Sunoco uses its eCAT system powered by Essential Suite software to manage compliance with Title V of the Clean Air Act. eCAT tracks the hundreds of thousands of tasks required to comply with Title V permits and assigns them to individuals, improving accountability. It allows Sunoco to identify compliance requirements, communicate tasks, and track their completion, catching noncompliance early. Using eCAT has helped Sunoco reduce deviations and pass corporate audits, saving time on reporting which used to take weeks but now takes days. While initially focused on Title V, eCAT can also track requirements for health, safety, and other business areas.

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Oil & Gas Industry
Sunoco’s eCAT System Uses ESS Software to Drive
Title V Compliance Accountability and Efficiency
“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 SuiteTM
from ESS. Sunoco uses the following
integrated modules: Essential AirTM
, Essential MSDS ManagerTM
, Essential Chemical InventoryTM
,
Essential Compliance ManagerTM
and Essential Task ManagerTM
.
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 Challenge
• Avoid risks of non-compliance with
Title V of the Clean Air Act
• Streamline compliance processes for
efficiency and effectiveness
The Solution
• Essential AirTM
• Essential MSDS ManagerTM
• Essential Chemical InventoryTM
• Essential Compliance ManagerTM
• Essential Task ManagerTM
The Results
• Identifies all Title V requirements and
communicates hundreds of thousands of
task assignments
• Tracks tasks to completion – catching
noncompliance and deviations, and
enabling corrective actions
• Saves time – enabling completion of
reports within days instead of weeks
• Improved internal corporate audit result
from non-conformance to “best practice”
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
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2. Sunoco’s eCAT System Uses Essential Suite
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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.
* This case study is adapted from an article in Inside Sunoco, Summer 2006 edition.
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