Chris Paul concentrates his practice on business issues and complex transactional and regulatory matters. He assists clients with resolution of all aspects of transactions, including pre-transaction due diligence, risk assessment and evaluation and preparation of contracts, and post-transaction implementation of contractual protections and best operating practices.
Chris has substantial legal and management experience in providing counseling to refining and manufacturing operations in areas of liabilities and exposures, environmental requirements, risk communication, environmental program auditing and upgrading, operational compliance, security regulations and programs, and development of compliance training, tracking and management systems. He also works with emerging regulatory issues involving environmental, health and safety issues associated with nanotechnology. He has done extensive work with companies to establish systems for managing large numbers of risks and liabilities with a coordinated team approach that increases efficiencies and results in more predictable and consistent outcomes. Additionally, he has a background in energy regulation, having been responsible for transitioning plant natural gas supply to a deregulated environment, and work with pipeline tariff issues.
Chris also does extensive work with midstream and downstream energy companies, with a particular focus on pipeline and storage logistics for oil and gas companies. He has significant and unique experience in products, crude oil, NGL, natural gas transmission and natural gas distribution pipeline management and operations, including system acquisitions and divestitures, capacity leasing, real estate transactions, feedstock and product quality issues, employment issues, operating agreements and contracting, security issues, SCADA issues, and coordination of compliance (Department of Transportation, Environmental Protection Agency, Occupational Safety and Health Administration, Transportation Security Administration), emergency response, and litigation activities. His SCADA and security work is also of particular interest to utility and transportation companies.
His practice also includes significant environmental work involving site remediation and issues of natural resource damage claims, application of risk-based closure requirements, cost recovery actions, and environmental compliance planning and programs.
As part of his counseling practice, he is a frequent guest speaker before such audiences as the Association of Oil Pipelines, the American Petroleum Institute, NACE International (National Association of Corrosion Engineers), ARMA International, Environmental Federation of Oklahoma, Air and Waste Management Association, OSU Environmental Management Program, ENTELEC (Energy Telecommunications and Electrical Association),IRWA (International Right of Way Association), various other industry, professional and educational organizations, and for specific client programs.
Chris is an adjunct instructor for the Oklahoma State University (OSU) Engineering Extension Environmental Management Certificate Program. He is also certified as a mediator by The Mediation Institute and is TWIC (transportation worker identification credential) qualified.
Chris's extensive achievements and contributions to the legal industry have earned him inclusion in Oklahoma Super Lawyers (environmental, transportation/maritime, business/corporate). He was also honored for his professional and civic contributions as a 2010 recipient of the Journal Record's Leadership in Law Award.
Prior to joining McAfee & Taft in 2009, Chris was a partner with Joyce & Paul, PLLC, a law firm he co-founded in 2000. His extensive career experience includes serving as in-house counsel for Sun Company and Sun Pipe Line Company, environmental manager for Sun Company, Tulsa Refinery, and partner at Gardere & Wynne, LLP. He also served on active duty for four years as a U.S. Army Judge Advocate General's Corps lawyer with the Seventh Infantry Division where he concentrated in criminal trial work and military operations law and concurrently served as a Special Assistant U.S. Attorney for the Northern District of California.
Representative Experience
· Represented various clients in Clean Water Act cases brought by the Environmental Protection Agency and the Department of Justice.
· Provided for clients' on-site response and legal guidance in emergencies such as spills, fires, or other incidents or events, to include two of the largest on-land petroleum spills in the United States.
· For various clients, handled the acquisition of major pipeline facilities, including all aspects of various transactions, including due diligence, risk assessment and evaluation, preparation of contracts, and post-transaction implementation of contractual protections and best operating practices.
· For multiple clients, handled the divestiture of various terminaling and pipeline facilities.
· For multiple clients, established compliance programs, primarily related to environmental, health, safety and security issues.
· For multiple clients, manage environmental, health, safety and security auditing, to include on-site activities at industrial, refining and pipeline facilities.
· Managed nuisance and personal injury case involving a refinery facility that resulted in a successful verdict that was the 1996 National Law Journal Defense Verdict of the Year.
· Managed nationwide audit program for oil terminaling company subject to various state and federal regulations involving their storage tanks.
· For multiple clients, developed records management programs to improve business efficiencies and meet legal requirements related to ongoing records disposition, as well as preparation for litigation and regulatory inquiries.
