MCERTS - Pollute at your peril

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. Although everyone welcomes initiatives to protect the environment, MCERTS has been criticised for being onerous and expensive. In fact, it should deliver a range of benefits in the future, including potential cost savings for some process operators, argues Tony Hoyle of ABB.

The MCERTS scheme is part of the EA's strategy to ensure that the UK 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 Pollution Prevention and Control (PPC) Regulations.

All the most potentially polluting processes now fall under PPC and companies running these processes must apply to the regulator for a licence to operate. This can be a complex procedure and, with so much at stake, many companies choose to bring in external consultants, such as specialists from the engineering services arm of ABB, to help ensure that they get it right.

PPC covers chemicals and pharmaceuticals, food and beverage, power, pulp and paper, water and waste water, oil and gas and industrial operators. 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 PPC.

Any site operator who is responsible for discharges specifically mentioned in a PPC 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 is important enough to fall under the MCERTS scheme.

Some companies may currently operate sites that fall under legislation other than PPC, such as Integrated Pollution Control, Local Air Pollution Control (although PPC is replacing both of these), the Water Resources Act or the Urban Wastewater Treatment Directive. However, the regulator may require that these sites also comply with MCERTS standards.

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.

For example, this is precisely what's happening right now in the rapidly evolving area of flow metering for the measurement of water abstraction and effluent discharge (under Self Monitoring of Effluent flow for PPC installations). 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 as they stand a much better chance of achieving the +-8% uncertainty target for total daily effluent volume.

The situation is set to change very soon however, since ABB is currently going through the MCERTS approvals process for its MagMaster meters. Once there are one or more magnetic flow meters available with MCERTS approval, companies will be obliged to use them, rather than opting for unlisted competing products using the same technology.

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.
Zirconia Oxygen Analyser
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 United Kingdom Accreditation Service (UKAS) 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. Unlike the air monitoring regime, the MCERTS scheme for water is still being rolled out. The deadline for an inspection of flow monitoring arrangements and QMS audit for existing sites is December 2008.
Monitoring of flow
The equipment 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 and is being operated and maintained in a way that safeguards the integrity of its ongoing performance.

MCERTS inspectors are appointed by Sira on behalf of the EA. The inspectors aren't employed directly by Sira. Instead, a number of competing companies are offering inspection services. Details of these can be accessed via the Sira or www.mcerts.net website.

Inspectors will prepare a report based on their expert opinion as to whether the operating company's monitoring arrangements meet MCERTS requirements. This includes an assessment of the application, type of measurement device and the estimation of measurement uncertainty. The QMS will also need to be assessed separately by a UKAS accredited certification body that has MCERTS included in its scope. This might be the
operator's existing ISO14001/9000 auditor, for example, or Sira.

Sira then checks the inspector's report and the QMS auditor's report. If the MCERTS requirements have been met, it will issue an MCERTS Site Conformity Inspection Certificate, which is valid for five years, but will still require QMS surveillance visits.

Emissions to land

Soil sample analysis reveals how much contamination is present in the ground around a site. The EA only accepts analytical data from laboratories who are accredited under the MCERTS Chemical Testing of Soil scheme. Accredited laboratories are listed on the United Kingdom Accreditation Service (UKAS) website.

Costs vs. benefits

The main criticism leveled at the MCERTS scheme has been that it is expensive and places an onerous burden on end users and equipment suppliers. While it may be expensive, it can also deliver some real benefits to all the stakeholders concerned.

Of course, the main benefit is that it protects the environment, which is something that should interest everyone. We're all duty bound to be environmentally responsible and having regulatory standards in place ensures that responsible companies can do business on a level playing field, rather than facing competition from rivals who don't invest as heavily in environmental protection.

Having certified products available also removes significant ambiguity from the marketplace. Process companies can be sure that the monitoring equipment they choose is up to the required standard and this prevents them from wasting money on unsatisfactory solutions.

The whole thrust of the EA's modernisation agenda and its emphasis on self-monitoring is also a way for companies to save money. The cost of training staff to monitor stack emissions or of obtaining an MCERTS Site Conformity Inspection Certificate may seem substantial, but being able to monitor your own emissions could be far cheaper than paying for frequent, expensive site visits from EA inspectors.

Even the instrument suppliers, who are bearing the brunt of initial cost increases as they apply to have their products certified, should benefit in the long run. It's the level playing field argument again. By having good engineering practice enshrined in legislation, responsible practitioners can be confident that buyers are comparing like with like.

The other criticism of MCERTS is that it restricts the choice of equipment available to end users. For example, at the time of writing, just six online analysers for CWMS had MCERTS approval, along with only three flow meters.

This is a situation that will improve with time. For example, ABB's MagMaster technology will soon join the exclusive club of MCERTS-approved flow meters. And in the more established area of CEMS, the list of approved products now runs to almost 80. In fact, ABB's AnalyzeIT AZ100 Zirconia Oxygen Analyser system was the very first product to be listed under the MCERTS scheme.

From an equipment manufacturer's point of view, earning a coveted place on the list of MCERTS-approved products is an involved process that requires a substantial investment and genuine commitment. For example, the procedure for flow meters and all equipment includes three steps:
1. Laboratory testing is used to determine performance characteristics, where such testing requires a highly controlled environment;
2. Field testing is carried out on processes representative of the intended industrial sectors and applications;
3. Surveillance - initial and continuing - comprises of an audit of the manufacturing process to confirm that the manufacturer has provisions to ensure manufacturing reproducibility and to control any design changes to ensure that they do not degrade performance below the MCERTS standards.

A changing situation

The whole concept of using BAT means that the situation with MCERTS must continue to evolve as the available technologies and techniques improve.

For example, ABB is currently working with Sira on a standard for the verification of magnetic flow meters. A small number of meter manufacturers now offer effective verification tools (including ABB's CalMaster2, for example) that can carry out in-situ checks to ensure that the accuracy of the meters does not deteriorate over time.

The ability of these tools to test meters accurately without removing them from the line has already delivered massive savings in the water industry over the past 10 years, simply by reducing the need to take meters out of service. With an MCERTS standard in place, the same tools could soon be set to play a role in protecting the environment.

Conclusion

The benefits of MCERTS are numerous. It enables industry to be environmentally responsible and comply with legislation such as PPC. It gives purchasers the certainty that the products they are buying are up to a certain standard and by having good engineering practice enshrined in regulatory requirements, responsible instrument suppliers can be sure that they are operating on a level playing field.

Ultimately of course, it's the environment that will benefit, and that's good news for all of us. The scheme should help ensure that the industry's efforts at self-monitoring are transparent and credible. The current challenge is to understand the impact of MCERTS and PPC on industry and use the best available techniques and technology to measure emissions and reduce industry's environmental impact. For support with compliance, contact leading manufacturers like ABB with experience of MCERTS and its engineering services PPC consultants or visit
www.mcerts.net or www.sira.co.uk/mcerts website.

For more information on how to comply with MCerts and PPC, call ABB on 0870 600 6122 or email moreinstrumentation@gb.abb.com ref. 'MCerts/PPC'.

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    UK companies face tightening controls on pollution
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