Permitting, Regulatory Compliance + Safety
TRUSTED REGULATORY AND PERMITTING EXPERTISE
Environmental, Health & Safety regulations are continually changing and must be reviewed for project and operational compliance. Permitting processes and compliance reporting are complex and challenging. Regulatory missteps can cause project delays and penalties for non-compliance. As part of our Energy Project Execution mindset, KAHUNA USA supports every phase of the regulatory framework from PHA Facilitation to permit applications, as well as assistance with regulatory filings and plan preparation. We work strategically to ensure a smoother process for permit submittals and compliance assistance to keep your project on track, including:
- Permitting and Regulatory Compliance (Applications, Plans, and Filings)
- Regulatory Compliance Audits
- Health and Safety Compliance Program Development
- Loss Prevention and Risk Management Assessments
KAHUNA USA understands the federal, state, and local government regulation requirements required for successful business operations. We help determine regulatory requirements and provide permitting and safety options to meet your operational needs. We develop cost-effective methods for complying with complex, and confusing industry requirements; from completing state permitting applications, evaluating current operations, preparing required regulatory plans, and even assisting with responses to regulatory Notices of Violation.
The regulatory experts at KAHUNA USA keep your business safe and compliant, addressing worker safety, pipeline safety and making compliance with regulatory agencies in multiple states as straight forward as possible.
PERMITTING, REGULATORY COMPLIANCE + SAFETY SERVICES
- Permitting tasks: Construction stormwater, air, hydro test wastewater, waste
- Regulatory compliance tasks: SPCC plans, RMP plans, Emergency Response plans, pipeline safety / operational plans
- Safety compliance tasks: PSM required activities and plans, other OSHA required plans/programs
KAHUNA USA provided engineering services for 3 facilities in the western Permian Basin, including 2 new compressor stations, modifications to an existing facility and several OSHA Process Safety Management deliverables.
Prior to construction, KAHUNA USA facilitated Process Hazard Assessments (PHAs) per OSHA 29CFR1910.119 – Process Safety Management of Highly Hazardous Chemicals Standard on the facilities. The PHAs consisted of:
- Reviewing process specific piping and instrument diagrams
- Reviewing piping and equipment specifications
- Identifying incidents and potential consequences of operating parameter deviations
- Evaluating hazards with a Hazard and Operability (HAZOP) analysis
- Leading the HAZOP and recording all pertinent information, and
- Publishing the PHA results, including tailored recommendations, in a final, beneficial report
Prior to facility startup, KAHUNA USA prepared Operating Procedure Manuals (OPS) for each facility. The OPS provided all personnel operating the plant with information required to safely, efficiently, and effectively start, operate, respond to operational deviations and emergencies, and shut down the plant in a safe and orderly manner. The OPS were written to conform to OHSA’s Process Safety Management (PSM) Standard 29 CFR Part 11910.119(f): Operating Procedures.
Upon decommissioning the existing plant and construction of the new facilities, KAHUNA USA conducted an evaluation of the applicability of OSHA 29CFR1910.119 – Process Safety Management of Highly Hazardous Chemicals Standard which involved calculating the Maximum Intended Inventory at the facility and comparing this to the requirements listed in 29 CFR Part 1910.119(a)(1), specifically whether the process involved a Category 1 flammable gas in a quantity of 10,000 pounds or more.
KAHUNA USA has the knowledge and expertise to safely, efficiently, and effectively guide our clients through procedure development to comply with safety regulations.
KAHUNA USA completed a compliance evaluation in preparation for a pipeline audit by the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA). Conducted to assess the level of compliance of the facility and pipeline operations, as they compare to the requirements of 49CFR192 and 195. This evaluation included a review of existing manuals, data, and pipeline plans; pipeline operator and supervisor interviews; and site visits to portions of the facility ad pipeline right-of-way
Upon completion, KAHUNA USA aided the client in resolving questions and providing necessary documentation from the PHMSA audit, including PHMSA clarification on the facility Operations and Maintenance Plan, Control Room Management Plan, and Operator Qualifications Plan. KAHUNA USA ultimately conducted Department of Transportation Oilfield Impact Training with health and safety personnel. Participants were trained regarding the Federal Motor Carriers Safety Administration (FMCSA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) departments of the United States Department of Transportation (DOT), specifically as to how they impact the client’s operations and facilities.
This project required a complete review of the Regulation No. 7 for the wellpads and compressor stations operated by client in Northern Weld County, and western slope in Colorado. The updated regulation required those facilities to reduce and control methane and VOC emissions. KAHUNA USA attended virtual meetings with client operations and project management staff to review the actual operations and determine the applicability and requirements for the emissions reductions and controls. A summary set of spreadsheets were developed to summarize the applicability for each of the 15-20 sites. KAHUNA USA set up a summary of changes necessary to comply with the reduction deadlines. KAHUNA USA also visited the sites to confirm the equipment and layout for the sites and provide additional design assistance for controls to be added.
Tall Oak Midstream
This project required a fast track for air quality permitting and engineering design for a gas plant. As with most projects, KAHUNA USA provides the coordinated air permitting application with the preliminary design details to get the application review process started with the applicable state/federal agencies, in this case, the Oklahoma DEQ. Working with the engineers and Tall Oak’s environmental services consultant, KAHUNA USA was able to provide a complete application for submittal to ODEQ one and half months before the detailed design was completed. The air quality requirements were coordinated with engineering to assist with finalizing a compliant design.
We're here to help you with permitting,
regulatory compliance and safety.
James Fleak, P.E.
Jeff Citrone, chi, cap, pg
We ‘re here to help. Give me a call.