basic engineering of a large-scale grassroots Syngas Conversion (GTL) plant using Haldor-Topsoe autothermal reforming (ATR) technology.

• Urea-Ammonium Nitrate Plant, Poland – Worked on a feasibility study for a proposed Urea- Ammonium Nitrate manufacturing plant in Poland using Uhde Ammonia Synthesis and Urea Synthesis technologies.

• CTL plant, Australia – Advised the developer of a coal-to-liquid (“CTL”) project producing nitrogen fertilizers in the State of Victoria in Australia.

• Methanol Facility - Developed process design and cost estimates for converting an idle methanol manufacturing facility into a GTL plant including steam reforming, shift reaction, CO2 removal, and syngas conversion (Fischer-Tropsch synthesis) units.

• Methanol Plant, Equitorial Guinea – Provided consulting engineering services to Atlantic Methanol Production Company (AMPCO) related to the investigation steam turbine-driven syngas compressor failures at the Equitorial Guinea plant.

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Testifying Experience (2005-Present):

• Deposition - Criterion Catalysts vs. Ace Insurance - Value of assets damaged by a fire in a spent catalyst metals recovery plant.

• Testimony at Trial/Arbitration - Canadian 88 Energy vs. Union Carbide - Engineering, design, operations and maintenance of natural gas plant.

• Black & Veatch Pritchard vs. Saudi Aramco - Engineering analysis of EPC contractor’s claims on Shedgum Gas Plant expansion.

• Deposition - Celanese Corp. vs. Coastal Water Authority - Operation & maintenance of methanol pipeline.

• Testimony at Trial/Arbitration - Modec International vs. Sime Darby Engineering - Engineering analysis of delay claims on topsides modules for an FPSO.

• Testimony at Trial/Arbitration - Alstom vs. Insigma Technology - Flue Gas Desulfurization (FGD) spray tower absorber design and validity of patents scheduled in license agreement.

• Lurgi PSI vs. Northeast Biofuels - Review of design flaws in a corn-based, fuel grade ethanol plant.

• Enterprise Products Operating, LLC vs. Howe-Baker Engineers, LTD. - Delay analysis and standard of care in the engineering and design of cryogenic gas plants.

• Testimony at Trial/Arbitration - Lake Erie Biofuels, LLC vs. Benham Constructors - Review design flaws & overcharges during construction a biodiesel production plant.

• Testimony at Trial/Arbitration - Berge Helene vs. GE Oil & Gas - Expert on topsides module and equipment design and packaging for an FPSO.

• James Stewart vs. GDS Engineers, Inc. et al - Role of conceptual design engineer.

• Chart Industries vs. SME Associates - Breach of contract and intellectual property case – expert on use of brazed aluminum heat exchangers in cryogenic gas plants.

• S&B Engineers & Constructors, LTD. vs. PL Propylene LLC - Certificate of merit and expert opinion on whether design and procurement work was performed in accordance with prudent industry standards.

• Factory Sales & Engineering, Inc. vs. Aspen Power - Review defendant’s counterclaims related to deficiencies in the design & construction of a biomass boiler & pollution control equipment.

• Testimony at Trial/Arbitration - Motiva Enterprises vs. Cherry Moving Company, Inc. D/B/A Cherry Demolition - Root cause analysis of hydrocarbon release and fire in 2010 at Norco refinery.

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• Atlantic Methanol Production Company - Technical review of the performance of a revamped centrifugal synthesis gas compressor rotor bundle (AMPCO was considering an arbitration filing against the revamped syngas compressor supplier).

• Air Liquide Process & Construction vs. Turner Industries Group, LLC - Opine on the professional standard of care for engineers in connection with the design of a merchant hydrogen plant using steam-methane reforming (SMR) technology, including preparation a Certificate of Merit.

• Williams Field Services-Gulf Coast Company, L.P. vs. Eni Petroleum US, LLC, et al. - Dispute involving the basis for Daily Firm Capacity and space/weight constraints on the Devils Tower Spar in the deepwater Gulf of Mexico under the terms of a Production Handling Agreement.

• Samsung Engineering America vs. Dow Mitsui Chlor-Alkali - Review EPC firm claims related to Owner-caused delays and Owner directed changes.

