How to meet the EA's Operator Monitoring Assessment (OMA) requirements
The Environment Agency's (EA) Operator Monitoring Assessment (OMA) programme is a key part of ensuring that industrial operators correctly monitor their effluent discharges to the environment, both to air and, more recently, water courses.
OMA is one of the main pillars of the Environmental Permitting Regulations (EPR) and was introduced to strengthen the EA's auditing of operators' self-monitoring arrangements. Underpinning this is the idea that water companies will be partly responsible for monitoring their own discharges under the Operator Self Monitoring (OSM) scheme.
Under OSM all effluent must be measured, recorded and maintained within each company's site permit limits, bringing the ownership of monitoring and compliance back to the water companies. Companies wishing to achieve the maximum score for their assessments will have to use MCertified equipment or the Best Available Technique to be able to score maximum points.
Having passed the Environment Agency's testing requirements, MCERTified products will often constitute BAT, increasing the likelihood of achieving maximum points and being readily accepted by the Environment Agency's inspectors.
OMA initially applied only to emissions to air from industrial operations, but in May 2009, OMA Version 3 extended the requirement for OMA to include discharges to sewers and water. It divides the requirements of effective monitoring up into four sections, namely:
- Management, training and personnel competence
- Fitness for purpose of monitoring methods
- Maintenance and calibration of monitoring equipment
- Quality assurance of monitoring
Each of the four main sections is further divided into five or six elements to form a logical framework for assessing the effectiveness of the overall monitoring regime. Although operators need to address each element, the EA identifies three of them as fundamental. Getting a low score in any of these indicates critical flaws in the monitoring regime and an urgent need for improvements. The three fundamental elements are:
- Sampling facilities (section 2A)
- Measurement techniques (section 2B)
- Acceptability of calibration methods (section 3F)
In scoring the individual elements, a score of 1 is poor, 3 is acceptable and 5 is excellent. The scores for each element in a section are added together and an overall percentage of the possible high score is calculated for each section. The overall OMA score is then calculated as the mean of the section scores. The chief aim is to help operators to identify and prioritise any necessary improvements, so there is no absolute pass or fail score.
The EA maintains that responsible companies facing OMA for the first time should not suffer from onerous extra costs and can even save money by reducing their waste and optimising their use of resources.After all, poor waste management often leaves companies losing product and raw materials that might otherwise be recovered and re-used. In addition, OMA results are publicly available, so a high score is valuable social capital in a marketplace increasingly concerned about whether organisations are operating ethically and sustainably and are a good neighbour to local businesses and residents.
So the question many organisations are asking is what they need to do to secure a high OMA score. Some elements include critical requirements, without which it is impossible to get the highest score, however assiduously an operator applies the remaining measures. One area where there is a definite hardening of policy is in the requirement to use monitoring equipment that has been certified as officially fit for purpose. This is managed under the MCERTS scheme.
MCERTS relies on the independent testing centre SIRA to test and certify measurement and monitoring equipment for use with environmentally sensitive emissions, including all the waste streams specified in an EPR application. Like OMA, MCERTS started out on the air emissions side, so there is now a good choice of MCERTified equipment for every aspect of air emissions covered by the EPR. As long as existing equipment meets the required measurement standards it need not be replaced immediately. However, any new equipment must be purchased from the MCERTS list.
The regime is several years behind on the water side, where many equipment suppliers are still working with SIRA to get their instruments certified. But more instruments are being added to the list all the time. This fast-changing situation means that operators should check whether MCERTified equipment is available as and when they need to install new instrumentation for monitoring their aqueous effluent. If it is, they should use it. The current list is available on the SIRA Web site.
Of course, winning a high OMA score is about much more than shipping in the right kit. It also requires the expertise to ensure that the equipment is installed, operated and maintained properly so that it delivers reliable service between inspections. For example, ABB may be best known as an equipment supplier, but one of the related areas that has been keeping ABB busy is providing consulting services to site operators who are applying for EPR permits. This might be an initial application or it might be, say, the result of a site extension or an improvement notice from the EA. This activity used to be confined mainly to helping operators in the process industries, but the arrival of the utility companies in the OMA arena is making life busier than ever for consultants.
Even where operators consider it unnecessary to bring in the consultants, reputable equipment suppliers should offer a good level of technical support through their product service teams. They might help with commissioning and installation, as well as calibration and verification, for instance. This prevents some of the common problems that might otherwise affect monitoring performance, such as installing flowmeters without the correct upstream and downstream straight pipe runs or without the proper earthing. In the case of ABB, for example, opting for ABB engineers to commission instrumentation may also result in a one-year warranty extension offer for some products, in addition to the peace of mind of having a manufacturer's back-up and support.
The gap between OMA inspections can be up to four years, but the EA expects operators to demonstrate that standards have been maintained in the mean time. Operators should have detailed maintenance and calibration programmes in place and be able to demonstrate that equipment is reliable and available throughout. For instance, some continuous monitoring systems do not require frequent calibration checks, but operators should adhere to the manufacturer's guidelines if they want a good score. This is another area where the equipment manufacturer can really help. ABB offers a five-year contract to provide an annual electronic verification of its electromagnetic flow meters, for instance.
In short, there is plenty of advice and support out there for companies that are worried about facing OMA for the first time. The EA, consultants and equipment suppliers are all ready to help. Furthermore, companies that span both sewage and water treatment should consider whether the potential benefits of a consistent approach to monitoring mean that they would be better off bringing all their operations under a similar regime sooner rather than later. After all, it seems likely that they will soon be forced to introduce OMA across the board in any case.
ABB has released a comprehensive new guide to the Environmental Permitting Regulations (EPR) and MCERTS, the Monitoring Certification Scheme of the Environment Agency (EA). Entitled "MCERTS and EPR - a guide to environmental EPR legislation and monitoring systems and services", the guide is a useful point of reference for anyone responsible for the monitoring of emissions to air or water at an EPR regulated site.