Better regulation and MCERTS

1
Better regulation and MCERTS

• Rupert Standring
• Technical Advisor
• National Monitoring Service
• Environment Agency

2
Outline

• MCERTS
• CEMs
• manual stack emissions monitoring
• Guidance Notes M1, M2 and M20
• OMA Version 3
• Making it all work

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MCERTS

• MCERTS - Our Monitoring Certification Scheme
• Purpose
• provides good quality monitoring data
• built on European Standards called up by WID and
  LCPD
• clear and efficient implementation

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MCERTS for CEMs

• Covers continuous emission monitoring systems
  (CEMs)
• Aligned with European standard (EN 15267-3)
• CEMs undergo laboratory and field tests
• Quality assurance and design control of
  manufacturing
• Proves CEMs meet the requirements of Directives

5
MCERTS for CEMs

• Great success
• Over a hundred MCERTS CEM systems available
• Applicable to a wide range of pollutants
• Details from
• www.mcerts.net

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TGN M20 - Quality assurance of CEMs
Suitable equipment
QAL1 (MCERTS)
BS EN14181
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MCERTS for manual stack emission monitoring

• The scheme is split into two components
• The certification of personnel
• - difficult work
• - experience, training and examinations
• The accreditation of organisations
• - third party verification by UKAS

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Update on the Manual scheme

• The first eight years
• A lot of hard work by everybody!
• Overall a great success
• 500 people with MCERTS certification
• 32 laboratories with MCERTS accreditation
• Quality of work has improved

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Personnel competency
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Level 2 key role

• Must be on site to
• supervise trainees
• oversee Level 1 staff
• Responsible for approving
• site reviews
• risk assessments
• site specific protocols
• reports

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Accreditation of organisations

• Accreditation of organisations by UKAS
• Method specific
• Schedule of accreditation (e.g. particulates,
  moisture and oxygen)
• Permit specifies that monitoring contractors must
  have MCERTS accreditation
• Permit specifies the methods used
• Check the schedule of accreditation

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Performance standard for organisations

• Aligned with EN 15259
• Use of MCERTS certified personnel
• Use specified standards
• Use Method Implementation Documents
• Planning of a measurement campaign
• site review
• risk assessment
• site specific protocol
• Reporting of results

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Site specific protocol (SSP)

• SSP is a plan / strategy for carrying out the
  work
• Operators should have an up to date SSP
• Includes information needed to carry out the work
• For example includes
• sample methods
• sample number / duration
• expected measurement uncertainty

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Technical Guidance Note - M1

• Sample locations and facilities
• Poor sample location poor quality data
• M1 aligned with EN 15259
• M1 includes health and safety

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Technical Guidance Note - M2

• Sample strategy
• Index of methods
• CEN Standards (CEN)
• International Standards (ISO)
• National Standards (US EPA)
• Specified in Permits

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Alternative methods in M2

• Need to be aware of Alternative Methods
• May be better to use an instrumental technique
• real time readings
• Example
• measurement of HCl with FTIR
• Acceptable if MCERTS accredited for the method

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Operator Monitoring Assessment (OMA)

• Systematic auditing approach for
• Assessing the quality of monitoring
• Assessing the reliability of results
• Determining compliance with permit conditions

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History of OMA

• OMA version 1 launched in 2001
• OMA version 2 published in 2003
• OMA version 3 launched in May 2009

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How often?

• Audit operator self monitoring on a four year
  cycle
• Can be more frequent if
• major change to monitoring regime
• concerns about monitoring
• operator wants to have improvements recognised

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Sections

• OMA 1 - Management, training and competence of
  personnel
• OMA 2 Fitness for purpose of monitoring methods
• OMA 3 Maintenance and calibration of monitoring
  equipment
• OMA 4 Quality assurance of monitoring

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Scoring

• Each section has several elements
• Each element is given a score of 1 to 5 using the
• OMA guidance
• score of 1 or 2 requires the operator to make
  improvements
• score of 3 is acceptable
• score of 5 fully meets requirements

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Fundamental element 2A

• OMA 2A Sampling location and facilities
• If the sample facilities are poor this will
  affect other
• elements in the OMA
• A poor sample location may mean that a method
• cannot be carried out correctly, which affects
  other
• elements (e.g. 2E Method performance)
• Sort out sample locations (if possible)

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4C, 4D - Auditing

• Expect operators to audit their monitoring
  arrangements
• If audits have not been done a score of 1 is
  applied to the following elements
• OMA 4C Auditing of monitoring
• OMA 4D Audit compliance

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Why audit?

• Most common criticism by operators is
• Why do we have to audit MCERTS accredited
  contractors? They're the experts!
• Regular audits result in an improved quality of
  work
• Simple checks make a big difference

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Audit programme

• Start with simple checks
• risk assessment forms completed
• an exclusion area (if needed) has been set-up
• personnel have the right qualifications
• sampling procedures are available on site
• equipment calibration certificates are in date
• Audit forms available from www.mcerts.net

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Conclusion - making it work

• Applying monitoring standards through MCERTS
• work with operators, users and United Kingdom
  Accreditation Service (UKAS)
• keep standards under regular review
• work hard to make the schemes as efficient as
  possible
• Develop and improve our auditing tools
• Operators demonstrate they can deliver by meeting
  MCERTS

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Conclusion - guidance

• Deliver simpler, shorter guidance on monitoring
• Easily accessible through www.mcerts.net
• We encourage/welcome feedback
• each guide has contact details in it
• if weve got it wrong, or its not clear enough,
  well put it right!

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Contacts

• Manual monitoring
• Rupert Standring
• rupert.standring_at_environment-agency.gov.uk
• CEMs
• Rick Gould
• richard.gould_at_environment-agency.gov.uk