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Managing the Environmental Handoff: Tips for a Seamless Transition

Managing the Environmental Handoff: Tips for a Seamless Transition, Nate Kilgore

The transition from the construction phase of an oil and gas project to startup and operation is like the handoff in a relay race. You want it to be smooth and seamless. If the baton gets dropped, it can usually be pinned to a communications breakdown.

For a track relay team, a poor handoff can result in disqualification. For an environmental services team, it can produce a regulatory violation.

There are many factors that can make — or break — a swift and compliant handoff of environmental components of a project. Among them:

  1. Document management. One of the biggest roadblocks to a smooth turnover is environmental document management. Missing or out-of-date documents can be a drag on the process. Assigning responsibility for real-time documentation updates as changes are made helps to eliminate any bottlenecks or confusion at handoff.
  2. Construction vs. operational permit requirements. Although many regulatory requirements overlap between construction and operation settings, construction regulatory requirements are different in many situations. The construction project team must understand the facility’s operational requirements to prevent inadvertent operational regulatory violations.

    Construction stormwater is typically the most challenging of operational permit considerations. Often stormwater discharge quality requirements at a construction site can be different from those detailed in the owner’s operational National Pollutant Discharge Elimination System (NPDES) permit, which may or may not include construction stormwater discharge streams. Often, that’s because the construction site represents only a portion of the geography covered by the permit at a given time. Although the stormwater quality at the construction site might meet permit requirements under construction regulations, it might contribute to or violate operations compliance requirements when considered with the facility stormwater system. Construction and operations environmental staff must work together to understand their roles in meeting overall compliance goals and requirements.
  3. Discovery of legacy/pre-existing environmental impacts. Some construction sites have environmental liabilities that were unknown prior to construction. That’s why it’s imperative to perform environmental due diligence. You need to identify these liabilities and determine if they require removal and disposal to minimize disruptions to the project schedule, budget and operational requirements. This work can’t be done in a vacuum. The construction environmental team must keep the operations staff apprised of legacy threats so their potential impact on regulatory permit compliance can be properly managed.
  4. Project add-ons and upgrades. Environmental staff also must be aware of other construction at the site, including everything from asbestos abatement activities to infrastructure updates. Changes to a project’s footprint and complexity could change the environmental impacts of your project, as well as the Storm Water Pollution Prevention Plans (SWPPPs), Spill Prevention, Control, and Countermeasure (SPCC) plans, inspections, and training you develop. They also expand the need for collaboration and coordination between the construction project and existing operational staff.

The most effective way to keep any of these issues from slipping through the cracks is to break down the barriers between construction and operations teams. Finding the areas of overlap and engaging the operational team on these issues will better prepare them to continue regulatory compliance into routine facility operations once project turnover occurs.

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Nate Kilgore
Written by Nate Kilgore
Nathan Kilgore, PG, serves as a project geologist in the field of contaminant remediation.

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