Enterprise environmental monitoring Elements for guidelines on strengthening environmental monitoring and reporting by enterprises Aare Sirendi

Enterprise environmental monitoringEnterprise environmental monitoring

Elements for guidelines on strengthening environmental monitoring and reporting

by enterprises

Aare Sirendi

Enterprise environmental monitoring 2

Purpose and status of the Guidelines Purpose and status of the Guidelines

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


DefinitionsDefinitions

Enterprise environmental monitoring Operator Quality assurance Quality control Direct (based on measurements) monitoring Indirect (based on estimates) evaluation


Goals of enterprise environmental monitoring 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


Types of enterprise environmental monitoringTypes of enterprise environmental monitoring

Operation (process) monitoring Emissions monitoring Impact monitoring


Parameters measuredParameters 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


Parameters measured (continued)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


Overall obligations of the operator 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


Overall obligations of the operator (continued)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


Role of the public authorityRole 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


Main steps involved in programme developmentMain 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


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




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 non-compliance


The main quality considerations include: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


The main quality considerations include (continued):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

Monitoring approaches complementing or substituting direct measurement of emissions

Monitoring approaches complementing or substituting direct measurement of emissions


Surrogate parametersSurrogate 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;


Surrogate parameters (continued)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.


Disadvantages of the use of surrogates may include: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.


Mass balancesMass 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


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/kg-mole)32 = Elemental weight of sulphur in fuel (kg/kg-mole)T = Operating hours (h/yr)


The disadvantages of using calculations should be taken into account:

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.


Emission factorsEmission factors

Emission Rate = Emission Factor x Activity Data

(kg/h) (kg/kg production or fuel burned)

(kg production or fuel burned/h)


Determination of the timing requirementsDetermination of the timing requirements

Time when samples and/or measurements are taken;

Averaging time; Frequency.


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

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

Optimising costs of enterprise environmental monitoring

Optimising costs of enterprise environmental monitoring


Costs associated with 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 costsTraining of managers Continuous staff training to run the enterprise

environmental monitoring programme


Costs associated with enterprise environmental monitoring (continues)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


Possible actions to optimise costsPossible actions to optimise costs

Select the appropriate quality performance requirementsOptimise the monitoring frequency and match it with the

desired accuracy of the resultsOptimise the number of parameters to be monitored by

only considering those that are strictly necessaryConsider the use of continuous monitoring only when it

provides the requested information at a lower overall monitoring cost than discontinuous monitoring


Possible actions to optimise costs (continued)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).

REPORTING AND RECORD KEEPING REPORTING AND RECORD KEEPING


Types of data that should be recordedTypes 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;


Types of data that must be recorded (continued)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.


The analysis and reporting of results: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


The operator will submit enterprise environmental monitoring data to the competent authority

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


Air emissions and air quality monitoringAir emissions and air quality monitoring

Conversion to reference standard conditions

Normalised data are standardised to a particular temperature and pressure, typically 0 ºC and 1 atm respectively, although sometimes they may be referenced to 25 ºC and 1 atm.


Conversion to Reference Oxygen ConcentrationConversion 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)


Approaches to assess complianceApproaches to assess compliance

1) the measurements, or a summary statistic estimated from the measurements

2) the uncertainty of the measurements3) the relevant ELV or equivalent parameterBefore assessing compliance, all three items may

need conversion.


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

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

1. compliant2. borderline or3. non-compliant.


There are two aspects of compliance to be considered:

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.


In order to assess compliance with limit values the following items are necessary:

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


Use of enterprise environmental monitoring data for enforcement and public review

Use of enterprise environmental monitoring data for enforcement and public review

Can enterprise environmental monitoring information be used as a basis for non-compliance actions against the facility?

Enterprise environmental monitoring programmes should be available for review by the general public


The End

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Enterprise environmental monitoring Elements for guidelines on strengthening environmental monitoring and reporting by enterprises Aare Sirendi