Over the past 20 years UK regulatory bodies have taken a proactive stance in developing pragmatic and innovative approaches to industrial emissions control. Certainly in the field of Emission Monitoring the UK has taken an influential role in developing an approach which, when looking at the international stage, may be considered as best practice. There has been no hint of ‘gold plating’ requirements emanating from the EU, in fact quite the opposite, the approach has been to improve and make them cost effective and practical.
Monitoring of emissions from industrial processes is now common practice and in the past few years, new European standards have been developed and adopted in the UK to improve the quality of emission monitoring data.
The regulatory scene
Industrial plant with the most potential to pollute to air, water and waste in the UK, as in the rest of the EU, tend to fall under the scope of EU directives. The recently adopted Industrial Emissions Directive (IED), harmonises requirements across the EU (with more prescriptive BREF guidance) and integrates and supersedes the requirements of the Integrated Pollution Prevention Control (IPPC) Directive, Large Combustion Plant Directive (LCPD) and Waste Incineration Directive (WID). The IED continues to adopt many of the philosophies used in the UK such as permits which consider emission limits and monitoring requirements in light of Best Available Techniques (BAT) with central guidance on what should be considered as industry specific BAT. In the UK, plants are categorised as Part A1, A2 or Part B and are regulated by the following agencies:
In support of the extensive experience and practice on regulating industrial processes, the UK has developed pragmatic approaches that supplement the requirements emanating from Europe focussing on practical implementation issues. This guidance ensures that the limited process and regulatory resources are used as effectively as possible in minimising pollution and may have relevance to other countries where there are insufficient industrial bases or resources to document and provide guidance on practical experience.
In the UK as in all Member EU states, we use European (EN) Standards as the basis for most emissions monitoring requirements. If there is a European standard, this must be applied and only in the cases where there is no EN standard the following hierarchy has to be followed:
• Comité Européen de Normalisation (CEN)
• International Organization for Standardization (ISO)
If the substance cannot be monitored using standards covered by the above, then a method can be selected from any one of the following:
• American Society for Testing and Materials (ASTM)
• Association Francaise de Normalisation (AFNOR)
• British Standards Institution (BSI)
• Deutsches Institute fur Normung (DIN)
• United States Environmental Protection Agency (US EPA)
• Verein Deustcher Ingenieure (VDI)
The UK is active in ensuring that appropriate standards are developed and used.
British Standards EH2/1 committee sends UK experts to participate in CEN-TC264 working groups where EN standards are developed. Fortunately, in the UK there are a significant number of professionals (from test houses, regulators, process operators, consultants and suppliers) who are active within this process meaning the UK’s technical experience and culture for ‘open’, standards are well represented in the standards making process. Refer Standards update article.
However, to complement this activity the EA, in co-operation with the STA, publishes Method Implementation documents (MIDS), providing guidance on how the UK interprets the standard and providing critical guidance on issues not addressed in the standard. The MID is anything but gold plating. It addresses issues where it has been difficult to obtain agreement across the European working group, and provides pragmatic guidance on detail. For example the EN standard 13284-1 applicable to sampling dust in a stack is ‘silent’ on the issue of filter conditioning ahead of sampling, which recent experience has shown to be important for high quality measurement at low dust. This is now detailed in the MID (which is of value to the UK community effective today) and will be a UK contribution to the CEN standard when it is revised in the future. Where further clarification is required or standards do not exist the EA develops various Technical Guidance notes, available to download from www.mcerts.net
Monitoring whether it be using continuous emission monitoring systems (CEMS) or by manually extractive sampling, the establishment of a good sample location within the stack is a fundamental key.
On new processes it should be very simple i.e. at the engineering stage, design the sample locations after deciding on the criteria of what emissions are to be monitored. However, this is not the case, many times it is overlooked until the plant is built.
On existing processes sampling positions may have been in existence for many years and in most cases are difficult to reposition.
On some installations the requirements have been implemented to the extreme and there are many cases where equipment has been located far up on the stack with the associated cost, health and safety risks.
