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ABB explains the benefits of best available techniques over cheapest available techniques.

It was over 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 cut corners by adopting what could euphemistically be termed the ‘CATNAP approach’ (cheapest available techniques narrowly avoiding prosecution).

Although it might make short-term cost savings, this approach is actually a shortsighted strategy that not only endangers our environment, but the profits of the companies that adopt it.

BAT is not simply about investing in the latest pieces of accurate kit; it’s about looking at the best way of reducing emissions in practice, whether that’s through well engineered, innovative equipment, novel processes, improved procedures or good engineering practices.

Minimising emissions is not only good for the environment, it’s also good for business, as fewer emissions mean less waste and improved efficiency.

For instance, reducing emissions to air is often about increasing the energy-efficiency of a site.

Similarly, reducing liquid effluent cuts treatment and pumping costs, while preventing soil contamination has a massive impact on the long-term remediation costs for any operation.

It’s 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 don’t really care how the operator achieves it.

Of course, it will shift the goal posts 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.

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 (some operators with lower levels may also need to monitor if mentioned in permit consent due to a sensitive aquatic area) 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 a +/-8 per cent uncertainty target for the measurement of total daily volume of effluent discharged.

This covers not only the equipment, but factors such as correct fitting and the training of relevant personnel to ensure that an installation is operating properly.

As far as selecting the right kit goes, if there are MCertified examples of a particular measurement technology, operators must use them in preference to competing products based on the same technology.

However, this requirement need 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 available, but inspectors 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.

This situation is happening at present 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 when compared to these technologies.

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 per cent uncertainty target.

The ABB electromagnetic Watermaster flowmeter has achieved MCerts accreditation.

The Watermaster is one of the first flowmeters to be awarded a Class 1 MCerts conformity certificate for closed-pipe flow measurement.

As well as using suitable equipment, operators must also prove that they are capable of managing their effluent self monitoring successfully.

This requires that they have their sites checked by an MCerts inspector and to undergo an audit of the Quality Management Systems (QMS) relating to their flow monitoring arrangements.

The inspection deadline was 31 December 2008, yet only a fraction of the sites that had effluent-flow monitoring as part of their PPC operating permits had undergone an MCerts inspection by that date.

Any remaining operators must ensure they comply as quickly as possible, or they run the risk of stiff penalties.

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 that provide added benefits, such as improved accuracy or in-situ verification capabilities, in order to improve process management in the long term.

ABB can offer expert guidance on all aspects of Environmental Permitting/PPC compliance, from the latest products, technologies and verification services for environmental monitoring through to advice on preparing a permit and implementing the quality assurance processes needed to ensure continued compliance.

ABB Automation Tech – Instrumentation and Automation

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