Regulatory Background
The Title V Operating Permit Program under the U.S. Clean Air Act Amendments of 1990 requires certain facilities to apply for and obtain Title V operating permits, which consolidate all applicable requirements from U.S. federal, state, and local air quality regulations and existing air permit terms and conditions. The facility’s Responsible Official (RO) is tasked with routinely submitting compliance certifications that indicate the status of compliance, noting any deviations from the requirements of the Title V Permit. The RO must sign off that informa-tion provided in the compliance certificainforma-tion is true, accurate, and complete “based on information and belief formed after a reasonable inquiry.”
em • case study
by Sara King and Jeffrey Meyers
Sara L. King is the environmental director at the ConocoPhillips Ponca City Refinery, in Ponca City, OK. Jeffrey D. Meyers is a retiree of the ConocoPhillips Ponca City Refinery, where he was the environmental director. E-mail:
Sara.L.King@ ConocoPhillips.com.
This article presents the approach developed by the ConocoPhillips Ponca City
Refinery (PCR) for implementing a sustainable Title V air permit compliance system
and the process for compliance verification (CV) at the lowest cost possible.
Development and Implementation of a
Title V Compliance Verification Process
One of the biggest challenges under the Title V Air Permitting program is performing a “reasonable inquiry” into the compliance status of each Title V permit requirement and then reporting deviations to the regulatory agency semiannually. The potential for serious enforcement reinforces the importance of developing a sustainable system to effectively communicate Title V obligations to those account-able and a process to verify compliance and iden-tify deviations. The simple spreadsheet-based system developed by PCR performs the functions necessary to integrate environmental obligations into plant operations and then quickly verify compliance status in preparation for Title V deviation reporting.
Process units operating at the Ponca City Refinery, photo courtesy of ConocoPhillips.
Use Existing Systems
PCR initially considered commercially available, all-in-one software, but chose a simpler approach that was more easily integrated into plant operations and maintained by on-site staff.
The refinery already supported several robust systems:
• Distributed control system (DCS)
• Maintenance scheduling and tracking system (SAP) • Automated plant information system (OSIsoft PI
System Datalink “PI-Datalink”)
• Electronic workflow system and electronic docu-ment managedocu-ment system (Livelink)
• Operations information system (AspenTech Operations Manager—Role Based Visualization) • Emission inventory calculation application
(inter-nally developed)
• Microsoft Office system programs Distribute Accountability
Plant personnel were empowered with the knowl-edge, accountability, and compliance tracking tools
ConocoPhillips Ponca City Refinery
PCR is a 187,000-barrel-per-day oil refinery operat-ing crude toppoperat-ing units, catalytic crackoperat-ing units, a coker, reformers, hydrotreaters, an alkylation unit, amine gas treaters, steam- and hydrogen-generating units, a wastewater treatment plant, and feed-stock and product storage. Equipment having environ-mental obligations includes 35 stack emission points (10 of which are equipped with continuous emission monitoring systems), 4 flares, 50,000 fugitive piping component emission sources, and 60 above-ground storage tanks subject to floating roof inspections. Individual applicable regulatory requirements num-ber into the tens of thousands.
The general types of Title V Permit obligations applicable to the refinery include stack emission limits, leak monitoring, tank inspections, emissions testing, reporting, and recordkeeping. A robust system is needed to ensure ownership of environ-mental obligations by those who actually control the outcome. A process is also needed to ensure deviations from Title V Permit obligations are identified for inclusion in the required compliance status reports.
Fundamental Principles
PCR followed the six criteria described below in designing its Title V compliance verification process: 1. Use Existing Systems: No new enterprise soft-ware system or customized vendor applications; use existing systems and processes.
2. Distribute Accountability: Ensure accountability resides with those who control the outcome, minimizing the amount of work for any one individual.
3. Alignment: Align with day-to-day refinery operations, processes, and procedures.
4. Minimize Work for Title V Reporting: Create an efficient process for verifying compliance. 5. Involve Plant Personnel: Involve plant personnel
in Title V certification reasonable inquiry process. 6. Sustainability: Use sustainable system
compo-nents and minimal resources.
