Innovation vs Transformation Impacting Emission Monitoring Data Collection and Reporting Decisions (Part III of III)
A quick summary to get you all up to speed in case you haven’t read Parts I and II of this series.
Maintaining emission compliance obligations on top of your regular production responsibilities is becoming more and more complex.
As part of your overall compliance obligation, you must collect and report data to the specified agencies on regular intervals as designated by the applicable rules.
The rules themselves allow affected sources to figure out how best to meet the data collection and reporting requirements needed to demonstrate compliance.
In simpler times, many industrial facilities called on in-house experts to add environmental data collection to their already establish production control software systems.
Over time more and more 3rd party data systems came into the market through CEMS integrators supporting new source requirements, offering integrated CEMS/DAS systems.
New more stringent monitoring requirements under the Acid Rain Program and the NESHAPS/MACT/CPMS rules gave way to software only providers specializing in compliance reporting systems.
Despite the ever-increasing demands to stay compliant with air emission regulations, one must decide if the investment in an innovative home-grown solution is better than transforming their compliance process by using a 3rd party compliance partners’ data acquisition system.
This brings up to date and onto Part III….
Part III: “Lean on Me” Bill Withers Never Sang Truer Words & a Case for a 3rd Party Compliance Partner
In the summer of 2017, I was front row center of the main stage at the Newport Folk Festival to witness a truly exceptional tribute to the late, great Bill Withers. The set was performed by a group that go by the name of Grandma’s Hands Band. They were an eclectic group of talented artists occupying the musical space commonly referred to as the folk/rock sound. Near the end of the set, Justin Vernon and Phil Cook collaborated on guitar and keyboard singing Bill’s classic hit; Lean on Me. They executed the song flawlessly, lyrically reminding us that we all need help from time to time. This is the perfect way for me to close out this all-important series on Innovation vs Transformation and its’ impact on emission monitoring decisions. A compliance partnership, like the song, is all about leaning on each other to solve a common problem.
The Backstory
Big data and how to use it correctly is in the forefront of most every corporate decision these days regardless of industry type. Everything is going digital, migrating to cloud-based IoT, and using outcome-based analytics to help better manage their businesses. With technology moving at breakneck speed and fears of falling behind driving quick decisions, many companies are committing before they have fully vetted out their implementation options. Collection/analysis of large-scale data and the analytics applied to it is only as good as the upfront, process planning that goes into developing it. As companies commit to a big data partner, they introduce another opportunity to use in-house experts to design home grown feeder systems, executed by the data software provider. This environment presents a new wrinkle in the innovation vs transformation environmental discussion.
As reported in Part I of this series, the notion of considering innovation vs transformation impacting emission monitoring data collection and reporting started with a meeting I attended in late 2019. The company that called the meeting was facing a data dilemma. They had a fleet of compliance forward facilities but no data reporting standard in place. The lack of standardization made it difficult for the environmental staff to evaluate data, find anomalies, correct errors and generate reports. They were wrestling with the build vs buy decision when we met. The decision struggle was evident as there were some compelling arguments supporting doing this with existing resources vs partnering with an outside application-specific expert. The “in favor of” drivers included but were not limited to the following:
Corporate level management had already committed and purchased the software and tools to implement a corporate data lake system to be utilized by all the mission critical parts of the organization. The data lake itself was being built by contract software providers, working on department-specific deliverables with key personnel from each business unit. This was a corporate-wide, digital transformation directive that had already been deployed in other areas of the business by the time we met with the Environmental Team in November. The air compliance department was going to be required to participate in this program at some level or another. This was a significant investment and culture shift that could not be bypassed by the risk assessment/environmental decision makers.
In general, the subject organization runs a compliance responsible operation. They have a long history of being a good neighbor and for being forward thinking in how they handled their compliance obligations. Known as early adopters they were held in high regard by industry peers for their proactive approach to meeting the regulations. The only flaw in their program was the lack of data acquisition standardization for reporting. The fleet of plants and the number of regulated sources all manage their emissions data differently. The implementation of a corporate data lake created the opportunity to build a standard to handle their fleetwide air compliance.
The corporate environmental team represents some of the top players in terms of rule knowledge and obligation fulfillment in their core industries. In recent years with the promulgation of more stringent NESHAPS/MACT regulations they were elevated to, what I would call, USEPA stakeholder status. Working directly with the USEPA rule-writers, they used their in-house experts to better define their industry and source-specific data collection and reporting requirements. This is a very progressive approach that few companies are willing to venture into, working directly with the regulators to help craft how the rules will be met. Every detail was challenged, every ambiguity was given clarity and revised standards were built off this effort. The result of their work was to the benefit of all other affected sources within their industry sector.
