This document discusses implementing a Digital Automated Handling System (DAHS) for compliance with the Refinery Sector Rule. It outlines the purpose, infrastructure, integration, configuration, verification and implementation of a DAHS. The DAHS would integrate data from control systems, historians and spreadsheets to compile compliance data from raw operating data. It also discusses regulatory requirements, infrastructure limitations, process controls integration, and training personnel to use the new system.

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