Regulatory Updates affecting Part A and B1 Industrial Processes

06/01/2012

Environmental Policy for industrial air emissions in the UK continues to be driven in the main by decisions and directives from the European Council. These in turn are focused on supporting the Thermatic strategies for health improvements (concerns on particulate and NOx) and reducing carbon emissions.
 
Key new initiatives from the European Parliament relating to the health aspects of air pollution are:
 


• the recent adoption of the Industrial Emissions Directive which brings under one umbrella separate requirements from the Waste Incineration Directive (WID), Large Combustion Plant Directive (LCPD) and Integrated Pollution Prevention and Control (IPPC). The implementation of this new directive is unlikely to have major ramifications in the UK since a major driver behind the directive is more consistent implementation of existing directives across the EU and the UK has a good record in this regard. There are likely to be some changes at the edges, particularly related to stand by and medium sized boiler units and the average emission limits (AEL’s) applied to processes as the BREF (Best Available Technique Reference Documents) are revised and made more prescriptive at a European level
 

• the Air Quality Directive which introduces new ambient standards for fine particulate (PM 2.5) and sets standards for NOx. It is likely that the major implication of the directive is in driving initiatives to reduce NOx emissions, although a possible implication of the directive is that Industrial Operators located near areas not meeting PM10 and PM2.5 ambient limits (non-attainment areas) may well face more pressure from regulators to reduce particulate levels.
 

In the UK, changes that are occurring relate mainly to data quality. This supports the Environment Agency’s risk based approach to regulation and self-monitoring rules for industry. The EA is putting increased focus on both these approaches since it results in pragmatic and cost effective outcomes. Adequate quality monitoring data is required to support both objectives and hence there is a general trend to higher quality in data monitoring.
 

The two major schemes to support quality of monitoring are MCERTS: The Environment Agency’s Monitoring Certification scheme and Operator Monitoring Assessment (OMA).
 

In relation to MCERTS, the adoption of Version 3.3 of the performance standards applied to CEMS has resulted in three separate approvals for different types of particulate CEM:
 

• Class 1: QAL1 approved Particulate CEMS with appropriate reference materials and QAL3 features to satisfy EN 14181, tested against EN 15267-3.
• Class 2: Filter dust CEMS, approved for particulate measurement in mg/m3 in processes where EN 14181 is not applied (eg metals, minerals, chemical and food industries) tested against EN 15859
• Class 3: Filter leak CEMS, approved for monitoring the condition of dust arrestment plant and providing alarms for monitoring changes in emissions (tested against EN 15859). These types of instruments are often used in smaller bagfilters to help plant minimise and detect emission (ie failure) events.
 

To support industrial operators in meeting these latest requirements, PCME has had instruments tested against the latest MCERTS Version 3.3 performance standards and can offer a range of products to meet these different approvals.
 

The OMA scheme is now operating against a new Version 3 protocol in which Part A Industrial Processes (regulated by the Environment Agency) are audited every four years to ensure provisions for monitoring emissions to air and water are ‘fit for purpose’ and of adequate quality. The audit focuses on the quality of monitoring in terms of management, correct equipment, ongoing operation and maintenance of CEMS, correct location and corrective actions taken, based on the use of emissions data. Plants with high quality monitoring provisions end up with higher OMA scores and are rewarded with less regulatory attention in other areas, on the basis that the operating procedures around understanding and minimising emissions at the site level can be relied upon.
 

This combination of OMA assessments and MCERTS approvals is improving the quality of emissions data obtained in the plant and giving emphasis to high quality monitoring and appropriate field service support.

Archive 2012