· For multiple clients, provided representation in response to citations issued by OSHA alleging various safety violations at industrial facilities.
· For multiple clients, provided representation in real estate issues involving pipeline facilities, including condemnation actions.
· Represented clients in matters related to Department of Transportation Notices of Violation or other actions.
· Represented clients in purchasing equipment for control systems, to include SCADA control systems for pipeline companies and other utilities.
· Represented clients in establishing security programs and handling of security issues related to both physical and electronic security requirements, including the Chemical Facilities Anti-Terrorism Standards.
· Represented client involved in an armed raid on industrial facility by law enforcement and EPA, and subsequent white collar criminal charges.
· Provided legal and management counseling to refining, manufacturing and transportation operations in areas of liabilities and exposures, environmental requirements, risk communication, environmental program auditing and upgrading, operational compliance, and development of compliance training, tracking and management systems.
· Represented large refining facility to apply risk-based closure requirements to part of the plant at a substantial savings to the client. This work involved issues of potential Natural Resource Damage claims and coordination with multiple parties on technical and legal issues.
· Managed environmental staff and oversight of work involving various aspects of environmental compliance, including permitting, audits, air and water emissions, hazardous waste disposal, and remediation projects. Specific projects included: coordination of environmental matters for refinery turnaround, two major remediation projects, upgrading of air compliance program, and development of environmental training and tracking systems.
· Represented clients in antitrust evaluations, Robinson-Patman Act work and pre-merger notification filings; import/export work including the formal protest of a U.S. Customs duty determination; consumer credit work and major bankruptcy litigation; licensing and copyright matters; confidentiality and nondisclosure issues; and contracting for sales, services, materials procurement, capital purchases, railroad and computer equipment leasing, software development, and construction.
· Completed a project involving partnership with a group of end-user companies to construct a downstream manufacturing facility on refinery property to access direct pipeline supply of petrochemical feedstock. In addition to work with state and local authorities on zoning and permitting and work involving coordination for financing, contracts were crafted for the sale of feedstocks, provision of certain refinery services, transportation, environmental permitting, and real estate matters.
· Successfully represented a client in a debarment proceeding resulting from a felony conviction for violation of environmental laws.
· Represented multiple clients in responding to Federal Trade Commission civil investigative demands.
Attorney Articles
· Stealth regulation?
McAfee & Taft RegLINC - May 2012
· First criminal charges filed in Deepwater Horizon spill
McAfee & Taft RegLINC - May 2012
· Halliburton evidence on Deepwater Horizon
McAfee & Taft RegLINC - April 2012
· Gulf spill update - air issues
McAfee & Taft RegLINC - April 2012
· Storage tanks
McAfee & Taft RegLINC - April 2012
· Hydrocarbon refrigerants
McAfee & Taft RegLINC - April 2012
· Safe Drinking Water Act enforcement
McAfee & Taft RegLINC - April 2012
· Nanomaterial regulation
McAfee & Taft RegLINC - April 2012
· Lead-containing tackle
McAfee & Taft RegLINC - April 2012
· Canada to withdraw from Kyoto Protocol
McAfee & Taft RegLINC - April 2012
· $38 million fine for Pacific Gas & Electric 2008 explosion
McAfee & Taft RegLINC - April 2012
· EEOC sues trucking company for taking action to keep alcoholic driver off the road
McAfee & Taft RegLINC - November 2011
· RCRA notice requirements
McAfee & Taft RegLINC - September 2011
· OSHA ramps up regulatory enforcement, use of general duty clause citations
McAfee & Taft RegLINC - September 2011
· Pipeline safety reauthorization
McAfee & Taft RegLINC - September 2011
· Document destruction- Spoliation or legitimate process?
