ENV-03-134 Implementing an Environmental Management Information System (EMIS) for Title V Permit Compliance. A Case Study: Valero Refining Company – New Jersey

Description:

This paper will discuss a case study of implementing an Environmental Management Information System (EMIS) for Title V compliance tracking through task management at the Valero Refining Company – New Jersey ("Valero") refinery in Paulsboro, NJ. The paper will provide an overview of the implementation process, a discussion of the technological issues, and focus on specific implementation hurdles. Implementation challenges to be discussed include: deciding on a type of EMIS (paper based vs. simple electronic tools vs. “off the shelf” software, etc.); breaking down the lengthy Title V permit into manageable compliance demonstration tasks; determining the level of detail to include in each task; determining ownership and supervision of tasks (environmental staff vs. operations level); deciding if and how to group similar compliance tasks; determining task frequency (particularly in terms of permit requirements that have a “continuous” frequency or requirements that have no specified frequency at all); and dealing with requirements where it is unclear how compliance can be demonstrated. Successes and lessons learned from this project will be summarized in this paper through a discussion of the entire implementation process from concept inception through the completion of the first Title V annual certification for the refinery.