RESTORING PLANTS QUICKLY AND SAFELY.
44NOVEMBER 2014 | HydrocarbonProcessing.com
Plant Safety and Environment
One of the more common mistakes encountered by envi- ronmental professionals is processors relying entirely on en- vironmental consultants to understand the rules. Although consultants are always willing and eager to provide assistance, internal knowledge is key to long-term success.
Know plant operations, inside and out. Environmen-
tal compliance requires careful planning to collect informa- tion at a level of accuracy required to meet the objectives of an environmental program. Detailed information should be maintained for all assets throughout an organization, including the age, material type, service records and construction specs. Other information—such as installation, contractor, climate, and exposure (i.e., weather conditions)—may also be helpful.
Implement asset- and risk-management programs.
Although most owners/operators already have integrated asset- and risk-management programs throughout their or- ganizations, those who do not have such a program need to implement one, and quickly. The goal of integrated asset- and risk-management programs is to allow an operator to assess the entirety of its processes and assets, rather than to keep track via the narrow lens of permits and departments.
The rationale for such a program must be demonstrated through a risk-based asset-management approach that priori- tizes capital, as well as operation and maintenance investment, on the basis of the highest return on investment, weighed against the level of risk that an organization is willing to accept.
Note: Integrated asset- and risk-management programs must be organization- and location-specific, and take long-term op- erational and business goals into account. Beyond this, such programs should be built upon by the local operation manager, based on local needs. A fully developed, integrated asset- and risk-management approach requires a number of iterations, and it should be reviewed frequently for more complex systems, es- pecially where program performance goals are high.
Be proactive. It is understandable that some owners/opera-
tors wait until the last minute to conduct environment-related activities, including environmental permitting, remediation or negotiations with regulators. However, by waiting, these own- ers/operators face the risk of penalties, negative press, increased regulatory scrutiny and decreased operational efficiency (FIG. 3).
Of course, putting off these activities creates its own problems. The last-minute panic of starting the process days before a permit
is due or a regulatory action is taken can have severe impacts on an organization, including lost time from shutdowns, frantic data compilation, and increased legal and administrative fees.
Choose the right consultant. The best way to avoid get-
ting caught in the negative feedback loop is to hire the right consultant for an operation. Unfortunately, this can also be the toughest decision, especially since there is often no physical product to evaluate. Aside from checking credentials and ref- erences, the decision often rests largely on what a consultant communicates. When interviewing consultants and reading proposals, things to look for include questions such as:
• Does the consultant’s technical experience match the company’s needs?
• Does the consultant understand the regulations as they apply to the company’s operations/location?
• Does the consultant offer strategic options that provide cost-effective solutions that are in the company’s best interest?
• How well does the consultant communicate?
• How busy is the consultant, and what capacity does the consultant have to support the size of the company’s operations now and in the future?
• Will the consultant be a long-term partner to support the company’s business needs?
Asking these types of questions and carefully considering the consultant’s qualifications is critical and will save time and money in the long run.
Develop the right plan. Environmental compliance pro-
gram plans outline the entire compliance structure of an or- ganization. These plans name the environmental compliance team, outline compliance requirements, describe commit- ments, develop mitigation plans, create staff training plans and list environmental permits.
In addition, these plans demonstrate an organization’s com- mitment to compliance and to integrating verification proce- dures into operational and management systems. These steps help ensure compliance with regulatory requirements, detect nonconformities and correct identified deficiencies.
Due to the importance of these documents, they must be organization- and site-specific, and they must include all ap- plicable regulatory program obligations. Owners/operators should not try to save resources in this step, as it will prove det- rimental in the long run.
Do not treat environmental activities as commodities.
In recent years, some hydrocarbon processors have treated en- vironmental activities—from audits, investigations and nego- tiations—as commodities, using inexpensive “one-size-fits-all” approaches to support regulatory compliance programs and environmental loss investigations. Although attractive from an initial investment, generalized assessments can create higher risks over the long term for hydrocarbon processors, as com- pared to site-specific investigations.