McAfee & Taft RegLINC - September 2011
· Endangered species litigation - Potential impact on pesticide use in production agriculture
McAfee & Taft RegLINC Newsletter - September 2011
· EPA data collection on nano substances
McAfee & Taft RegLINC - July 2011
· Draft DOT report on pipeline fitness for service
McAfee & Taft RegLINC - July 2011
· Endangered species litigation
McAfee & Taft AgLINC Newsletter - June 2011
· Aftershocks
McAfee & Taft RegLINC - May 2011
· Environmental crime - Asbestos and the Clean Air Act
McAfee & Taft RegLINC - January 2011
· Harsh disciplinary actions within EPA Criminal Investigation Division
McAfee & Taft RegLINC - January 2011
· PHMSA advisory: Risks associated with mobile devices
McAfee & Taft RegLINC - September 2010
· Steel producer to pay $1.6 million civil penalty for alleged violations
McAfee & Taft RegLINC - July 2010
· Oil spill prevention, control and countermeasure
McAfee & Taft RegLINC - May 2010
· EPA may establish new leaded aviation gasoline standards
McAfee & Taft RegLINC - May 2010
· Pipelines: Control room management
McAfee & Taft RegLINC - May 2010
· Gavel to Gavel: Skipping basics cost Toyota
The Journal Record - April 7, 2010
· SCADA Security, Compliance, and Liability - A Survival Guide
Pipeline & Gas Journal - September 2008
· Regulation of Pipeline Breakout Tanks Under the United States Department of Homeland Security Chemical Facility Anti-Terrorism Standards
Oil, Gas & Energy Law Intelligence - March 2008
· SCADA - beyond the technical issues
Global Pipeline Monthly - January 2008
· Legal Issues in Pipeline Integrity Programs
Pipeline & Gas Journal - October 2007
· Legal Issues in Pipeline Integrity Programs
Oil, Gas & Energy Law Intelligence - April 2007
· Legal Issues in Pipeline Integrity Programs
Journal of Pipeline Engineering - March 2007
· Legal Issues in Pipeline Integrity Programs
Global Pipeline Monthly - March 2007
In The News
· NACE Corrosion and Punishment Forum: The Legal and Regulatory Implications of Pipeline Integrity Programs
Pipeline & Gas Journal - March 2012
At The Podium
· Pipeline Integrity Recordkeeping and Other Legal Issues presented at American Gas Association's Legal Forum on July 16, 2012 in San Diego, California.
· Pipeline Integrity Recordkeeping and Other Legal Issues presented at American Gas Association's Operations Spring Conference on May 4, 2012 in San Francisco, California.
· Corrosion and Punishment Forum presented at CORROSION 2012, sponsored by NACE International on March 14, 2012 in Salt Lake City, Utah.
· Records and Communications 101 - Identifying and Managing Legal Issues in Everyday Communications presented at Oklahoma Aerospace Alliance Legal Forum on January 26, 2012 in Tulsa, Oklahoma.
· Records and Communications presented at International Right-of-Way Association (IRWA) Conference on January 20, 2012 in Oklahoma City, Oklahoma.
· Regulatory Update presented at Pipe Line Insurance Manager's Conference (PLIMC) on November 2, 2011 in Austin, Texas.
· Issues from the PG&E San Bruno Accident presented at Marsh Midstream Forum on October 18, 2011 in Tulsa, Oklahoma.
· Recognizing and Managing Environmental Liability presented at CEAT Continuing Education on October 17, 2011 in Tulsa, Oklahoma.
· True Story of a Major Records Failure presented at ARMA Oklahoma City Chapter Meeting on September 22, 2011 in Oklahoma City, Oklahoma.
· Case Study presented at Association of Oil Pipe Lines Annual Business Conference on September 16, 2011 in Denver, Colorado.
· Pipeline Safety 101 presented at Association of Oil Pipe Lines Annual Business Conference on September 15, 2011 in Denver, Colorado.
· Pipelines in the News: Communications in Crisis presented at Association of Oil Pipe Lines Annual Business Conference on September 15, 2011 in Denver, Colorado.
· Compliance, Civil and Criminal Penalties presented at NACE 2011 Central Area Conference on August 31, 2011 in Grapevine, Texas.
· Environmental Law 101 for ROW Personnel presented at 29th Annual Region 2 International Right of Way Association Seminar on August 11, 2011 in College Station, Texas.
· Legal Issues Regarding Federal Regulation in Corrosion Control Programs presented at NACE 58th Annual Corrosion Course on June 8, 2011 in Norman, Oklahoma.
· Compliance, Civil and Criminal Penalties presented at NACE International Corrosion Conference 2011 on March 14, 2011 in Houston, Texas.
· Compliance, Civil and Criminal Penalties presented at NACE International Corrosion 2011 Conference & Expo on March 14, 2011 in Houston, Texas.
