Effective monitoring allows the performance of industrial facilities to be assessed against the requirements set in their permits.
In order to guarantee fair and useful data, monitoring requirements should be defined that include measurement methodology, frequency and an evaluation procedure (see IED Article 14). The way monitoring is conducted should be based on information taken from the BAT conclusions. Specific requirements are determined by the permit-issuing authority and detailed in each installation's permit or in general binding rules that apply at the national or regional level for all installations of the sector concerned.
Some minimum binding monitoring requirements established under some sector Directives (e.g. Large Combustion Plants, Waste incineration etc) apply in addition to the BAT-driven monitoring requirements.
With regard to the monitoring of soil and groundwater in particular, it is specifically stated that periodic monitoring shall be carried out at least once every five years for groundwater and every 10 years for soil (IED Article 16). The monitoring of surface waters is addressed separately.
According to Article 3(12) of the IED, BAT conclusions shall contain emission levels associated with BAT and associated monitoring. This can be done either by including separate conclusions on monitoring or as part of other conclusions, such as where an environmental performance range is provided. The BREF review rules are explicit regarding the reference information that should accompany the emission data submitted in the context of the development / review of the BAT conclusions:
1. The frequency of the measurement/sampling/monitoring;
2. The averaging period used to report the data;
3. The type of monitoring method used (e.g. direct measurement, indirect measurement, mass/heat balances, emission factors) and an indication of the EN/ISO (or other) monitoring standard(s) used including the sampling method and sample pre-treatment. If available, the limit of detection (LOD) and the limit of quantification (LOQ) will be given for the parameter monitored. In cases where the monitoring standard used is not an EN/ISO standard, a description of the standard will be provided.
4. An indication of the measurement/sampling/monitoring uncertainties.
5. Details of the data source, e.g. who collected, analysed and submitted the data.
6. Whether the data was taken during normal operation or under other than normal operating conditions
The reference document on general principles of monitoring (ROM) should be taken into account with respect to the expression of monitoring results and how to deal with uncertainties, direct measurements and monitoring requirements. This document is awaiting adoption.
The main difference in monitoring techniques relate to the frequency of measurements taken and the types of approaches. The main distinction is between:
Direct measurements: continuous, periodic or campaign measurement; and
Indirect methods: mass balances, emission factors, surrogate parameters or other calculation methods.
Owing to the size of industrial activities, and in order to achieve more accurate and timely monitoring, direct measurements based on continuous measurements (CEMs) are preferred. Whilst periodic measurements would only provide “snapshots” at a given time, continuous measurements cover all periods when pollutants are emitted and allow real-time output (total load of pollution) and verification of results. As there are a greater number of measurements, the sampling basis is much more robust and shielded from cheating (for period measurements the timing of sampling can be chosen in order to inaccurately reflect more favourable conditions of operation). The main argument against using CEMs is higher capital, maintenance and operating costs. However, plant operators have benefit from CEMs as they allow for better process controls. Automatic monitoring systems have the significant advantage of enabling real-time reporting to the public of industry performance, allowing corrective measures to be taken.
Continuous measurements are required for a range of pollutants for specific IED sectors, in most Member States mass thresholds trigger continuous monitoring.
Considering recent experience in BREF reviews, we seek the following information:
-Feedback on our overview table with information on standards applied outside the EU; An overview of monitoring requirements to air and water set under the IED, BAT conclusions or national provisions is provided in the attached document.
-CEMs applied for pollutants monitoring not yet covered by BAT conclusions;
-Examples of reporting monitoring results of CEMs on websites / online database;
-Continuous measurement for mercury with measurement certainty of single measurement <0.5 µg/Nm³ and PCCD/F;