The biggest challenge with this method is that non-specific site investigations often do not incorporate the complex regu- latory environment that varies by region, city and county. Fur- thermore, these investigations do not take into account an op- eration’s unique objective. An incomplete, inaccurate or even overly comprehensive assessment can cause delays and add unexpected costs to a project.
FIG. 3. Do not wait until the last minute to conduct environmental activities, including remediation, permitting and negotiations.
Hydrocarbon Processing | NOVEMBER 201445
Plant Safety and Environment
Openly communicate. Generally speaking, owners/opera-
tors who meet with regulators have a higher probability of posi- tive outcomes than those who do not, so it is highly encouraged that owners/operators, environmental consultants, and the ap- plicable regulatory body meet to discuss project challenges.
Open communication has two main goals. First, it gives an opportunity for the agency to provide guidance to facilitate compliance with regulations governing land use, emission controls, compliance and new facility development. Second, it maintains open lines of communication throughout the com- pliance process. This will help prevent misunderstandings in compliance communication, and it may help explain how mis- takes occurred in the first place.
Follow through, but be flexible. An effective environ-
mental compliance plan is a living, breathing document. To be effective, it must become an integral part of an organiza- tion. Too often, these documents lay dormant until a regulator shows up for an audit, or until a violation occurs. Through ac- tive application of the plan’s policies and procedures on a daily basis, active compliance can be achieved. This compliance can streamline an organization’s business and operations, reduce the likelihood of statutory violations, help mitigate damages and show that a company is doing its best to comply with all applicable rules and regulations.
Owners/operators must follow through with fully imple- mented and verified corrective actions, as outlined in the com- pliance plan. Those who do not follow through with these ac- tions face further compliance issues, negative press and even higher penalties.
Risky business. Long gone are the days of the “wait-and-see” environmental approach—owners/operators should remove the phrases “let the regulators tell us what to do” and “we’ll worry about that later” from their lexicon. To remain competi- tive, owners/operators must possess a deep understanding of all requirements to ensure compliance and move the industry away from the regulatory spotlight.
Hydrocarbon processors have never had a better opportunity to address the regulatory “elephant in the room” than the pres- ent. Comprehending the regulatory environment, understand- ing operations thoroughly and teaming with key environmental professionals will help owners/operators prepare for, plan and mitigate any hazards associated with normal operations.
With technological advances, hydrocarbon processors will be able to make informed and defensible decisions to address critical needs in the appropriate sequence and in a financially sustainable manner. Regulators may not offer complete relief, but these steps can deliver a much-needed compromise.
VERNON “KRIS” ALLEN has 18 years of practical experience focused on air quality planning and permitting. He is a senior project manager engaged in the growth and development of air quality practice. His experience includes technical and project management support for numerous projects, including conformity analysis, environmental planning/review (NEPA/CEQA), air permitting (NSR, PSD, Title V, Title IV and Minor Source), emission inventories, abatement (RACT/BACT/LAER/MACT), regulatory applicability reviews and air-dispersion modeling. Mr. Allen holds a BS degree in environmental restoration and waste management from Colorado Mesa University. He is a member of the Gas Processors Association, the Air and Waste Management Association, the Rocky Mountain EHS Peer Group and the Colorado Oil and Gas Association.
A0 11 2 0 EN
Partner with
the Best
With over 50 independent subsidiar- ies and more than 220 engineering and sales offi ces spread across the world, SAMSON ensures the safety and environmental compatibility of your plants on any continent.
To offer the full range of high-quality control equipment used in industrial processes, SAMSON has brought together highly specialized compa- nies to form the SAMSON GROUP.
SAMSON AG · MESS- UND REGELTECHNIK Weismüllerstraße 3
60314 Frankfurt am Main · Germany
Phone: +49 69 4009-0 · Fax: +49 69 4009-1507 E-mail: [email protected] · www.samson.de SAMSON GROUP · www.samsongroup.net
Asia Asia A