• Deposition - General Welding Works, Inc. vs. L-Con Engineers Constructors - Evaluate the quality of workmanship on the shop installation of tower internals in Propane/Propylene Splitter Columns supplied by a fabricator and on the corrective actions that had to be undertaken by the EPC contractor to remedy defects on the installed trays inside the delivered columns.

• Deposition - Ascend Performance Materials, LLC vs. CenterPoint Energy Houston Electric, LLC - Assess the damages sustained by Ascend Performance Materials at the Chocolate Bayou petrochemical manufacturing complex as a result of a power outage caused by CenterPoint Energy in 2010. Offered expert testimony on effects of the outage on APM’s equipment, utilities and reactor processes, the sequence of events, and actions taken to restart the various units, plus the quantities of lost production.

• Sandy Creek Power Partners, LP vs. IHI, Inc. - Prepared a Certificate of Merit highlighting deficiencies in the design of control systems including cross-limits between feedwater and fuel for a coal-fired boiler following an overheating event in a power station.

• Cyanco vs. CDI Engineering - Expert on a matter involving the design and computer modeling of pollution control equipment in a sodium cyanide manufacturing unit in Texas.

• Deposition - Utica East Ohio Midstream vs. Preferred Engineering - Prepared a Certificate of Merit opining on the engineering standard of care and duties of the detailed engineering contractor for a natural gas liquids (NGL) extraction plant.

• Brahma Group, Inc. vs. Ames Construction - Analysis completeness of mechanical and E&I design, mechanical subcontractor inefficiencies, lack of skilled pipefitters and other craftsmen, and owner-directed re-sequencing and changes (through RFIs and site instructions) for a flotation process plant (High-Grade Mill) at a gold mine in Colorado.

• Testimony at Trial/Arbitration - HYL Technologies vs. Tecnimont KT - On behalf of the EP Contractor and technology provider, analysis of defective steam system design and supply by the vendor for a large Process Gas Heater package in a Direct Reduced Iron process facility in Louisiana.

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• Bay, Ltd. vs. Ventech Engineers USA, LLC et al - Developing counterclaims for the EPCM contractor in a dispute involving the field mechanical subcontractor and the owner of a crude oil fractionation facility.

• Enterprise Field Services vs. El Paso Natural Gas Company - Contract dispute involving gas compression services and which party is responsible for the cost for end-of-life inspection and major maintenance and repairs on a gas turbine-driven centrifugal compressor.

Testifying Experience (Prior to July 1998):

• Individual vs. Sun Production Company - Failure of an oil and gas separator

• Texas Utilities Fuel Company vs. Mitchell Energy - Breach of gas contract terms

• Deposition - Penn Octane vs. International Bank of Commerce - Design of LPG storage terminal

• Deposition - Individual vs. Western Gas Resources - Sequence of events in an accident involving exposure to H2S emanating from gas plant

• Testimony at Trial/Arbitration - Grand Junction, CO NGL fractionator vs. engineering contractor - Flaws in design of modifications to a natural gas liquids (NGL) fractionation facility

*From July 1998 to September 2005, Mark Landrum was Lead Process Engineer followed by VP of a process technology company, Syntroleum Corporation, and then VP of Syntroleum Gas Resources Company in Tulsa, Oklahoma, therefore not working as a consultant or providing expert testimony.

Seminars and Papers Presented:

“Business Interruption Network Analysis for Offshore Pipeline Systems,” IOPF2009-5001, Proceedings of the 4th International Offshore Pipeline Forum, IOPF 2009, October 2009.

“Operational Risk Management Principles Applied to the E&P Sector,” Society of Petroleum Engineers Annual Technical Conference, September 2008.

“High Quality Competitive Distillate Fuels from Coal-to-Liquids Processing,” AM-07-27, 2007 National Petrochemical and Refiners Association Annual Meeting, March 2007.

Presentations at several gas monetization, stranded natural gas and GTL forums and conferences in Colorado, Texas, Washington, D.C., New South Wales in Australia, and Tehran, Iran while Vice President, Business Development at Syntroleum Corporation.