Fractionation Plant - Louisiana
Cadre’s team facilitated the five-year Process Hazard Analysis Revalidation (PHA-R). Under OSHA’s paragraph §1910.119(i)(2)(iii), “An employer must comply with the management of change standard when existing facilities are modified more than by ‘replacement in kind'” and §1910.119(e)(6) calls for a review at least every five years thereafter. Cadre staff evaluated the prior PHA-R and all MOCs for the review period, assembled an on-site review team and led the revalidation process. The combined team discussed relevant topics including MOCs during the review period, recordable incidents and assured that all processes were – and are – aligned with current PHA processes and regulations. Cadre’s expertise and efficiency resulted in a revalidation that was completed in a fraction of the time devoted to the prior PHA-R, much to the client’s satisfaction.
Underground NGL Storage Terminal - Texas
Cadre’s experts updated the environmental manual for a NGL (Natural Gas Liquids) salt dome storage facility with a total capacity of 370 million barrels of integrated liquids and 23 million barrel of brine that serve the Houston Ship Channel. With these procedures, the facility was able to comply with EPA and TECQ requirements.
Sorrento, Louisiana
Cadre rewrote the operations procedure for a cryogenic refinery off-gas processing facility to address PSM and DOT pipeline audit findings. We also developed training programs using our proprietary format for operations and maintenance. This effort corrected all findings related to operator information and training.
Cadre annually conducts the following services for this facility:
- The annual LOTO certification for this facility.
- The annual EAP drill for this facility.
- Updating training and operations program changes as part of the annual review.
Multi-Facility Developer and Manufacturer of Oil/Gas Jack-Up (deep water) Drilling Platforms
Cadre performed an occupational safety and health audit for this expansive operation, which covered approximately 150 acres with facilities both under roof and open to the environment. The operations involved both onshore and offshore safety and health requirements. This project followed an OSHA inspection resulting from an incident and citations. All documentation was reviewed and updated as required. The documentation included, but was not necessarily limited to:
- Medical records
- Quantitative and qualitative medical examination of workers whose jobs required them to work in an unusually hazardous environment
- Reviewed the history, education, certification, etc. of physician(s) performing medical examinations
- Performed medical surveillance
- Operational and Performance Respiratory Fit-Test
- Medical qualifications required to perform Self-Contained Breathing Apparatus (SCBA) and Personal Protective Equipment (PPE)
- Training records
- Training instructor qualifications
- Heavy-lift (multiple cranes) preparation, planning and execution. This included the draw-works and drilling platform.
- Required OSHA recordkeeping
- Toxicity analysis of surface “sand” blasting materials and operation
- Facility monitoring and security procedures
To further complement the audit, the auditor reviewed and advised the client concerning sub-contractor safety and health preparations as cross-matched to the company’s safety policies and procedures. This included “one-man” sub-contractors through “multi-employee” sub-contractors. At any given time, there were 250 welding contractors working onsite.
The audit included 29 CFR 1910, 1918 and 1926. These inspections and audits included the client manufacturing, service and administrative departments.
Above-Ground Coal Mine Facilities - West Virginia & Kentucky
These facilities are above ground transfer facilities for storing and transporting coal. To identify the hazards associated with this process, a hazard assessment was conducted coordinating with the Corporate EH&S Representative and the Facilities Managers. We conducted an exhaustive research of the West Virginia Standards for mining the Kentucky Standards for Mining along with the Federal MSHA standard. We developed a health and safety (H&S) manual for each facility that met the state, federal, and corporate requirements for operating above ground facilities safely. The prominent element of this process was the individual state requirements for each facility.
Underground NGL Storage Terminals - Texas
Cadre’s safety specialist updated the Operation’s Manual for the southern and northern terminals of a NGL salt dome storage facility in Mont Belvieu, TX maximum storage capacities of ~14 m bbls and ~360 m bbls, respectively. This effort was to ensure compliance with ISO 9001 quality requirements, OSHA’s PSM, and DOT regulations.
Underground NGL Facility - Mississippi
Cadre worked with the operation department and management to determine the requirements for operating the facility. Coordinating with the facilities management Cadre wrote the operating procedures and developed a training program using our proprietary format. This program ensured the facilities ability to comply with OSHA’s PSM and DOT regulations.
