Surfing the Air Emissions Datawave
A system checklist to help environmental managers at industrial facilities avoid the storm
- By Bill Forbes
- Nov 19, 2007
As communities and governments
around the globe strive to minimize
environmental impact, regulators
and industries are seeking new
market-driven programs to reduce emissions
and meet clean air objectives. In
the 1990s, the U.S. Environmental Protection
Agency set about to improve air
quality with the establishment of Clean
Air Act Amendments (CAAA). These
amendments defined an operating permits
program and requirements for
“enhanced monitoring” of compliance.
In the same decade, the EPA went a step
further and introduced the first emissions
cap and trade program to achieve
significant reductions of sulphur dioxide
(SOx) emissions. Since that time, numerous
regional, national and international
emissions trading programs have been
introduced for nitrogen oxide (NOx),
volatile organic compounds (VOCs), carbon
dioxide (CO2) and other pollutants.
In 2004, Texas introduced the highly
reactive volatile organic compound
(HRVOC) monitoring and trading program to address air quality concerns in
the Houston non-attainment area. Like
other emissions trading programs, the
HRVOC provides economic incentives for
achieving reductions in the emissions.
These emissions trading programs put a
dollar value on traded emissions, which
challenges industries to improve the
accuracy and timeliness of monitoring
and reporting methods. The more effectively
an organization can manage its
portfolio of emissions, the better it can
maximize the value of its assets.
Passive Data Management Approach
In order to reduce compliance costs and
risks, industry commissioned software
tools to streamline the data management
process. These tools do not actively
acquire, evaluate or calculate results, but
instead take a passive approach, relying
on the periodic uploading of preformatted
data into a software tool. The frequency
of upload depends upon the
functionality provided and the availability
of manpower. Uploading and reconciliation
of data is commonly performed on
a weekly or monthly basis.
Less sophisticated passive tools
require that preformatted data be manually
evaluated for missing or bad data. In
some cases, data substitution may be
required before uploading can be performed.
This effort is just as manpowerintensive
as working with spreadsheets
and in fact is often accomplished using
spreadsheets and log forms. More
sophisticated passive applications may
perform data substitution automatically
upon uploading of data. However, data
formatting is still required and may take
a week or more. Once the information
has been uploaded, another week may
be needed for further evaluation and
reconciliation. Finally, the information is
available for end users to create records
and reports both for internal use and for
compliance reporting.
As a result, this passive data management
approach may run a month or
more behind real time, offering only an
“after-the-fact” look at emissions performance.
There is no information available
to assess an organization’s emissions
footprint or portfolio of assets in a
timely manner.
The limitations of these traditional
and passive data management
approaches include:
1. Inaccuracy of information
and reports:
• Manual entry errors
• Importing errors from multiple
data sources, spreadsheets, and
log forms
• Incorrect or inconsistent
calculations
• Use of bad or invalid input
data (lacking complete data
validation or quality assurance)
• Improper or inconsistent data
substitution
2. Lack of timeliness
• Challenge of collecting
information from multiple
people, departments, and
spreadsheets
• Unresolved performance
problems during report
preparation period
• Challenge of incorporating
increasing number of records
and reports
• Month-end, quarter-end, yearend
reporting frequency
3. Inconsistency
• Varied interpretation of
regulations reflected in
Drawbacks of Traditional Data
Management Approach
Traditional air pollution regulations were based on the concept
of command and control. Industry had several options available
to meet emissions performance standards, including:
new process design, new or modified process equipment,
add-on air pollution control devices, or the use of less-polluting
fuels and raw materials.
Determining compliance with these command and control
regulations could be as simple as a periodic stack test. Some
regulations required manufacturers to maintain purchase and
usage records for fuels and raw materials. Others required the
continuous monitoring of process parameters, pollution control
device operating parameters or emissions. Typically,
emissions data was averaged over periods from one hour to
30 days.
In this era, the most common tools used to maintain usage
records and continuous monitoring records were spreadsheets
and log forms. According to a recent report issued by
PriceWaterhouse Coopers, “Getting the Data Right,” spreadsheets
are still a common tool for calculation and reporting.
This “traditional data management system” made use of
data extracted from a Process Data Historian and imported
into spreadsheets. Process and environmental engineers created
and maintained additional spreadsheets and log forms
that acted as manual data collection pools. At the end of the
month, quarter or year, data reconciliation and substitution
would be performed where deemed appropriate. For example,
if data from the process historian indicated the monitor was
down while log forms revealed the process unit was down as
well, no monitor downtime would be reported to the regulatory
agency for that period. Then all of the spreadsheets and log
forms would have to be merged and used to generate the
required report.
