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.
Meeting the MCERTS compliance deadline was just the first step for the many companies that fall under the EPR regulations. Tony Hoyle, ABB UK Product Flow Manager, explains that the new challenge facing these companies is maintaining their compliance in between inspections and ensuring that they are ready for their follow-up assessments. MCERTS is the Environment Agency’s certification scheme to ensure that companies have effective measures in place to monitor their effluent flow. Industrial sites need to meet MCERTS requirements whenever their discharges must be monitored and controlled as part of their permits under the Environmental Permitting Regulations (EPR). EPR directly replaced the Pollution Prevention and Control (PPC) regulations in April 2008.
Some sectors, notably water, are ahead of the game, while other industries are still coming up to speed with their EPR and MCERTS obligations. The scope of the regulations is also being progressively extended over time. For example, nuclear sites will be brought under the MCERTS umbrella for the first time and must have their inspections done by 31st March 2010. Around 30 nuclear sites in the UK are expected to be affected.
The current situation is that the EA’s December 2008 deadline for those companies already covered by EPR to have MCERTS inspections has come and gone with only a fraction of qualifying sites successfully certified.
This was not entirely unexpected, however. The demand for qualified MCERTS inspectors rose so sharply in the run up to the deadline that there was no way everyone was going to make it in time. The EA has therefore decided not to penalise sites that overshoot, as long as they booked in their inspections before the deadline and have them carried out within “a reasonable time”.
Those sites that successfully complete the audit and inspection process are awarded a Site Conformity Inspection Certificate, which lasts for five years. However, it’s important to recognise that continued vigilance will be needed in the intervening years to prevent any problems cropping up the next time the inspector calls.
If you’re still waiting…
Those companies that are still waiting to be inspected for the first time need to make sure they are prepared. First, assess the current flow measurement arrangements to see whether they comply with MCERTS.
Does the measuring system constitute 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.
As long as existing equipment meets the measurement standards, it need not be replaced. However, if new equipment is being installed, the BAT requirement will eventually mean using a meter from the EA’s published list of equipment that has been tested and MCERTified. The current list is available on the EA’s Web site.
But many equipment vendors are still at the stage of putting their instruments through the approvals process with the EA’s chosen certification body SIRA, so there may still be some leeway in using some uncertified equipment. For example, ABB WaterMaster meters are already certified, but some of the company’s other models of meter are still being assessed.
Having the right kit is just the start. For instance, is the metering system installed and maintained correctly and has its measurement accuracy been properly verified, perhaps by checking it against readings taken using another flow measurement technique? Reputable equipment vendors have a wealth of expertise in this area. For instance, ABB’s instrumentation service engineers can provide in situ verification services for ABB meters using the CalMaster2 and VeriMaster suite of tools, and can also use a variety of technologies to check third-party instruments.
Finally, do you have the right people and processes in place to ensure that the flow readings will continue to be accurate in future? This is vital, since the inspector and Sira will be auditing procedures as well as checking the installations.
If in doubt about any of the requirements, it may be worth getting external advice. Calling in the consultants is one option, but reputable equipment vendors can often provide advice on installing and operating flow monitoring systems correctly.
Once you have your certificate…
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. For example, it may be a good idea to use a videographic recorder like ABB’s ScreenMaster range to log the data.
The performance of flow meters should be checked and verified annually, and visual surveys carried out on the surrounding installation to make sure that nothing is interfering with the readings. For example, has anyone routed a high-voltage cable where it might interfere with an electromagnetic meter, or rerouted effluent pipe work without letting the person responsible for environmental monitoring know?
A fresh approach
MCERTS and the self-monitoring of effluent flow is just part of a wider philosophy within the EA to promote “better regulation”. This means encouraging companies to comply with and even exceed legal requirements without constant supervision.
Society demands high standards of environmental responsibility while businesses want a regulatory regime that minimises bureaucracy. Better regulation will effectively reward good performers with lower costs and more autonomy. On the other hand, those companies that don’t measure up could face severe penalties, so the onus is now on industry and water companies to get it right.
Bring in the experts
A typical service contract schedule will involve: