Abstract

This paper will describe the role of document management technology in supporting environmental compliance processes in the petroleum industry. Specifically, it will discuss document management in the context of regulatory compliance, environmental management systems and remediation practices.

Regulations such as the Clean Air Act, the Resource Conservation and Recovery Act and the Clean Water Act emphasize the need for petroleum companies to develop an environmental management system (EMS). Benefits of an environmental management system or EMS include a reduction in environmental liability, identification of regulatory requirements, responsiveness to pressure from stakeholders and competitive differentiation via environmental marketing.

Document management is the foundation of an environmental management system. Document management contributes to improved compliance by ensuring that all users have access to the latest information they need, as they need it. Waste disposal procedures are available immediately upon revision, facilitating compliance at the point of waste generation. Training content is updated immediately to ensure that regulatory changes are incorporated in the EH&S curriculum. Permits are easily accessible so that their requirements can be understood and satisfied. Safety requirement can be coordinated and communicated effectively.

In summary, this paper will discuss the challenges petroleum companies face in complying with EH&S regulations and how document management can streamline and improve this process.

Introduction

According to a recent Enforcement Alert, the US Environmental Protection Agency (EPA) Office of Regulatory Enforcement considers the petroleum refining industry a priority sector (Office of Regulatory Enforcem Volume 2, Number 2 EPA 300-N-99-003, April 1999). As such, the agency has increased its compliance assurance and enforcement focus of the petroleum sector.

Over the course of the last two years, regulators in the US have focused on the Clean Air Act Amendments (CAA), the Resource Conservation and Recovery Act (RCRA), and the Clean Water Act (CWA).

In Canada, regulators have focused on pollution prevention and toxic release reporting. The Canadian Environmental Protection Act (CEPA) was proclaimed into law on March 31, 2000. The National Pollutant Release Inventory (NPRI) requires facilities which meet certain criteria to file a report with Environment Canada declaring the amounts of any of the 176 NPRI substances released on site to the environment or transferred off site for treatment or disposal.

Canada also launched the Accelerated Reduction and Elimination of Toxics (ARET) initiative. The ARET program is a multi-stakeholder pollution prevention and abatement initiative involving industry, health and professional organizations, as well as governments across Canada.

CLEAN AIR ACT

The Clean Air Act is of tremendous significance to the petroleum sector. The EPA felt compelled to develop a petroleum refinery strategy based on the estimate that the average refinery emits 422,904 pounds of toxic pollutants annually (based on 1994 Toxic Release Inventory data reporting releases of 67,241,720 pounds). Additionally, refineries emit more volatile organic compounds than the other major industry groups (EPA Enforcement Alert).

EPA's Toxic Release Inventory for 1993 identified 159 refineries. Based on Department of Energy data for 1994, 78 percent of the U.S. crude oil processing capacity is located in just ten states.

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