Environmental Protection

Surfing the Air Emissions Datawave

A system checklist to help environmental managers at industrial facilities avoid the storm

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.

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