ENV-03-135 Practical Methodology for Addressing Ongoing Title V Compliance Certification – A Refinery Case Study

Description:

A previous database of applicable citations and regulatory text specific to the facility existed, but spot checks with current regulatory content revealed that changes had occurred since the text had been imported, perhaps five years ago. Further, longer citations were truncated because of limitation of field size in the various forms that the data had taken over the years. In order to provide effectively for management of change, ERM’s proprietary CFR Text GrabberTM utility was used to import a whole new corpus of regulatory text. This process can be repeated periodically, overlaying the current body of regulations and flagging changes. In other words, the system need not become out of date merely because a rule changes. State rules were not available on-line in the same format, so they were programmatically transformed into a suitable format and then imported using the same custom tool. Federal requirements were mostly pulled from the EPA’s eCFR web site, but some were not available or were outdated, in which case the slower GPO site was used. A unique feature of CFR Text Grabber™ is that it programmatically works out the complete citation for each regulation using the innermost level given by the source text. This is an essential conversion piece that makes periodic pulls possible without manual manipulation. The list of potentially applicable Federal subparts and state rules was based on similar analysis performed for other refineries. Once the citation list was imported into the database, the facility’s draft Title V permit was obtained electronically from the agency and database tables containing permit conditions and numerical limits were imported. In order to document the applicable requirements that would be selected from the database, a comprehensive applicability review was performed. Each citation was judged as either: · Applicable; · Applicable but overridden by another requirement; · Applicable but an equipment standard; · Applicable but does not contain a requirement; or · Not applicable. In conjunction with this activity, wherever a more stringent requirement was identified, a cross-reference to that specific citation was created. For those requirements judged to be applicable, text that described a suitable periodic check was created. These checks were assigned to a responsible position in the organization, and a frequency at which the check would be performed was established.