Figure 1. Phase 1 project development steps.
Organize Requirements Summary spreadsheets by Area & Program
Add consolidated federal, state & permit obligations
Add task owners
Add supporting compliance tools: • Short-term limit DCS tags & alarms • Long-term limit tracking spreadsheets • Work practice procedures
• Sampling, testing, and reporting notifications & procedures
Review short-term limit DCS tag attributes: • Short-term limit DCS tags & alarms • Algorithms
• Alarm setpoints • Data compression settings
Review draft Requirements Summary and supporting compliance tools with end users to solicit feedback
Implement Requirements Summary and supporting compliance tools
to manage their own environmental process unit constraints. Accountable plant personnel included unit operators, unit engineers, shift supervisors, analyzer technicians, equipment inspectors, and environmental staff.
Alignment
As much as possible, existing operational spread-sheets, reports, processes, and systems were used to embed environmental constraints, environmental
maintenance, testing, or sampling requirements, and emission tracking tools into the normal work processes of the refinery. This strategy significantly improved acceptance and integration of environ-mental obligations into day-to-day plant operations. Minimize Work for Title V Reporting
For the wide variety of tasks required at PCR, both real-time monitoring and periodic auditing approaches were employed as part of a successful CV process. Many numerical environmental limits were already monitored real-time in process unit control rooms on DCS consoles. Advisory warning alarms were set up to allow plant personnel to make process adjustments before environmental limits are reached. For other environmental obligations, periodic auditing was deemed to be adequate. The periodic auditing process was automated using the refinery’s existing workflow process automation
Figure 2. Abbreviated requirements summary table.
Figure 3. Example requirements summary table dashboard page.
USE THE BUTTONS BELOW TO VIEW ASSIGNED TASKS Analyzer Dept Operator Environmental Staff Flare Numeric Limits Tank Numeric Limits
Title V Title V Compliances DCS Compliance Compliance Title V Compliance What Counts as a Permit Equip ID Assigned To Limit/Task Procedures/Tools Follow-up Action Tags Verifier What To Check Deviation Citation Equip A CEMS Anzlyzer CEMS CGA: CGA spreadsheets If CGA relative none Maintenance Review CEMS & Deviation if one or Permit Equip B CEMS Dept Conduct and instructions accuracy is more Manager COMS maintenance more of the following Specfic
Cylinder Gas located in electronic than X%, contact logs in electronic occurs: -Adjustment Condition X Audit folder XXX. SAP Env Staff, repair folder XXX or repair not made
PPM work order is CEMS, and redo after daily autocal generated each CGA exceeded the criteria quarter summarized in the
QA/QC Plan Appedix A. -CEMS not recalibrated after each daily autocal faliure. Tank A Env Staff Storage Tank Tank dimensions none none Area Lead Review records Deviation if any Permit
Env Records: are located in of tank dimension records of tank Specfic Maintain a electronic document and analysis of dimension or analysis Condition X record of management system. capacity. of capacity are not
dimension and available. analysis of
capacity for life of storage vessel.
Fuel gas CEMS Operator Fuel Gas H2S Monitor DCS Alarms Contact Production 3-hr avg tag=XXX Area Lead Review daily Deviation when limit Permit Limit: X ppmv Mgr and enter Warning alarm at X environmental was exceeded Specfic (X-hrolling avg incident: tracking Warning alarm at X reports and Condition X calc’d hourly on report Exceed alarm at incident notification
the hour) 100% of limit system metrics for See notes. excess emissions
Equip A Env Staff Agency Notices Reminder is in none none Area Lead Identify newly Deviation for notice Permit Equip B for Construction the Environmental installed or modified that was not submitted Specfic
& Startup: Reporting Calendar equipment in the on time or did not Condition X Submit notices reviewed during last 6 months. contain the required
for construction monthly staff information. and startup meetings Review construction
and startup letters Deviation if the submitted in the construction or previous 6 months startup notices are on file in Env. Library not available.
