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Regulators Consider Expanding Telemetry

Regulators Consider Expanding Telemetry

One need look no farther than the smart home innovations commercialized through Amazon’s Alexa and the “internet of things” to know that technology allows us to monitor and manage remotely what formerly required on-site access. That ability to monitor systems remotely applies to commercial and office buildings just as it applies to residential properties. And it applies to the monitoring of remediation system and industrial treatment process efficiency just as it applies to monitoring security systems and appliances

The MassDEP is currently evaluating and soliciting comments on an idea to collect real-time performance data on the operation of subslab depressurization systems (SSDS) also referred to as Active Exposure Pathway Mitigation Measures (AEPMMs). These systems, installed at contaminated sites to assure that subfloor contaminant vapors do not migrate into indoor air, are often part of more comprehensive closure plans. MassDEP currently requires telemetry to provide immediate notification to both MassDEP and the owner and operator of a building protected by an approved AEPMM upon failure of the AEPMM, as a result of loss of power, mechanical failure or other significant disruption of the system that may diminish system effectiveness. To date, the information provided to MassDEP through telemetry is limited to system power status, but MassDEP is considering expanding the requirements of its program to require system operators to provide real-time system operation performance information. MassDEP believes this performance information could be used to confirm that the systems are operating in accordance with specified parameters and that the system is operating as intended.

Expansion of the use of telemetry to monitor SSDS/AEPMM has obvious implications for those who operate these systems. It also has implications beyond SSDS/AEPMMs. If the logical extension of SSDS/AEPMM monitoring is from simple system power telemetry to real-time performance measurements, why stop there?

Loureiro currently works with numerous clients to automate systems. Such systems include, but are not limited to remediation systems used to extract and treat contaminants from groundwater, soil, or air; industrial plating processes, industrial wastewater pretreatment systems; and Publicly Owned Treatment Works (POTWs) treating influent wastewaters from significant industrial users (SIUs). Monitoring systems have become standard for industrial wastewater systems with permitted discharges to remain protective of the waters of the United States, including surface water bodies, groundwater aquifers, wetlands, as well as to remain protective of POTWs. These permitted discharges extend pollution control programs implemented by the Environmental Protection Agency (EPA) under the Safe Drinking Water Act (SDWA) and the Clean Water Act (CWA) for industrial plants; more specifically, the National Pollutant Discharge Elimination System (NPDES) permit control program, comprising the National Pretreatment Program. In many cases, our systems allow our clients to monitor system performance remotely, providing real-time information and alerts, which allows them to manage equipment failure, upsets, or other system abnormalities.
It would be easy enough to transmit this same information to a regulator or to provide a regulator access to the same telemetry systems to monitor regulated system performance. But what are the implications of providing such information and access to real-time data to regulators? Are regulatory agencies prepared to evaluate and use the massive volume of information that these systems can provide? Some examples of the potential challenges:

  • Over- notification: Recent storms interrupted electricity at several residential properties fitted with SSDS triggering telemetry to notify Loureiro (and the MassDEP) of repeated, short-term shutdown, and restart conditions.
  • Improper notification: Water flow sensor communicating to remote telemetry system fell out of calibration reporting a false wastewater discharge flow reading to operators. In these instances, if real-time flows or notification when flows exceed the limits were required by the State for permitted wastewater discharge systems, the State could be improperly notified of a permit exceedance, placing a site in a permit incompliance situation when in reality there was simply a monitoring unit malfunction.
  • Notification management: Given the possibilities of over-notification and improper notification scenarios that could occur with the far-reaching monitoring and data transmission capabilities of telemetry systems, unless there is a dedicated team on standby for a system operator that will confirm the root causes of every system notification, management of system notification could pose arduous, complicating system operation/monitoring and could lead to uncertainties of the true chronology of system notifications, if assistance from a dedicated team is not enlisted.

Loureiro is working with our clients and regulators to understand and make sensible decisions around the opportunities that technology affords with respect to transmitting real-time information.  As we continue to innovate and leverage technology to make our systems smarter, more efficient, and safer, we are also keeping an eye on the implications of such technological advantages.  Is it appropriate for a regulator to have real-time information when that regulator may not be aware of other factors at hand?  Will the availability to real-time information alter how system performance, and ultimately enforcement decisions are evaluated?  Finding solutions will be challenging and will involve participation of a variety of interested and affected parties including industry, regulators, and the public.  Solutions will be harder to find than simply “asking Alexa”.

Edwin Muniz & Matt Quaranta
Loureiro Engineering Associates, Inc.

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