Enterprise environmental monitoring

Elements for guidelines on strengthening environmental monitoring and reporting by enterprises

Aare Sirendi

Purpose and status of the Guidelines

The current Guidelines serve to help: Public authorities Industrial operators Environmental inspectors Third parties

Enterprise environmental monitoring

Definitions
Enterprise environmental monitoring Operator Quality assurance Quality control

Direct (based on measurements) monitoring

Indirect (based on estimates) evaluation
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Goals of enterprise environmental monitoring

Improved control over impacts on the

environment Higher environmental awareness Increased management responsibility for regulatory compliance Increased cost-effectiveness Increased public access to information
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Types of enterprise environmental monitoring

Operation (process) monitoring
Emissions monitoring Impact monitoring

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Parameters measured
Raw material inputs
Operating conditions Use of raw materials and energy Channeled emissions of waste gases Controlled discharges of waste water

Controlled disposals of solid waste

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Parameters measured (continued)

Diffuse releases to air, water and land
Accidental releases Nuisance level of noise, vibration and odour Process/plant conditions Operation and maintenance of monitoring

equipment Impact on receiving environment

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Overall obligations of the operator

Develop a draft enterprise environmental

monitoring programme Conduct and document monitoring Follow all procedural requirements Perform quality control and quality assurance Follow safety precautions
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Overall obligations of the operator (continued)

Evaluate the performance of the methods of

programme implementation Provide inspectors access to facility and data Operators will not carry out the impact monitoring themselves but are covering its costs

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Role of the public authority

Enterprise environmental monitoring is not meant to replace government supervision Public authorities will be responsible for assessing the correct implementation of the enterprise environmental monitoring programmes Public authorities will consider the costs of data production, analysis and reporting The need for impact monitoring will be considered at the stage of enterprise environmental monitoring programme development

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Main steps involved in programme development

Specifying the goals for enterprise environmental monitoring Stating the responsibilities Identification of the scope of enterprise environmental monitoring Considering the general approach and the monitoring methods available Specifying the technical details of particular standard

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Main steps involved in programme development (continued)

Specifying the monitoring timing requirements of

sampling and measurements Stating clearly the location where samples and measurements are to be taken Stating the operational conditions Including appropriate quality assurance and control requirements
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Main steps involved in programme development (continued)

Defining the recording and reporting

requirements Arrangements for the assessment and reporting of exceptional releases Establish an internal framework to ensure compliance Provide statement of the compliance control procedures and the response in case of noncompliance
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The main quality considerations include:

Traceability of the measurements results
Maintenance of the monitoring system The use of recognised Quality Management

Systems Periodic checks by an external Accredited laboratory

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The main quality considerations include (continued):

Certification of instruments and personnel under

recognised certification schemes Calibration of equipment according to designated techniques Self-certification of monitoring data Participation in laboratory inter-calibrations and other evaluations
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Monitoring approaches complementing or substituting direct measurement of emissions

Surrogate parameters
Cost savings thus greater cost-effectiveness; Reduced complexity; Wider scope: more discharge points can be

monitored for the same or less resource; Sometimes more accurate than direct values;

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Surrogate parameters (continued)

Give an early warning of possible upset

conditions Less disruption to the process operation than direct measurements; Information from several direct measurements may be combined Recovery of corrupted monitoring data.
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Disadvantages of the use of surrogates may include:

The need for calibration against direct measurements; May only be valid for a restricted range of process conditions; May not assure as much public confidence as direct measurements; Sometimes less accurate than direct measurements; May not be valid for legal purposes.

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Mass balances
The emissions are the same order of magnitude as inputs or outputs; The amounts of the substance (input, output, transfer, accumulation) can be readily quantified over a defined period of time.

Estimating emissions by a mass balance is based on the following equation: Total mass into process = accumulations +total mass out of process +uncertainties Inputs = products +transfers +accumulations +emissions +uncertainties
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Calculations MSO2 = Q x C/100 x (64/32) x T Where: MSO2 = Annual load of sulphur dioxide emitted (kg/yr) Q = Fuel mass flow rate (kg/h) C = Concentration of sulphur in fuel (wt%) 64 = Molecular weight of sulphur dioxide emitted (kg/kgmole) 32 = Elemental weight of sulphur in fuel (kg/kg-mole) T = Operating hours (h/yr)
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The disadvantages of using calculations should be taken into account:

They require validation; Scope should correspond to the case studied; Require data that are reliable and specific to the

conditions of the facility; More time consuming and complex than application of emission factors.
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Emission factors
Emission Rate = (kg/h) Emission Factor (kg/kg production or fuel burned) x Activity Data (kg production or fuel burned/h)

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Determination of the timing requirements

Time when samples and/or measurements are

taken; Averaging time; Frequency.

