Air Compliance

Air Emissions Data Collection: ‘An Exercise in Futility’

The post discusses the challenges of emissions recording keeping and reporting for industrial manufacturers.

Once again you’re updating air permit spreadsheets—a monthly recordkeeping ritual (if you’re on top of it!) for Environmental Teams that involves pulling data, gathering material usage, and equipment hours, and tracking down paper logs; then manually transferring it all to a set of spreadsheets. While recordkeeping and emissions reporting and compliance are essential to air pollution regulation, they can burden many facilities. The time and resources spent on reporting can detract from what teams really want to focus on, and where they can make the biggest impact: reducing emissions and implementing sustainable practices.

Emissions reporting is an essential component of environmental compliance for many industries. It involves collecting, calculating, and reporting data related to air emissions, including greenhouse gasses, volatile organic compounds (VOCs), and hazardous air pollutants (HAPs). The reporting requirements for emissions can vary depending on the type, size, and location of the facility and the pollutants emitted. 

Requirements are complex 

Title V of the Clean Air Act Amendments requires specific sources of air pollution to obtain permits and comply with emissions limits and other requirements and requires these sources to report their emissions to regulatory agencies annually. While Title V emissions reporting is a crucial component of air pollution regulation in the United States, it is not the only reporting requirement that sources must comply with. Other federal, state, and local reporting programs require sources to report their emissions data. Non-Title V reporting requirements can vary widely in scope and complexity. 

The reporting requirements are highly detailed and technical, requiring sources to accurately measure and report emissions for  volatile organic compounds (VOCs), hazardous air pollutants (HAPs), and greenhouse gasses (GHGs). On top of that, they may be subject to different reporting requirements based on the product line or piece of equipment.  This complexity can make it difficult for sources to understand their reporting obligations and ensure that they are complying with all applicable regulations. 

For example solvent use and surface coating operations are common sources of air emissions that are regulated under air permits at industrial facilities. From paint spray booths to wipe cleaning activities, you might need to monitor your usage of each specific material and use that data to calculate the associated air emissions. For example, you may need to calculate emissions data by things like type of application, type of material, chemical components of the material, or priority pollutants like VOCs. You may need to track those items both in gallons and in pounds, as sums or averages, and compare the emissions to limits that are based on calendar periods (monthly or annually) or rolling periods (12-month rolling) or sometimes both!

Recordkeeping is hard work

Adding to the complexities and burdensome requirements of emissions reporting is a general need for management of emissions data at the site level. To obtain production and material usage quantities necessary for reporting, facilities often rely on data provided to them by operations, pull data from accounting systems, or even rely on manual data input from paper logs or tickets. A significant amount of time, in some cases up to 200 hours per year, is spent just in obtaining this data and then more time is spent further formatting this data to be useful for their reporting needs. 

Monitoring and recordkeeping sound easy enough, but typically requires a substantial monthly investment to compile the data, update the spreadsheets, and run the calculations to determine if operations were within the permitted limits. 

Collecting accurate and reliable data can be a significant challenge for air permits. Data must be managed continuously or periodically to demonstrate compliance with permit limits and requirements. Accurate and reliable data are critical for correctly assessing permit compliance, but it can be challenging to obtain due to instrumentation malfunction, data manipulation, or human error.  EHS record-keeping is not a primary concern for operations staff, who are focused on core production activities. It can be 'like pulling teeth' trying to get operations staff to regularly compile this data.

Spreadsheets are not the answer 

After collecting data, it must be stored properly to ensure its integrity and availability when required. This is when many turn to excel, however Excel is not a data storage system. Managing large amounts of data in a structured manner can be a significant challenge, especially for companies with multiple facilities and permits.

Spreadsheets are also the go-to for running emissions calculations. Permits often require slicing and dicing the data based on the source within the facility; then, there is a need to look at the rolling totals to date. Rolling totals are not a native equation in Excel, and mis-entering the formulas can lead to errors in your emissions reporting.  Last but not least, excel is highly susceptible to human error: miss a cell in that sum and your 12-month total is off.  

Mistakes are costly, and the risk is real

Recently a shoe manufacturer in Minnesota, was fined $30,000 by Minnesota Pollution Control Agency (MPCA) for violation of their air quality permit that occurred in 2020 and 2021. Failure to properly calculate emissions for hazardous air pollutants (HAPS), small and very small particulate matter (PM 10 and PM 2.5), and volatile organic compounds (VOCs) was cited in the violation.  

We’ve built something better

Here at Mapistry, we’ve dissected hundreds of air spreadsheets. We’ve seen formula errors like referring to the wrong emission factor for an emission source, mistakes with unit conversions, typos in formulas & operators, vague notes left by previous employees, and more, making it hard to know whether your spreadsheet is reliable.


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