· Managing Records and Communications in a Litigious Society presented at American Petroleum Institute Inspection Summit on January 26, 2011 in Galveston, Texas.
· Regulatory Update presented at 2010 Pipeline Roundtable on October 6, 2010 in Tulsa, Oklahoma.
· Environmental Law 101 presented at 2010 ChemInnovations Conference & Expo on October 2010 in Houston, Texas.
· Case Study: Incident Preparedness presented at Association of Oil Pipe Lines 2010 Annual Business Conference on September 16, 2010 in Atlanta, Georgia.
· Developments in Eminent Domain Rulings presented at International Right of Way Association's 56th Annual International Education Conference on June 30, 2010.
· Communications and Legal issues presented at Oklahoma Higher Education Heritage Society on May 20, 2010 in Oklahoma City, Oklahoma.
· Identifying the Risks That Lie Within Potential Business Opportunities presented at 2010 API Pipeline Conference and Cybernetics Symposium on April 20, 2010 in New Orleans, Louisiana.
· SCADA, Security Control Systems and Cyber Law presented at University of Tulsa Presentation on April 2010 in Tulsa, Oklahoma.
· Records and Emails presented at Building Owners and Managers Association on April 2010 in Tulsa, Oklahoma.
· Environmental Law and Regulation 101 presented at American Institute of Chemical Engineers 2010 Spring Meeting on March 2010.
· Legal Issues with E-Mail and Records Management presented at Oklahoma City Chapter of ARMA on February 2010.
· Legal Pitfalls in Electronic Communications presented at IRWA Pipeline Committee - 2010 Federal Agency Update Meeting on January 28, 2010.
· Legal Issues Regarding Federal Regulations in Corrosion Control Programs presented at The University of Oklahoma's 57th Annual Corrosion Control Course on January 27, 2010.
· Legal Issues Related to E-Mail Use and Management presented at Tulsa Chapter of ARMA International on January 7, 2010.
· Regulatory Update presented at Marsh Pipeline Roundtable on December 10, 2009.
· Nanotechnology: Risks and Environmental Impacts presented at Air & Waste Management Association: Tulsa Chapter on October 2009.
· Pipeline Security Issues presented at Association of Oil Pipelines 2009 Business Conference on September 2009.
· Legal Issues in Pipeline Integrity Programs presented at Association of Oil Piplines 2009 Business Conference on September 2009.
· Environmental Issues presented at Association of Oil Pipelines 2009 Business Conference on September 2009.
· More Legal Issues in Pipeline Integrity Management Programs presented at 21st International Pipeline Pigging & Integrity Management Conference on February 2009.
· Legal Issues and Corrosion Control Programs presented at University of Oklahoma 56th Annual Corrosion Control Course on January 2009.
· Records Management - More Legal Issues presented at ARMA Meeting on January 2009.
· SCADA Security, Compliance and Liability presented at Marsh Pipeline Roundtable on November 2008.
· Pipeline Security Issues presented at Association of Oil Pipelines 2008 Business Conference on September 2008.
· Legal Issues in Pipeline Integrity Programs presented at Association of Oil Pipe Lines 2008 Business Conference on September 2008.
· Environmental 101 - Issues for Financial Institutions and Leaders presented at Bank Seminar on September 2008.
· SCADA and Security Issues: Beyond the Hacker Threat presented at Energy Telecommunications and Electrical Association Annual Meeting on April 2008.
· Managing Pipeline Integrity Programs in a Litigious Society presented at 20th International Pipeline Pigging & Integrity Management Conference on February 2008.
· Legal Issues in Pipeline Integrity Programs presented at National Association of Corrosion Engineers: Tulsa Chapter on February 2008.
· Legal Ethics and Antitrust Issues presented at Association of Oil Pipe Lines 2007 Business Meeting on September 2007.
· Bullies, Budgets and Blunders presented at Association of Oil Pipe Lines 2007 Business Meeting on September 2007.
· SCADA Operations, Security and Compliance, Part I and II presented at Energy Telecommunications and Electrical Association Annual Meeting on April 2007.
· Records Management to Survive Discovery presented at Marsh Pipeline Roundtable on March 2007.
· Legal Issues in Pipeline Integrity Programs presented at 19th International Pipeline Pigging & Integrity Management Conference on February 2007.
