Responsible Care 2019 goals update; new goals set

Responsible Care uses a philosophy of plan, do, check, and act, whereby activities are planned, carried out, and then evaluated for their effectiveness.

Dakota Gas manages its safety, health, security, and environmental responsibilities by following the Responsible Care Management System® (RCMS) process.

Responsible Care uses a philosophy of plan, do, check, and act, whereby activities are planned, carried out, and then evaluated for their effectiveness. Following Responsible Care guidelines is voluntary and not required by government regulations, although the system demands a commitment to staying in compliance with government rules. Responsible Care companies must prove they are living up to their commitments by passing a third-party audit of their management system every three years. Internal audits are also conducted between recertification audits and will continue to be performed over the course of the next certification cycle.

Each year, Dakota Gas lists goals for the new year and reviews goals set from the past year to recognize and highlight the progress made over the past year. The information covers the core areas for a Responsible Care company – environmental, health and safety, product stewardship, sustainability, and security. Goals are set in these core areas each year in an effort to drive improvement.

Plant Manager Dale Johnson will be reviewing the 2019 goals and achievements made, as well as presenting the 2020 goals during upcoming employee communications sessions.

The following goals were set for 2019:

Compliance, Safety, and Industrial Hygiene goals

1. Continue to work on potential non-conformance observations from the Process Safety Management Compliance Audit from September 2017.
a. This effort continues with 17 of the 21 potential non-conformance observations complete.

2. Evaluate and implement new Risk Management Plan (RMP) amendments.
a. RMP amendments have been implemented.

3. Increase the number of CI inspections to reach 2019 goal of 250.
a. This goal was met.

4. Complete noise monitoring for 6200 and 4300 units.
a. This goal was met.

5. Evaluate portable monitors for applicability plant wide.
a. This goal was met.

6. EXP 6.2 software roll-out at Dakota Gas.
a. This goal was met.

7. Survey potential exposure from process sample points by identifying potentially hazardous sample points, surveying current methods used to acquire samples, and prioritizing exposure risk. Modify four sample points to make them inherently safer in 2019.
a. This goal was met.

8. Fully implement PHMSA recommendations
a. All recommendations have been implemented.

2019 Environmental goals

1. Reclamation of SP-100 and SP-101 closed landfills:
a. Reduce leachate level in SP-100. About 30,000 gallons were pumped from SP-100 in 2019.
b. Run plant air to resume operation of leachate recovery pumps from closed areas (SP-101 and north half of SP-109 active landfill). This goal was not completed as the strategy changed to using gas-powered pumps.

2. SP-109 active landfill improvements:
a. Dredge southeast corner leachate collection pond to enhance leachate handling. This goal is set to be completed in 2020.

3. Groundwater remediation:
a. 95% reliability for groundwater recovery well. Work on this goal continues as the plan is to maintain 95% reliability of air stripper on an annual basis. Only 87.8% for 2019, due to having to put in a new recovery well and some air stripper maintenance issues.

4. Implement North Dakota Pollution Discharge Elimination System changes.
a. Identify strategies to reduce storm water contaminants. This effort continues.

5. Air control and monitoring system optimization:
a. Develop and implement mercury control technology. This effort continues.

2019 Emergency Management and Security goals

1. Conduct four vehicle site entry audits.
a. This goal was met.

2. Conduct four emergency response drills (one for each shift).
a. This goal was met.

The following goals were set for 2020:

Compliance Safety and Industrial Hygiene goals

1. Work towards resolving potential Process Safety Management non-conformance observations from September 2017.
a. Multi-year corrective action plans were developed for all potential non-conformance observations and are currently being implemented.
b. Seventeen of 21 potential non-conformance observations are completed.
2. Implement new online Safety Data Sheet (SDS) management system.

Emergency Management and Security goals

1. Conduct four vehicle site entry audits.
2. Conduct four emergency response drills (one for each shift)

Environmental Performance Measurement goals

1. Reclamation of SP-100, SP-101, and the north half of SP-109 closed landfills
a. Reduce leachate level 80,000 gallons in SP-100
b. Recover leachate from closed areas (SP-101 and SP-109)

2. SP-109 landfill improvements
a. Dredge southeast leachate collection pond.
b. Dewater inactive phases.

3. Waste characterization, remediation, and disposal
a. Verify compliance with new waste handling and storage rules in all waste storage areas around plant site.
b. Develop procedures and templates for spill reporting.

4. New underground storage tanks rule implementation
a. Replace all underground storage tanks with above-ground storage tanks for 2020.

5. Groundwater remediation
a. Groundwater recovery well operation – Maintain 95% reliability

6. North Dakota Pollution Discharge Elimination System changes
a. Implement new surface water pollution control strategy.

7. Air control and monitoring system optimization
a. Develop and implement mercury control technology for Riley boilers.
b. Submit an application for a new operating permit incorporating recent facility changes and PAL renewal.

8. Learning Management System training implementation
a. Update/create training curricula.
b. Identify/assign to appropriate personnel.

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