Limits and Enhancements on the DAHS and it's use at a facility for the compliance solution

1. www.all4inc.com
Implementing a DAHS for
Compliance with the
Refinery Sector Rule
Eric Swisher | eswisher@all4inc.com | 610-422-1117

2. 2 Your environmental compliance is clearly our business.
Acknowledgements
Adam LaFever | Sr. Engineer
Environmental Systems Corp.
10801 N. Mopac Expwy, Bldg 1, Ste
200 Austin TX 78759
Office: 512-250-7936
www.envirosys.com

3. 3 Your environmental compliance is clearly our business.
❑ Purpose
❑ Infrastructure
❑ Integration
❑ Configuration
❑ Verification
❑ Implementation
Agenda

4. 4 Your environmental compliance is clearly our business.
Purpose
Raw
Data
Compliance
Data
CMS
Operating Data
??
Source: Environmental Systems Corporation 4C Workshop Presentation

5. 5 Your environmental compliance is clearly our business.
Ideal Configuration
CMSDCSHistorian DAHSSpreadsheets
X

6. 6 Your environmental compliance is clearly our business.
The hardware, software, and security platforms that
may limit or enhance the DAHS.
❑ Infrastructure:
❑ IT Security (Firewalls)
❑ Data Transfer (wires, fiberoptic, etc.)
❑ Data Communication Protocols
Infrastructure

7. 7 Your environmental compliance is clearly our business.
Infrastructure
CMS DCS HistorianDAHS
OPC
Modbus
ServerController
Analog
or
Digital
Source: Environmental Systems Corporation 4C Workshop Presentation

8. 8 Your environmental compliance is clearly our business.
The ultimate use of the DAHS at a facility as part of
the compliance solution.
❑ Integration:
❑ Infrastructure Limitations
❑ Process Controls
❑ Operations/Instrumentation
❑ Alarms/Notifications
❑ Reporting
Integration

9. 9 Your environmental compliance is clearly our business.
The process for interpreting the regulatory
requirements in order to build a DAHS-based
compliance approach.
❑ Configuration:
❑ Regulatory Requirements
• Validation, calculation, averaging, quality assurance actives, operational
status, etc.
❑ Documentation
❑ Reporting Database Structure
Configuration

10. 10 Your environmental compliance is clearly our business.
❑ Regulatory Interpretations
❑ Newly Applicable
• 40 CFR Part 63 Subpart CC
• 40 CFR Part 63 Subpart UUU
❑ Existing
• 40 CFR Part 60 Subpart Ja
Configuration

11. 11 Your environmental compliance is clearly our business.
The process by which the DAHS will be evaluated
for correctness and completeness.
❑ Verification:
❑ Data Analysis
❑ Alarm/Notification Review
❑ Report Review
Verification

12. 12 Your environmental compliance is clearly our business.
The process for implementing and delegating the
use of the DAHS.
❑ Implementation:
❑ Training (or Re-training)
❑ DAHS Roll-out
• Manageable Pieces
• Achievable Schedules
Implementation

13. 13 Your environmental compliance is clearly our business.
❑ Infrastructure
❑ Integration
❑ Configuration
❑ Verification
❑ Implementation
Conclusion

14. 14 Your environmental compliance is clearly our business.
Questions?
Eric Swisher
Senior Technical
Manager
(610) 422-1117
eswisher@all4inc.com