Electric Power Generation Plant - Texas
This plant is a peaker plant located in North Central Texas. To identify the required health and safety programs for this facility, a comprehensive hazard assessment was performed. These include:
- Updated H&S procedures.
- Updated regulatory compliance training programs. The training included all regulatory compliance information and regulatory compliance information based on site specificity including emergency action plan.
- Emergency action plan drills.
- Generated the annual personal protective equipment certification.
- Updated the lockout/tagout program.
25,000 barrel per day O-grade Fractionator Facility
The facility did not comply with OSHA’s PSM and DOT regulations. Cadre’s experts updated the operations procedures and developed a self-paced training program for operations to certify their operator on the process to ensure compliance. We developed training programs using our proprietary format for operations and maintenance. This effort corrected all findings related to operator information and training.
Cadre annually conducts the following services for this facility:
- The annual LOTO certification for this facility.
- The annual EAP drill for this facility.
- Updating training and operations program changes as part of the annual review.
Electric Power Generation Plant - Texas
The Public Utilities Commission of Texas (PUCT) and the Electric Reliability Council of Texas (ERCOT), acting on state Senate bill SB-1133, required the power plant to submit an emergency operating procedure by March 2, 2012. Failure to do so would have limited the ability of the plant to continue operating, or even required the plant to discontinue operations. Cadre researched and developed an EOP that was approved by the plant’s corporate offices, submitted ahead of the deadline, and accepted by ERCOT. The EOP included the following elements:
- Facility Background Information
- Winter Weatherization Plan
- Summer Weatherization Plan
- Winter Emergency Operation Plans
- Adverse Weather Emergency Operation Plans
- Recovery of Generation Capacity
- Pandemic Plan
- Black Start Drill Procedure
- Facility Black Start Plan
- Work Plan
- List of Start-Up Equipment
- Emergency Contact List
- Affidavit of Compliance
Major Manufacturer, North Houston, TX
Cadre completed a comprehensive hazard assessment and OSHA-type safety inspection/audit for a major manufacturer in Houston, Texas. This comprehensive, multi-faceted audit was performed for two purposes: 1) Improve the safety culture (They had 25 OSHA-recordable accidents since January 1st), and 2) to reinstate the canceled insurance. The inspection/audit included, but was not limited to:
- Initially, all documentation was reviewed, documented, and updated as required. This followed an OSHA-type inspection resulting from an incident and citations. The documentation included:
- Medical records
- Training records
- OSHA 300 Recordkeeping
- Device inspections (i.e., crane, forklift, etc.)
- Reviewed and advised concerning subcontractor safety and health preparations as cross-matched to the Company’s Safety Policies and Procedures
- Other as applicable
- Evaluated the facility monitoring and security procedures.
- Established facility monitoring and security procedures.
- Worked with management to establish a time and motion study to improve the workflow while utilizing this large scale operation.
- Set up subcontractor policies and procedures
- Provided a comprehensive report of findings. This was a confidential report and was provided to applicable personnel.
Chalmette, Louisiana
Cadre rewrote the operations procedure for a cryogenic refinery off-gas processing facility to address PSM and DOT pipeline audit findings. We developed training programs using our proprietary format for operations and maintenance. This effort corrected all findings related to operator information and training.
Cadre annually conducts the following services for this facility:
- The annual LOTO certification for this facility.
- The annual EAP drill for this facility.
- Updating training and operations program changes as part of the annual review.
Crude Oil Spill Clean-up, Gulf of Mexico
Cadre researched and developed a regulatory compliance matrix for the facilities during and following the spill clean-up. A significant amount of municipal codes were researched to glean, develop and display the information. The matrix format was chosen to display the information. The vast amount of information had not been coordinated as in the matrix before this time. These data included:
- Federal, state, county/parish and city municipal codes are included in the final display matrix.
- Material from five (5) states is included in the completed presentation. Four (4) of the states bordered the Gulf of Mexico, one (1) state was inland.
- These researched data included, but not necessarily limited to:
- International Building Codes.
- International Fire Codes.
- National Fire Protection Association Codes.
- International Plumbing Codes.
- American for Disability Act Codes.
- County and/or Parish Municipal Codes.
- City and/or Local Municipal Codes. In at least one (1) instance a local code was specific to the point of requiring that all decorative landscape plants be not more than 24-inches tall. In another instance fire hydrants are required to be painted a specific shade of blue coloring.