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Averaging time and the frequency depends on the type of the process:

A very stable process A cyclic or a batch process A relatively stable process

A highly variable process

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Optimising costs of enterprise environmental monitoring

Costs associated with enterprise environmental monitoring

Resources to design the system: including staff time, hiring of outside contractors Design and construction of dedicated lines, control loops, wells,sampling ports Laboratory and analytical costs Training of managers Continuous staff training to run the enterprise environmental monitoring programme
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Costs associated with enterprise environmental monitoring (continues)

Sampling Transport of samples Treatment of samples Data processing Distribution of data Hiring of third party contractors to perform parts of the monitoring Modification of the monitoring system Penalties for an inadequate functioning of enterprise environmental monitoring

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Possible actions to optimise costs

Select the appropriate quality performance requirements Optimise the monitoring frequency and match it with the desired accuracy of the results Optimise the number of parameters to be monitored by only considering those that are strictly necessary Consider the use of continuous monitoring only when it provides the requested information at a lower overall monitoring cost than discontinuous monitoring
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Possible actions to optimise costs (continued)

Consider, where possible, replacing expensive parameters with surrogates that are more economical and simpler to monitor Standardize data collection techniques, use to the needs existing procedures and tools of data management and analysis; Consider whether data collection matches the capacity to respond to and capitalize of the information generated Consider complementing routine monitoring by special studies (such as campaign monitoring).
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REPORTING AND RECORD KEEPING

Types of data that should be recorded

All sampling, analyses, measurements,

examinations, calibrations and maintenance carried out in accordance with the permit or the enterprise environmental monitoring programme; All planned changes (alterations or additions) to the permitted installation;

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Types of data that must be recorded (continued)

All incidents which affect the normal operation of

the activity and which may create an environmental risk; All non-compliance cases and self-correction measures; All complaints of an environmental nature related to the operation of the activity. A record shall also be kept of the response made in the case of each complaint.
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The analysis and reporting of results:

Evaluate results, including through a statistical

analysis Assess compliance with regulatory requirements Report and explain results to the authority and the public

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The operator will submit enterprise environmental monitoring data to the competent authority
Periodically, according to a predefined schedule; Immediately, when violations are discovered Upon the request of the competent authority

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Air emissions and air quality monitoring

Conversion to reference standard conditions Normalised data are standardised to a particular temperature and pressure, typically 0 C and 1 atm respectively, although sometimes they may be referenced to 25 C and 1 atm.
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Conversion to Reference Oxygen Concentration

Where:
Er = emission expressed at reference oxygen content

Em = measured emission
Or = reference oxygen content (expressed in percentage)

Om = measured oxygen content (expressed in percentage)

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Approaches to assess compliance

1) the measurements, or a summary statistic estimated from the measurements 2) the uncertainty of the measurements 3) the relevant ELV or equivalent parameter Before assessing compliance, all three items may need conversion.

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The result of this assessment can be assigned to one of three categories:

1. compliant 2. borderline or 3. non-compliant.

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There are two aspects of compliance to be considered:

1. Evidential compliance. This means compliance with requirements to provide adequate monitoring evidence. 2. Compliance with limit values. This means compliance on the basis of monitoring results with requirements for emissions not to exceed numerical limits in permits, or for ambient impacts not to exceed quality standards in receiving environments.

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In order to assess compliance with limit values the following items are necessary:
The limit value for the relevant operating

condition The relevant measured pollutant or parameter value An estimate of the uncertainty in measurements A level of statistical probability or confidence

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Use of enterprise environmental monitoring data for enforcement and public review
Can enterprise environmental monitoring

information be used as a basis for noncompliance actions against the facility?

Enterprise environmental monitoring

programmes should be available for review by the general public

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The End
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