Permitting, Regulatory Compliance + Safety
TRUSTED REGULATORY AND PERMITTING EXPERTISE
Environmental, regulatory, reporting, and permitting processes are complex and challenging period. Further, penalties for non-compliance are high and can cause project delays. As part of our Energy Project Execution mindset, KAHUNA USA supports every phase of the regulatory framework–beginning with REGULATORY STRATEGY DEVELOPMENT for the project and/or operation. 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 potential penalties for non-compliance may be costly. As part of our Energy Project Execution mindset, KAHUNA USA supports every phase of the regulatory formwork 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 environmental, safety, and operational regulatory requirements that must be met for successful business operations by determining regulatory obligations and providing permitting and operational options to meet the regulatory requirements and operational needs. KAHUNA USA helps our clients develop cost-effective methods for complying with complex, and confusing industry requirements; from completing permit applications, evaluating current operations, preparing required regulatory plans, and even assisting with responses to regulatory Notices of Violation.
The regulatory experts at KAHUNA USA help keep our business and its employees safe and compliant, and we help make complying with regulatory agencies in multiple states as straight forward as possible.
Macro List of 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
Three facilities in the western Permian Basin, including two new compressor stations combined with modifications to an existing compression facility. KAHUNA USA provided engineering services involving serval OSHA Process Safety Management responsibilities.
Prior to construction, KAHUNA USA facilitated Process Hazard Assessments (PHAs) per the 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, and piping and equipment specifications
- Identifying previous incidents and potential consequences of operating parameter deviations associated with the processes
- Completing a Hazard and Operability (HAZOP) analysis to evaluate hazards of the process
- Leading the PHA team in conducting the HAZOP and recording all pertinent information, and
- Publishing the PHA results, including recommendations in a final report
Prior to facility startup, KAHUNA USA prepared Operating Procedure Manuals (OPS) for each facility. The OPS provides all employees and personnel involved in the operation of the plant, with information required to safely, efficiently, and effectively start, operate, respond to operational deviations and emergencies, and shut down the plan 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 portions of the existing gas plan and construction of additional compression at the site, KAHUNA USA finished by conducting an evaluation of the applicability of the OSHA 29CFR1910.119 – Process Safety Management of Highly Hazardous Chemicals Standard to this facility. This evaluation involved calculating the Maximum Intended Inventory at the facility and comparing this to the applicability requirements listed in 29 CFR Part 1910.119(a)(1), specifically whether the remaining processes 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 the development of procedures 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
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