· Nanotechnology - The Promise, the Opportunity, the Law and the Risks presented at Environmental Federation of Oklahoma Annual Meeting on October 2006.
· Erosion of Privilege - Due Process Under Siege? presented at Association of Oil Pipe Lines Business Meeting on May 2006 in Minneapolis, Minnesota.
· Avoiding Eliot Spitzer - Records Management to Survive Discovery presented at Association of Oil Pipe Lines 2006 Business Meeting on May 2006.
· Legal Issues for Engineering Professionals and Organizations presented at Oklahoma Society of Professional Engineers in conjunction with Oklahoma State University, College of Engineering, Architecture and Technology on April 2006.
· Claims Management presented at Marsh Pipeline Roundtable on January 2006.
· A Broader View of SCADA - Operations, Security and Compliance presented at RTAP Users Meeting on December 2005.
· Environmentalism and Sustainability - It's the Economy, and We're Not Stupid! presented at Environmental Federation of Oklahoma Annual Meeting on September 2005.
· Integrity Management Plans - Enforcement Issues and Implications presented at Association of Oil Pipe Lines 2005 Accounting and Regulatory Workshop on May 2005.
· The Ethics of Excellence Part IV - Not Just for Attorneys presented at Association of Oil Pipe Lines 2005 Accounting and Regulatory Workshop on May 2005.
· Pollution Prevention presented at Environmental Federation of Oklahoma Annual Meeting on April 2005.
· Hard Time for White Collars: The Regulatory Environment and Rising Risk presented at Marsh Insurance Conference on May 2004.
· The Ethics of Excellence Part III presented at Association of Oil Pipe Lines 2004 Accounting and Regulatory Workshop on May 2004.
· Pipeline Enforcement Issues presented at American Petroleum Institute Pipeline Conference on April 2004.
· Dollars Per Drop - The Calculation of Spill Volumes Under the Clean Water Act presented at Environmental Federation of Oklahoma Annual Meeting on October 2003.
· Agency Relations: Issues of Civil Liability presented at Hunton & Williams Pipeline Legal Issues and Policy Conference on July 2003.
· Negotiating Mergers and Acquisitions in Oklahoma: Asset Purchase Agreements and Due Diligence Procedures presented at National Business Institute on June 2003.
· Criminal Liability Roundtable presented at Association of Oil Pipe Lines 2003 Summer Meeting on June 2003.
· The Ethics of Excellence Part II presented at Association of Oil Pipe Lines 2003 Accounting and Regulatory Workshop on May 2003.
· Emerging Legal Issues presented at American Petroleum Institute Pipeline Conference on April 2003.
· The Ethics of Excellence presented at Association of Oil Pipe Lines 2002 Accounting and Regulatory Workshop on May 2002.
· Incident Management presented at 6th Annual Arkansas-Oklahoma Joint Environmental Law Conference on May 2002.
· Negotiating Mergers and Acquisitions in Oklahoma: Asset Purchase Agreements and Due Diligence Procedures presented at National Business Institutes on November 2001.
· Trends in Environmental Inspections and Enforcement Part II presented at Association of Oil Pipe Lines 2001 Accounting and Regulatory Workshop on May 2001.
· Refineries and Community Relations: Citizens Suits, Responsible Care and Environmental Justice presented at 6th Annual Central States Refining Conference on September 2000.
· Trends in Environmental Inspections and Enforcement Part I presented at Association of Oil Pipe Lines 2000 Accounting and Regulatory Workshop on May 2000.
· Environmental Training presented at Fifth International Petroleum Environmental Conference on October 1998.
Professional Organizations and Memberships
· Tulsa County Bar Association
· Oklahoma Bar Association
· Transportation Lawyers Association
· Oklahoma Academy of Mediators and Arbitrators
Civic Involvement and Leadership
· Aircraft Owners and Pilots Association
· American Legion
· Arthritis Foundation (Former Member and Board Chair, Eastern Oklahoma Chapter; Former Member and Audit Committee Chair, National Board of Directors)
· Association of the United States Army
· Leadership Oklahoma (Class XXII, 2009)
· Leadership Tulsa (Class XXII, 1995)
· National Rifle Association
· Oklahoma Aerospace Alliance (McAfee & Taft Liaison)
· Tulsa Affiliate of the Susan G. Komen Race for the Cure (Legal Advisor)