(126b) Improving the Process of Certifying Title V Compliance at a Refinery Marketing Terminal

Verifying and certifying compliance with Title V permitting requirements can be a labor intensive, hurried, and often inefficient process that places facility management at personal and professional risk. This is especially true for facilities that have recently changed hands or which are undergoing significant upgrades or changes, which is the case at many U.S. refineries today.

At the request of Western Refining Environmental Management, Zephyr Environmental Corporation performed a work process improvement pilot study for the Western Refining Marketing Terminal facility in El Paso. The study documented work processes associated with managing and verifying compliance with the Title V permit at the Marketing Terminal, with a focus on the compliance certification and deviation reporting processes. The ultimate goal of the work process analysis was to develop recommendations to improve the efficiency and effectiveness of work processes and tools related to Title V compliance; thereby, reducing time spent managing compliance information, creating reports, and completing the Title V certification process. The overall results of this successful pilot study with examples of key work products are presented.