Take up BAT to stay in the game
Tony Hoyle has this wake-up call for the industry: This is no time to CATNAP (using cheapest available techniques narrowly avoiding prosecution) but rather time to go in to BAT (best available techniques) in order to cut emissions and save money.
WE SHOULD be familiar with the concept of BAT (best available techniques) for pollution prevention. It was more than 20 years ago that the Air Framework Directive (AFD) first introduced BATNEEC (best available techniques not entailing excessive costs) for air emissions from major industrial polluters.
This was followed in 1996 by the Integrated Pollution Prevention and Control (IPPC) Directive, which extended BAT to cover the control of emissions to water and land, as well as air.
Even so, some industrial operators continue to try and to cut corners by adopting what could euphemistically be termed the CATNAP approach (cheapest available techniques narrowly avoiding prosecution). This approach is actually a shortsighted strategy that not only endangers our environment, but also the profits of the companies that use it.
BAT is not simply about investing in the latest pieces of accurate kit. It is about looking at the best way of reducing emissions in practice.
Fewer emissions mean less waste and improved efficiency. For instance, reducing emissions to air is often about increasing the energy efficiency of a site, and saving energy is a subject that is increasingly weighing on the minds of people in finance departments.
Similarly, reducing liquid effluent use cuts treatment and pumping costs, while preventing soil contamination has a massive impact on the long-term remediation costs.
It is also important to recognise that BAT is not a prescriptive approach. It does not mean buying new kit every time someone comes up with a new idea. Item 17 of the IPPC Directive says: “… emission limit values, parameters or equivalent technical measures should be based on the best available techniques, without prescribing the use of one specific technique or technology, and taking into consideration the technical characteristics of the installation concerned, its geographical location and local environmental conditions…”
In other words, as long as a site is successfully delivering the best environmental performance that can reasonably be expected, the legislators do not really care how the operator achieves it. Of course, it will shift the goalposts if a new technique comes along with the potential to significantly reduce emissions, but any investment required as a result should be offset – at least in part – by greater efficiency. Here in the UK, IPPC was initially implemented through the Pollution Prevention and Control (PPC) Regulations, but these have recently been incorporated into the Environmental Permitting Regulations (EPR). The latest step in the 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 BAT. Where the self-monitoring of effluent flow is concerned, operators are subject to an about 8% uncertainty target for the measurement of total daily volume of effluent discharged.
As far as selecting the right kit goes, it means that if there are MCertified examples of a particular measurement technology, operators must use them in preference to competing products based on the same technology. But this requirement need not apply if there is an alternative technique available that can out perform the MCertified instruments for specific applications. There may not be any MCerts-approved examples of the superior technology available, but inspectors will usually be happy for companies to use it because it constitutes BAT.
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. 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 is currently going through the MCerts approvals process for its electromagnetic WaterMaster and MagMaster meters and expects to receive certification this autumn. Once there are one or more magnetic flow meters available with MCerts approval, companies looking for magnetic meters will be obliged to use them.
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 a MCerts inspector, and to undergo an audit of the quality management systems relating to their flow monitoring arrangements. The inspection deadline was December 31, 2008, yet only a fraction of the sites that have effluent flow monitoring as part of their PPC operating permits have undergone an MCerts inspection. Any remaining operators must ensure they comply before the end of the year.
Businesses across the board are feeling the pinch from rising energy and commodity prices, and they must optimise their processes and minimise waste if they hope to remain competitive. Monitoring equipment has a significant role to play, and it may be worth investing a little more in good- quality equipment and technologies in order to improve process management in the long term.
Everyone benefits from BAT. CATNAP now and you could lose out in the future.
Tony Hoyle is UK flow manager at ABB.
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