As regulations evolved, manufacturers began to recognize
the impact of the new regulatory frameworks on compliance
monitoring costs and risks. More and more effort was needed
to collect, analyze and report emissions data and to support
the data needs of emissions audits. The pressure to address
these new demands for information continued to grow, in
some cases leading to penalties associated with erroneous or
late reports or permit violations (exceeded emission limits).
At the same time, industry was forced to address the risk of
negative publicity due to non-compliance that could lead to
brand erosion. |
spreadsheet creation; varied
consistency across process areas,
a plant or company
• When the spreadsheet creator
departs, so does spreadsheet
consistency
• Process is not sustainable
4. Poor performance information
• Problems identified after-the-fact
• Results shared via after-the-fact
spreadsheet reports
New Market-Based Programs
Demand Faster, Accurate Knowledge
of Performance
The U.S. Acid Rain Program was the first
emission trading program to create a
market that placed dollar values on emissions.
Based on environmental and
health concerns, EPA wanted to achieve
significant reductions in air pollution.
Industry lobbied regulators to adopt
market-based programs to provide them
with the flexibility and incentives to
reduce emissions in the most economically
efficient way.
Of particular concern were regional
ozone problems. To address this concern,
market-based trading programs
were established to reduce NOx and VOC
emissions. Most were emissions capand-
trade programs that mimicked the
Acid Rain Program. Individual facilities
were granted annual allowances based
upon past activities and the annual
allowances were slowly adjusted downward
until the emission reduction targets
were achieved.
Key Benefits of an Active Data Management System
• Reduces the duration of compliance incidences or deviations
• Reduces risk of fines/penalties associated with:
– Compliance incidences or deviations
– Recording errors and incomplete or inaccurate reports
• Increases ability to take corrective action to ensure tighter compliance between
“reporting periods”
• Reduces recordkeeping & reporting costs
• Reduces validation, auditing or mitigation costs
• Increases efficiency and accuracy of corporate governance practices (Sarbanes-
Oxley credits trading)
• Increases the economic value of credits
• Increases corporate-wide visibility to environmental performance |
In 2004, Texas introduced the HRVOC
monitoring and trading program to
address air quality concerns in the
Houston-Galveston-Brazoria ozone nonattainment
area. The new program
introduced some of the most rigorous
emissions monitoring and reporting
requirements in place today. These new
HRVOC regulations require significant
changes in how companies monitor,
test, record, report and trade HRVOC
emissions.
As with the NOx and VOC emissions
programs, companies need to more
accurately assess their emissions portfolio.
Instead of an annual assessment
however, the HRVOC program requires
companies to quickly assess and accurately
record all HRVOC emissions and
related data for 100 percent of operating
time. Manufacturers are required to
assess HRVOC emissions performance
every 15 minutes in order to calculate
the required hourly and daily records
and ensure they are continuously operating
below their emission cap. This
assessment must be performed on all
HRVOC emission sources, including
flares, heaters, valves, cooling towers
and vents.
In addition to timely recording of
HRVOC emissions, companies in the
Houston-Galveston-Brazoria non-attainment
area also participate in the HRVOC
Emissions Cap and Trade (HECT) program.
The HECT program establishes a
mandatory annual HRVOC emissions
cap on all sites within the non-attainment
area. The cap-and-trade program
provides a market-based approach to
emissions reduction, allowing the buying
and selling of emission credits in
order to meet emissions limits. To make
the best emissions credit trading decisions,
companies need an accurate and
up-to-the minute account of their entire
emissions portfolio.
The traditional approach to emissions
management involves complicated data
collection and reporting workflows,
many of which are manpower-intensive
and rely heavily on multiple spreadsheets
and log forms. This approach
lacks the accuracy, timeliness, consistency
and security demanded by the
HRVOC rules.
Key Advantages of an Active Data Management System
Active compliance assurance:
• Real-time assessment of environmental performance
• Rapid response to data quality problems
• Unparalleled accuracy and timeliness of emission information
• Forecasted emissions metrics for buy/sell decision-making
A verifiable and auditable system of record:
• Quality assurance of input data for reduced reporting errors and rework
• Minimization of unauthorized manipulation of results
• Achieves touted “single version of the truth”
• Promotes best practices and ensures consistency
Scalable foundation for the future:
• Provides essential information for emissions trading
• Scalable to thousands of data sources and calculations
• Allows addition or modification of calculations as required by changing regulations |
Even small errors can lead
to inaccurate reporting, missed deadlines,
permit violations, financial penalties,
lost profit and brand erosion. Under
the new market-based system, industry
in Texas needs quick access to up-to-theminute
emissions performance and
process information, which is essential
to making optimal operational and trading
decisions.
Active Environmental Performance
Management Systems
Unlike the traditional and passive data
management approaches, an active
emissions management system
acquires and evaluates data in real
time, calculates emissions, and provides
e-mail alerts, real-time and predictive
emissions performance views and ondemand
reports.
This type of system actively acquires
process and emissions data from a
number of disparate data sources,
including process historians, distributed
control systems, lab information
management systems and analyzers.
Prior to being used in any calculations,
the raw data is quality assured
and validated. Evaluation of the data
is automatically performed to determine
process unit status and monitor
status, based on range checking and
flat-line detection. Based on the results
of data qualification, each reading is
assigned a status of good (use actual
value), bad (don’t use value) or substituted
(as prescribed by rule or permit).
Records are stored in a secure data
warehouse for use in reports and
views, and configurable e-mail alerts
are posted as appropriate. Authorized
users have access via Web browser to
role-based and personalized views
and on-demand, preformatted reports.
Views include historical, real-time
and predictive emissions performance
with selectable aggregations and
time ranges.
Active monitoring and recording systems
allow a company to identify areas
of concern before they cause emission
limit violations, allowing them to maximize
production while staying within
emission limits and to make effective
emissions trading decisions.
End of the Era of Spreadsheets
Corporate governance laws, shareholder
activism and emissions trading
opportunities are changing the way
companies evaluate, record, report and
trade their emissions. No longer will
spreadsheets suffice to withstand the
growing tide of emissions data. Active
data management systems with secure,
annotatable and auditable databases
offer an up-to-the-minute view of emissions
performance. Since they cannot
stand up to the demands of today’s
storm of data and myriad regulatory
requirements, the era of spreadsheets
may well be over. Now is the time to
evaluate how an active environmental
recordkeeping and reporting system can
provide your organization with the
insight to make optimal environmental
management decisions and give executives
confidence in the organization’s
emissions compliance initiatives.
Case Study: HRVOC
Real-time Compliance
One of the world’s top petrochemical producers with major
operations in the Houston area needed to deploy a real-time
environmental management application to meet local, state
and federal regulatory requirements for nitrogen oxides (NOx)
and highly reactive volatile organic compounds (HRVOC),
while taking advantage of the new emissions trading programs.
It sought a solution that would leverage its existing
information technology (IT) infrastructure and support a multisite
emissions performance management solution.
The company put together an internal team with representatives
from four sites, including members of its process engineering,
corporate IT, instrumentation and control, environmental,
analytical and projects divisions. After defining functional
requirements and analyzing proposals from various
firms, the company selected Pavilion Technologies to implement
its comprehensive environmental management solution.
Powered by the Pavilion8® software platform, Pavilion’s
Real-time Environmental Management (REM) Solution provides
a complete, real-time overview of plant environmental performance.
The platform’s scalability, flexibility and ease of integration
with existing business and plant infrastructure provided a
lower total cost of ownership than alternative technologies.
The chemical company implemented Pavilion’s REM at four
sites, affecting 22 process units and managing 420 emissions
sources; flares, cooling towers, vents, process safety valves,
incinerators, furnaces, boilers and engines. The company can
now accurately assess its compliance position across the
exponentially complex set of data sources and regulations. For
example, at one site alone, instead of using an estimated 32
spreadsheets to calculate HRVOC emissions, the company
uses Pavilion’s REM solution to aggregate and calculate 6,500
input variables once per minute, resulting in 10,000 qualityassured
emissions calculations and records.
As a result, the company has achieved its HRVOC monitoring
and trading goals and the following key benefits:
• Reduced risk of non-compliance with state and federal regulations,
and associated fines and penalties
• Unparalleled accuracy and timeliness of emission performance
information
• Maximized value of buying and selling emissions credits
through accurate emission inventory
• Increased scalability to thousands of data sources and
calculations as new regulatory requirements evolve
• Reduced total cost of ownership through the ability to
extend the application to cover new plant assets and changing
emission regulations
• Streamlined deployment based on leveraging the existing IT
and plant infrastructure
The Pavilion application provided an active assessment of
the plants’ environmental performance, enabling the company
to minimize regulatory risks and non-compliance costs, maximize
value in emissions trading markets and reduce environmental
impact. The solution provides real-time visibility into all
aspects of emissions performance. The company also has an
accurate account of its emissions portfolio across multiple
sites, arming executives with the ability to make the best emissions
trades and maximize the value of its emission credits. |
This article originally appeared in the 11/01/2007 issue of Environmental Protection.
About the Author
Bill Forbes is a senior application engineer at Pavilion Technologies. Forbes has worked for the past 13 years with leaders in the process industries to achieve production and environmental compliance goals, including the recent deployment of Pavilion’s active environmental performance management solutions for multiple petrochemical companies in the Houston-Galveston area to achieve HRVOC compliance goals. He holds an M.S. in engineering from the University of Texas in Austin.