A large upstream oil and gas company operates both an offshore production and onshore separation facility within the Outer Continental Shelf off of California, and therefore faces a complex web of environmental requirements at the federal, state and local level. Environmental permits and approvals include Title V permit, NPDES effluent permit, Coastal Commission and land use approvals, all of which require routine compliance certifications for a robust suite of monitoring, recordkeeping and reporting obligations. ALG was tasked with creating a sustainable environmental compliance tool that would document and effectively organize all applicable requirements and include details such as ongoing task frequencies, task completion instructions, and legal citations. The tool was expected to provide improved performance, streamline workflows, and when fully implemented, realize cost savings.
At the project’s inception, ALG met with client management and technical staff to confirm scope, deliverables, and confirm the role and responsibilities of the project team members. Working with our client, we effectively paired up environmental subject matter experts within ALG and the client’s corporate and facility staff to create subject teams for all environmental media. Individual teams then followed pre-approved project templates to delineate all ongoing obligations.. Research included full documentation of prior permitting and regulatory applicability determinations and complete documentation of specific regulatory exemptions. Additionally, prior compliance histories were reviewed to fully document the adequacy of ongoing monitoring, recordkeeping and reporting, with references to current agency-issued guidance. ALG leveraged existing software to support design/delivery of the finished compliance tool.
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After all team tasks were completed, the subject obligations were consolidated into a master tool for final delivery. This final deliverable served as the first comprehensive list of regulatory obligations for the subject facilities and is intended for ongoing tracking and updates in an easy-to-use format. When completed, the tool provides a complete compliance assurance database, an automated compliance task tracking to assure environmental sustainability and compliance.. By partnering with our client’s subject matter experts and facility compliance staff, ALG was able to reduce total project costs, and enhance full integration of the new tool into our client’s environmental management program.