Sunoco`S Ecat system uses ESS software to drive title V compliance accountability and efficiency

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Courtesy of IHS

'Managing compliance is a part of everybody's job,' said Patti Johnston, Sunoco's Manager of Health, Environment, Safety and Medical Systems. 'It's simply a requirement of doing business.' Johnston is the project manager for eCAT – the electronic Compliance Assurance Tool that's helping Sunoco stay on track with Title V compliance.

The software that powers Sunoco's eCAT system is Essential Suite™ from ESS. Sunoco uses the following integrated modules: Essential Air™, Essential MSDS Manager™, Essential Chemical Inventory™, Essential Compliance Manager™ and Essential Task Manager™.

Title V of the Clean Air Act, signed into federal law in 1990, requires a comprehensive air pollution control permit for each major source of air emissions – and compliance with the permit is mandatory. It is an ‘umbrella' regulation that consolidates all federal and state requirements into one enforceable document. Most of the permits are hundreds of pages long and contain thousands of individual requirements.

The Title V permit imposes limits on air emissions, work practices to reduce emissions, monitoring and inspections to prove ongoing compliance, and self-reporting of any noncompliance. The federal and state environmental agencies then use these detailed reports to audit how well the plant has complied, and to penalize non-compliance. 'eCAT is Sunoco's system for documenting, managing and reporting how we are meeting those requirements,' Johnston explained.

The eCAT system tracks the hundreds of thousands of individual tasks that plants must complete to assure Sunoco is in compliance. 'It associates those tasks to the final requirement and assigns an individual person or team to complete each task by a particular date,' Johnston explained. 'That way, each task is assigned to the most appropriate level of accountability.

'By tracking each task, plant managers are assured that each one is being completed in a timely manner – and that enables the managers to feel confident in personally certifying that the reports are 'true and complete' (a requirement of the regulation). In addition to accountability, this individual task assignment provides another benefit, explained Bernie Marshall, Senior Environmental Air Engineer for Sunoco's Haverhill and Neal plants. 'One aspect that often is overlooked is the education eCAT provides,' he said. 'By documenting the requirements and sending tasks to the responsible parties, we are educating those individuals on the environmental requirements. That enables people to reduce the number of deviations in a proactive manner.

'It's the proactive nature of eCAT,' Johnston said, 'that is the system's key – notifying assigned individuals or teams of their required tasks well in advance of the deadline. It also tracks non-compliance, potential deviations and corrective actions. This is one feature that Trish Neuhart, the OEMS coordinator at Sunoco's Toledo, Ohio refinery, really appreciates.

'With eCAT's end-user access and tracking tools, we went from having a major non-conformance during our last Sunoco corporate audit to being part of a best practice in centralizing data.'

The automated tracking is also a time saver. Paul Persing, a Sunoco Environmental Engineer, said the company's Frankford, Pennsylvania chemicals plant uses the system to prepare its semi-annual deviation reports and the annual certifications required for Title V compliance. 'It definitely saves time,' Persing said. 'It automatically rolls up data from many users and allows me to complete a deviation report in a couple of days that used to take me weeks.'

Jennifer Forbes, Environmental Engineer for the Delaware Valley Chemicals organization, agreed that eCAT is efficient. 'It pulls the data I need, performs the calculations and spits out the results in an easy-to-read report,' she said.

But Forbes, who is helping the Epsilon plant roll out the Air Module portion of eCAT, noted that the system's construction required a lot of research and effort to ensure it would be accurate. 'The saying ‘an ounce of prevention is worth a pound of cure' holds true for the Air Module,' she noted. 'All of that up front work not only saves hours of staff time, but also enables us to ensure that those calculations are as accurate as possible.'

But eCAT is not just for Title V compliance, Johnston explains. 'The system is generic enough that it can be used to track any kind of business compliance – Health & Safety, Department of Transportation and any other business-related requirements can also be tracked using the system,' she noted.

Persing agreed. 'There are definitely more areas where we can use eCAT,' he said. 'I see more benefits in the future.'

One added benefit is that eCAT provides a way for the business to document its activities, making tasks easily transferable among employees. This helps ensure business continuity as employees change roles or retire. As eCAT continues to roll out across the enterprise, the benefits are becoming more apparent. While Title V compliance is first and foremost, the system also provides well-documented processes, streamlines procedures and reduces costs. And, as additional uses are found, eCAT will continue to prove its value to Sunoco.

'We haven't yet realized the system's full potential,' predicted Persing.

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