First Name: | Erik |
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Last Name: | Feldman |
Email Address: | efeldman@rinconconsultants.com |
Affiliation | Rincon Consultants, Inc |
Subject | Amendments to mandatory Reporting Regulation |
Comment |
General Revisions(2) Require schematics for refineries and oil and gas production facilities Schematics, in general, provide important information and lead to a better understanding the complex operations at refineries and oil and gas production facilities. Requiring schematics can significantly improve a verifiers understanding of a facilities operation and would assist in the development of appropriate Verification and Sampling Plans. Verification (1) Change verification deadline from September 1 to August 1 We believe the verification deadline of September 1 is important to give the verifier sufficient time to conduct the analysis necessary develop appropriate verification and sampling plans and complete thorough facility evaluations and data checks. While we believe the suggested verification streamlining processes are positive suggestions that will help the overall verification process, we do not believe they provide sufficient streamlining to the verification process to justify shortening of the verification deadline by an entire month. The areas that represent the largest time sinks in the verification process are generally related to expanded data sampling, additional data collection, and revisions to reports based on identified non conformances. In our experience many facilities have large teams responsible for the facility operations, data collection, and reporting and significant time is necessary for the scheduling and collaboration necessary complete the site visits, data gathering and report revisions. Shortening the season and changing the deadline from September 1 to August 1 may limit the verification process by affecting the quality of the service and accuracy of data. |
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Original File Name:
Date and Time Comment Was Submitted: 2016-03-11 16:39:45 |
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