Very smart people doing very smart things and making a strong argument for innovation along the way. Thinking of all the projects I have seen over the years, it would be hard to say that these folks weren’t capable to build a rock-solid, a home-grown solution. They have the expertise, the tools and the money to pull it off. Even as an outside observer, representing a compliance partner at this meeting it would be hard to argue against them doing this themselves. So why was the meeting called and why the hesitation? Tough questions that boiled down to compliance complexity, incompatible plant to plant data availability, software deployment/implementation challenges and the demand on in-house environmental resources to ensure a properly designed, long term solution. The talent was there to make it happen, but the sheer weight of the task seemed counterproductive as measured against the higher-level compliance mission.
The Decision
The corporate profile of the subject group includes operations in pulp & paper, wood products, gypsum and other related industries. The production mix opens them up to several different air emission rules and regulations depending on industry type and unit ID. Almost every type of manufacturing operation they manage might have one or more rule in play. The compliance demands will vary but the responsibility to comply remains. For example, Pulp & Paper mills fell under 40CFR Part 60 Subpart BB, 40CFR Part 63 Subpart MM, 40CFR Part 63 Subpart DDDDD (Boiler MACT) while Plywood plants had to comply with Title V permits and 40CFR Part 63 Subpart DDDD (Plywood & Composite Wood MACT). Some of this will be satisfied by continuous monitoring of stacks using CEMS while others will be tracked using CPMS systems monitoring pollution control/process parameters and in some cases, manual entry of inspection data may even be required. Challenge on top of challenge trying to figure out how best to bring this together in a cohesive, reliable format.
In addition to not having a standard software platform to collect data from stack monitoring systems, the non-CEMS, CPMS data needed for MACT compliance was often fragmented across several different software systems. Environmental engineers responsible for reporting had a difficult time trying to organize, validate and manage this data across different, incompatible platforms. The process which relies heavily on organizing data in spreadsheets, is inefficient and increases the opportunity for errors. Like peeling an onion, the more the company evaluated their reality against the need, the more layers were uncovered. Transformation was winning over innovation and actions were put into motion to secure a competent, compliance partner.
The data lake providers that were contracted by corporate to take them into the world of digital transformation were experts in platform infrastructure, database configuration and outcome-based analytics. It was assumed that they have had no experience in managing air emissions data for NSPS and/or MACT compliance. The learning curve for them was projected to be steep as well as cost prohibitive, having to pay them hourly while they learned. After careful consideration, the team leaders shifted focus from innovation to transformation choosing to deploy in-house talent towards process improvements and use outside experts in air compliance software solutions to do the heavy lifting at the plant level. In other words, feed the lake with validated and rule qualified data from a standard platform and use the company experts to access it for risk management purposes. Improve workflow efficiencies and accuracy of results through partnership.
The Result
An analysis of the plant by plant data systems revealed a strong pull towards one air emissions DAS vendor over all others. At least 6-facilities out of the fleet of approximately 110 manufacturing plants, operating in roughly 33-States were already doing business with the same vendor. The DAS product reports from the plants were all positive which lead to the meeting that started this story. With this proven performance baseline in front of them, the environmental powers to be decided to invest in the next step and commit to a partnership approach.
By handing over the data acquisition design to a qualified air compliance software partner, the company was able to focus on transforming their resources rather than using them to create a fleetwide, DAS standard. The environmental support team could now efficiently work on data analysis and report generation tasks aimed at improving compliance performance instead of building the underlying compliance engine at the collection level. In the end this proved to be the better path forward. Although the outcome appears to be just about “buy vs build”, it was more about developing trust and creating a true partnership. In my view, you can’t have one without the other. A good product without the backend support and absent of a “we are in this together spirit” is a relationship that will eventually fail.
In this case, both parties became invested in the working solution. To ensure success, the company set out guidelines and deliverable requirements in a specification for their partner to follow. Specifics involving rule interpretations and reporting formats formed the baseline of the scope of supply agreement. The responsibility of bringing the necessary plant data together and feeding it to the data lake was now on the shoulders of the compliance partner. Rather than release a wholesale, fleetwide contract they agreed to test the model at 2-facilities that best represented the profile range of the fleet. One site had a robust, infrastructure that could easily deliver the data to the DAS system through a common portal (PI System) and the other was completely fragmented over several platforms. This test was designed to validate the decision before a full-on commitment. A smart move to the mutual benefit of both parties and a true indicator of my “lean on me” analogy.
The Final Word
The jury is still out on whether this example supports the Transformation over Innovation argument when it comes to emission monitoring data collection and reporting. I plan on reporting back with an update in about 6-months when the test model has been fully proven in the field. If nothing else I had a lot of fun bringing this story to you in 3-parts and hope you enjoyed reading it as much as I did writing it. As always, any feedback, supportive comments or opposing views are welcome. Like my previous posts, my goal is to educate, share relevant experiences and to raise awareness. I sincerely hope I accomplished at least some of that with this series. Thank you and have a compliant day.