How to meet MCERTS with flowmeters for accurate self-monitoring of effluent
The latest step in the Environmental Permitting Regulations (EPR) legislation is the obligation for all industrial companies discharging 50m3 or more of effluent per day to a watercourse or the sea to self-monitor their effluent flows. The self-monitoring obligation requires operators to comply with the Environment Agency's MCERTS certification scheme. Under this scheme, companies should be able to demonstrate to the satisfaction of a qualified MCERTS inspector that they are using the Best Available Technique (BAT). This page explains the MCERTS scheme and the technology available from ABB to help you meet its requirements.
What is MCERTS?
The Monitoring Certification Scheme (MCERTS) is designed to ensure that potential polluters are monitoring their emissions effectively and supplying the Environment Agency (EA) with reliable data.
The MCERTS scheme is part of the EA’s strategy to ensure that the K meets the requirements of European legislation. It was first applied to air emissions in order to comply with the Air Quality Framework Directive and its daughter legislation. MCERTS is now being extended to aqueous emissions and soil contamination in order to comply with the Integrated Pollution Prevention and Control (IPPC) Directive, which is implemented nationally through the Environmental Permitting Regulations (previously known as the Pollution Prevention and Control (PPC) Regulations).
All the most potentially polluting processes now fall under EPR and companies running these processes must apply to the regulator for a licence to operate.
What does it apply to?
Emissions to air
The MCERTS requirements for emissions to air are well established. ABB alone has five certified products in this area and the total number of approved systems is edging towards the 100 mark.
In addition to using the best equipment, air emissions monitoring should only be carried out by accredited test laboratories using certified staff, or by end-user companies with their own certified staff. Individual certification is based on a person’s experience, training and knowledge. It is carried out by the Sira Certification Service, which runs this MCERTS scheme on behalf of the EA. Accredited test laboratories are listed on the nited Kingdom Accreditation Service ( KAS) website.
The air monitoring systems themselves are known as continuous emission monitoring systems (CEMS), continuous ambient air monitoring systems (CAMS), or portable emissions monitoring systems (PEMS).
Even with MCERTS approval in place, however, it’s vital that operators talk to their equipment supplier to ensure that they are using the right measurement tools for the job. For example, even if a CEMS instrument has MCERTS approval and is designed to measure the correct determinand, stack conditions vary tremendously. It is therefore important to check the details of individual certificates, because they may contain specific limitations on the use of the equipment.
Emissions to water
To protect inland and coastal waters, MCERTS is now being applied to the monitoring of the flow and composition of effluent discharges, as well as the total flow and rate of abstraction by water companies.
The equipment needed is known as Continuous Water Monitoring Systems (CWMS), which includes separate categories for sampling systems, analysers and flow meters. This is in addition to the portable water monitoring equipment scheme.
As well as using approved equipment, site operators responsible for discharges to water must have their flow monitoring installations inspected regularly. The inspection must be carried out by a certified MCERTS inspector to ensure that the equipment has been installed properly. Furthermore, under the Operator Monitoring Assessment (OMA) scheme, site operators are assessed to check that they are capable of properly operating and maintaining a site in a way that safeguards the integrity of its ongoing performance.
Who does it apply to?
EPR covers chemicals and pharmaceuticals, food and beverage, power, pulp and paper, water and waste water, oil and gas and industrial operators. Nuclear sites will also be brought under the MCERTS umbrella for the first time and must have their inspections done by 31st March 2010. The EA’s Modernising Regulation Agenda places increasing emphasis on self-monitoring for all potential polluters and particularly those requiring a permit to operate under EPR.
Any site operator who is responsible for discharges specifically mentioned in an EPR permit has to monitor them in a way that meets MCERTS standards of quality and reliability. Although there are guidelines, there is no hard and fast lower limit regarding the quantity discharged. Anything important enough to be mentioned on a permit to operate will fall under the MCERTS scheme.