USE THE BUTTONS BELOW TO VIEW TITLE V WORKFLOW ASSIGNMENTS Analyzer Dept Mgr Operations Mgr Environmental Mgr Link to Deviation Log
system (Livelink). The electronic workflows were set up to send electronic Title V CV checklists to designated plant personnel, who then conduct the necessary “reasonable inquiry,” which is transmit-ted to the environmental staff for efficient and expeditious rollup of Title V compliance status reports.
Involve Plant Personnel
The work products were developed with input from plant personnel and modified based on sug-gestions received during the testing phases of the project. This ensured that environmental tasks were written in the language of the users, assign-ments were made to the most appropriate people, and that existing plant operational work process were identified and properly utilized.
Sustainability
Regardless of which type of system is used for compliance management, it must be kept ever-green to ensure all compliance obligations con-tinue to be met. Each of the system components used in the refinery’s compliance system has an owner responsible for updates. A simple workflow process is utilized by the environmental staff to communicate and remind system component own-ers of updates needed.
Development and Implementation
A project that affects plant-wide operations person-nel requires a long-term vision and clear definition of the end in mind. The project was developed and implemented by in-house staff over the course of five years. Because the project scope occurred over several years, it was important to divide the devel-opment and implementation into small segments so that benefits could be realized along the devel-opment path.
Development of Requirements Summary Tables
Figure 1 provides a summary of the steps used to develop the Requirements Summary Tables. Requirements Summary Tables were created using Microsoft Excel, and organized by refinery areas and programs as separate spreadsheets. An abbreviated Requirements Summary Table is illus-trated in Figure 2.
First, the Requirements Summary Tables were populated with the applicable requirements and owners. Similar or duplicative requirements were consolidated as much as possible. All requirements were rewritten using simple language that end-users understood. Then supporting compliance monitoring tools and procedures were specified. Finally, a dashboard page was added to enable users to quickly search by assigned tasks and by specific pieces of equipment. Figure 3 shows an example Requirements Summary Table dash-board page.
Figure 4. Compliance verification development steps.
Figure 5. Example Title V deviation log.
Add compliance verification information to Requirements Summary Tables: • Assign personnel to verify compliance
• Instructions for what to check • Deviation definitions
Create deviation logs
Develop electronic workflows with Livelink software
Pilot test electronic workflows with end users to solicit feedback
Implement electronic workflows
Requirements
Summary Table Equipment ID Deviation Begin Deviation Begin Deviation Cause of Corrective Action Task ID Date and Time Date and Time Description Deviation Taken
Development of Title V Compliance Verification (CV) Process
Figure 4 provides a summary of the steps used to develop the Title V CV process. Livelink software was used to create automated workflows that powered the process.
First, compliance verifiers and deviation definitions were added to each task in the Requirements Summary Tables. Deviation logs were also created for each operational area and program. Figure 5 shows an example deviation log.
Automated workflows were then created. If steps became late, the workflow automatically sent electronic notifications to the delinquent verifiers. A simplified visual depiction of the CV workflow process is shown in Figure 6. Figure 7 illustrates a
References
1. Beath, J.M. Use Periodic Checks to Demonstrate Title V Compliance; CEP Magazine February 2004.
2. Jenks, R. Mastering Environmental Tasks Using Compliance Management Tools; Chemical Engineering October 2002.
Figure 6. Simplified visual depiction of compliance verification workflow.
Figure 7. Screenshot of workflow assignment from Livelink software. Initiate Electronic Workflow Analyzer Dept Mgr Operations Mgr Environmental Mgr Compile Title V Reports
screenshot of a Livelink workflow assignment page.
Summary
The system developed by PCR performs the func-tions necessary to holistically incorporate environ-mental obligations into day-to-day plant operations and to quickly and efficiently verify compliance status in preparation for Title V deviation reporting. The success of this approach at other locations depends on many relevant factors, including management philosophy, plant size, regulatory complexity, availability of existing systems and applications, and resources available for keeping the system components evergreen.
Several lessons were learned during this process. These include:
1. Successful implementation requires complete management support.
2. Leverage existing systems; don’t over-design with functionality not needed.
3. Plant personnel are more willing to accept environmental information in a familiar format in which they had input on design and content. 4. Develop, pilot test, and implement in small