In 2007 the European Standards Committee CEN 264 published a standard EN15259:2007 Measurement of stationary source emissions -Requirements for measurement sections and sites and for the measurement objective, plan and report. The standard was many years in development with the UK taking a very active role.
The standard defines requirements for:
a) the measurement sections and sites at waste gas ducts of industrial plants, and
b) the measurement objective, plan and report
It is intended to ensure reliable and comparable results when used in conjunction with reference methods such as those that have been developed by CEN/TC 264.
The standard is important to plant designers, constructors, plant operators, testing laboratories, accreditation bodies and regulators and requires the specification of a measurement objective.
One major effect of the introduction of this standard all companies carrying out stack emission monitoring under ISO17025 accreditation through Europe have had to comply fully with this standard.
Two years ago saw the revision of the European standard BS EN 14181, first published in 2004, to provide formal quality assurance procedures to be applied to CEMs on all processes falling under Industrial Emissions Directive, IED.
The principles of BS EN 14181 are relatively simple in that suitable monitoring equipment is installed; it is set up correctly, calibrated effectively and monitored over time to ensure the derived calibration function maintains its validity and suitable checks are made. The outcome of this is to increase both the accuracy and precision of the installed instrument, thus increasing the confidence in the results it reports and ultimately reducing the potential requirement for additional specialist monitoring to verify the performance of the process.
Despite this relatively simple overview the processes involved in the execution of BS EN 14181 are quite complex and vary depending on the installation, the instrumentation and the industrial process operator. During the initial years of the introduction of the standard, stack emissions monitoring organisations performing EN 14181 work have been doing so outside the scope of ISO/IEC 17025 accreditation, and both industry and the Environment Agency had seen very variable quality in the way this work has been implemented, resulting in some extreme cases whereby a perfectly functional CEM has been condemned as mal-functioning due to basic misunderstandings of both the EN 14181 processes and the installation that was being monitored.
One of the most important aspects of EN14181 is the functionality tests, part of QAL2 and AST.
Reporting functional tests
EN 14181 specifies within QAL2 and the AST that CEMs must have a set of annual functional tests. The functional tests may be performed by the operator, test laboratory, CEMs supplier, or another third-party.
The functional tests include linearity, response time and zero / span checks.
Functional test results should be reported using a form that meets the requirements of Environment Agency Technical Guidance Note M20 and EN 14181.
UKAS working in partnership with the Environment Agency under the MCERTS scheme to defined accreditation criteria to ISO/IEC 17025 for stack emissions monitoring organisations that perform and offer a service to verify and calibrate CEMS in accordance with BS EN 14181. The Environment Agency made it mandatory that calibration being carried out to BS EN14181 must be by accredited organisation in England. For more details, visit http://www.s-t-a.org/en14181/.
Operator Monitoring Assessment (OMA)
The Environment agency (EA) have introduced Operator Monitoring Assessment (OMA) to strengthen our assessment of operators’ self-monitoring arrangements. OMA applies to the monitoring of emissions to air and discharges to water from industrial processes regulated under the Environmental Permitting Regulations (EPR) and takes place at least every 4 years.
The EA use OMA to:
• assess operators’ self-monitoring (including monitoring undertaken on behalf of operators by contractors) using a consistent and transparent approach
• provide a driver for necessary improvements
• contribute to targeting and prioritising our independent auditing of water and air monitoring. MCERTS schemes
Full details are available from www.mcerts.net
The EA signposts to plant operators the quality of monitoring it considers appropriate for regulatory compliance though the implementation of the MCERTS scheme. Whether it be for stack sampling, Continuous Emission Monitoring (CEMs), effluent monitoring, portable measurements and 5 other areas, the MCERTS schemes provides 3rd party assurance that minimum appropriate standards are being used by personnel and equipment meets minimum performance standards.
MCERTS is an enhancement of existing European and international quality/technical standards and provides international relevance to industrial regulation in other parts of the world.
Published: 06th Sep 2016 in AWE International