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

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.

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.

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.

This article originally appeared in the 11/01/2007 issue of Environmental Protection.