ENV-04-205 A Small Refinery's Approach to Certifying Title V Compliance Using Established Business Tools

Description:

Tesoro Refining and Marketing Company (Tesoro) owns and operates a 65,000-barrel-per-day (bpd) petroleum refinery in Mandan, North Dakota. The refinery was issued its Title V air quality permit by the North Dakota Health Department (NDHD) on December 1, 2003. Among the hundreds of requirements for this relatively small refinery was the obligation to certify compliance in December with all permit requirements by mid-February 2004. Given the short timeframe and tight budget for completing the initial certification, Tesoro sought an approach that would straightforwardly integrate all air permit compliance requirements into the refinery’s already established business tools. Such an approach would yield immediate benefits, such as: 1) Precluding the need for training on new software, 2) Minimizing unnecessary delays in developing and populating a requirements database, 3) Providing flexibility for the staff engineers, who are already familiar with the refinery’s software applications, to further customize and build on a compliance management solution, and 4) Allowing easy electronic transfer of data and results to other entities, including regulatory agencies. Tesoro Mandan utilizes spreadsheets that are organized in a manner consistent with the Title V permit and are automated to collect data through the plant information server. The spreadsheet tools not only serve as the data collection and quality assurance check but also supply documentation needed for the refinery’s periodic compliance monitoring reports. Compliance is managed on a day-to-day basis using both the refinery’s existing e-mail software to notify staff of tasks to be completed and a customized process book library of data used to routinely check key process parameters for compliance. Small refineries may not have the time or money to purchase and implement a new, expensive software system. Tesoro Mandan chose a hands-on approach by customizing its existing business tools as an interim solution for management of air quality compliance until new enterprise-wide business software tools may offer the flexibility needed to further develop environmental compliance management.