Innovation vs Transformation Impacting Emission Monitoring Data Collection and Reporting Decisions (Part II of III)

In Part I of “Innovation vs Transformation Impacting Emission Monitoring Data Collection and Reporting” I presented the argument that these concepts are similar but different depending on circumstances and the decisions to be made in support of continuous improvements.  In the context of this article I associated innovation with “build” solutions using in-house resources to create, invent, modify something to solve a problem and transformation with “buy” solutions that requires integration of newly purchased tools into existing processes.  Both solve problems but each, challenge the decision determination process differently.  I presented cases where the lines of division are more clearly defined in both a production/operational situation as well as a simple environmental example. This left us with a more complex decision-making challenge, to figure out if air compliance data is better served through in-house innovation efforts or by using procedural transformation to support a commercially available, DAS software purchase.  On to Part II for more insights.

Part II: The Wind in the Willows & Building an In-House Data Acquisition System for Air Compliance

One of my favorite literary memories of my youth came from reading the Wind in the Willows by Kenneth Grahame. The friendship and antics of Mole, Rat and Mr. Toad entertained me and my siblings many a night before bed and carried us through our own adventures by day.  The story of these three and the lessons they learned along the way came to mind as I was developing the second part of this three-part series about Innovation vs Transformation.  Unity, friendship and loyalty survived the consequences of the decisions made with each adventure taken.  With no sustainable damage done by any of the choices gone awry, the characters grew and, in the end, found balance through their working relationship.  Life improved by applying lessons learned to the next opportunity.

I have seen similar well intended ventures, a few undesirable outcomes and plenty of pulling together to salvage many a poor compliance decision, over the years. This is especially true when that decision involves the development of an in- house data acquisition system for air compliance and the long-term health of a company’s compliance obligations.  Any source affected by NSPS, NESHAPS, Acid Rain Program and any number of other emissions monitoring regulations must collect and report data to the governing regulatory agency in order to demonstrate that they comply with the applicable rules.  These requirements are spelled out and defined in the regulations and in the site-specific operating permit.  What is not mandated is the software mechanism that the end user must use to meet the requirements.  This nuance in the regulations leaves the door open for affected companies to decide whether to innovate or transform their reporting systems to meet the requirements.  Sources can either build their own system or purchase a 3rd party data acquisition and handling software system to do the job.  Either solution may work but one may work better than the other when measured against the larger picture of maintaining ongoing compliance. The choice is yours.

Manufacturing procedures and the equipment used to efficiently run industrial operations is an intricate dance choreographed by a team of intelligent, creative people from the management offices through the shop floor.  Maximizing production while minimizing errors is an art form carried out in precise fashion by in-house experts required to safely execute each aspect of the production line, day after day. Managing US manufacturing facilities that use processes supported by fossil fuel burning operations is significantly more challenging because of emission (byproducts of combustion) regulations. It forces organizations to figure out how to integrate another level of expertise into the process, having to meet production objectives while maintaining permitted emission output, at the same time. It is a resource prioritization decision that gets further complicated with each new regulation and change to permit conditions demanding more and more stringent control of emissions.

In the early days of compliance when continuous monitoring was kept relatively simple under NSPS, it was not unusual for us to see reasonably functioning, home-grown reporting systems.  After over 30-years in the air emissions and compliance community, I have found that most organizations have people on staff that are intelligent and talented enough to build a compliance data acquisition system that works.  Typically, the same people that are responsible for automating their operations within the available framework of Distributed Control Systems (DCS), Historians and other software tools used to manage production, can adapt one or the other to meet air emissions data collection and reporting.  Good people doing good work trying their best to keep up with regulations within a culture built for process improvement.

As things changed and environmental demands became more complex, the challenge of keeping up started to outweigh the in-house effort.  A crossroad had been reached and a broader view was required. Historically this shift gave way to several continuous emission monitoring system (CEMS) integrators to begin dabbling in the development of stand-alone, data acquisition software products.  As CEMS were being delivered to satisfy new source monitoring requirements, end users started migrating towards outside data solutions.  Finally, with the more stringent demands put on power producers under the Acid Rain program the industry gave birth to software only providers offering turnkey DAS or DAHS systems. Still home-grown systems survived in many cases but clearly a paradigm shift was in the works.

In today’s market NESHAPS, MACT Compliance and CPMS monitoring of sources has upped the ante on justifying the building and maintaining of in-house, compliance, data acquisition solutions.  Innovation using the available onsite tools is still an option, but it is becoming less attractive for the long-term health of the company.  I think we all agree that environmental compliance is a unique avenue in the overall scheme of US manufacturing. It challenges companies to figure out how best to apply resources to solve problems. As companies move closer and closer to digital transformation in their business operations and IOT solutions to support production, they must ask themselves: are we better served looking outside for support using problem specific experts or should we be like Mr. Toad and keep pushing our available “machines” into new adventures? When it comes to data acquisition for meeting emissions obligations, at what point does in-house innovation stop making sense and procedural transformation using proven, 3rd party solutions become the right path forward? Is there an easy, one size fits all answer, or will it remain a plant by plant decision? How does one decide?

Questions, we will chew on and address in Part III: “Lean on Me” Bill Withers Never Sang More Powerful Words & a Case for a 3rd Party Compliance Partner - the final chapter of the series.