The focus on self-monitoring
The latest step in the legislation is the obligation for all industrial companies discharging 50m3 or more (some operators with lower levels may also need to monitor if mentioned in permit consent due to a sensitive aquatic area) of effluent per day to a watercourse or the sea to self-monitor their effluent flows.
The self-monitoring obligation requires operators to comply with the Environment Agency’s MCERTS certification scheme. nder this scheme, companies should be able to demonstrate to the satisfaction of a qualified MCERTS inspector that they are using the Best Available Technique (BAT). Where the self-monitoring of effluent flow is concerned, operators are subject to a ±8% uncertainty target for the measurement of total daily volume of effluent discharged. This covers not only the equipment, but also factors such as correct fitting and the training of relevant personnel to ensure that an installation is operating properly.
How do you comply?
The actual requirements of the MCERTS standards vary, depending on whether the company is monitoring emissions to air, discharges to water or checking for contaminated land. But the overriding requirement for any type of monitoring is that companies should be able to demonstrate that they are using the Best Available Technique (BAT) to protect the environment.
In practice this means that, if there are instruments or systems using a particular technology that have passed all the necessary tests and received an MCERTS compliance certificate, operators must use them. Lists of the approved equipment can be found on the www.MCERTS.net or Sira website.
This requirement should not be misconstrued, however. It does not apply if there is an alternative technique available that can outperform the MCERTified instruments for specific applications. There may not be any MCERTS-approved examples of the superior technology, but the regulator will usually be happy for companies to use it because it constitutes BAT. This scenario is naturally going to crop up more in the early days of the scheme, because it takes time for instrument manufacturers to get their products approved.
In fact, this situation is happening right now in the self-monitoring of effluent discharge. The few MCERTS-approved metering systems listed so far rely on open channel flow or clamp-on ultrasonics, but magnetic flow meters offer a demonstrable improvement in metering accuracy when compared to these technologies. MCERTS inspectors are therefore happy to approve monitoring installations that rely on magnetic flow meters from reputable suppliers since they stand a much better chance of achieving the ±8% uncertainty target.
ABB’s own electromagnetic WaterMaster flowmeter has achieved MCERTS accreditation. The WaterMaster is one of the first flowmeters to be awarded a Class 1 MCERTS conformity certificate for closed pipe flow measurement.
MCERTS inspections – what’s involved?
As well as using suitable equipment, operators must also prove that they are capable of managing their effluent self-monitoring successfully. This requires them to have their sites checked by an MCERTS inspector and to undergo an audit of the Quality Management Systems (QMS) relating to their flow monitoring arrangements.
Once a site has been approved by an MCERTS inspector, the resulting certification will be good for the next five years, although the site’s QMS will continue to be audited on an ongoing basis, with the frequency of surveillance audits determined by the level of competence shown by the operator. It is therefore a good idea for operators to ensure the continued accuracy of their effluent self-monitoring equipment to eliminate the risk of a breach in their permit conditions.
Maintaining compliance between inspections
Once issued, the MCERTS conformance certificate covers the site for five years, but companies will be expected to take demonstrable, proactive actions to keep up their effluent monitoring performance during that time.
Furthermore, just as car owners are responsible for ensuring that their vehicles always have a valid MOT certificate, EPR-regulated site operators must make sure that their MCERTification status is not jeopardised by a lack of preparation in the run-up to any subsequent inspections.
The EA has therefore decided that companies may opt to have their next inspection carried out up to 12 months before their old certificate runs out. If they pass, their new certificate will cover them for five years from the date that their old certificate expires. If they fail, they will be expected to take any necessary remedial action as soon as possible and definitely in time to be recertified before the previous certificate runs out.
MCERTS does not explicitly prescribe the use of a particular management system, but working to an accepted BS or EN standard can be an excellent way to make sure all the requirements are met, including providing the added reassurance of annual external audits.
At the very least, companies should be keeping clear records to show that they are carrying out their own regular checks.