The intention of the conference today is to look at the practicalities
of the quality and practical issues
in relation to emission monitoring and to allow you to interact with us.
There is a number of our regional inspectorate staff here
and our specialised air team as well.
So take an opportunity to interact and question and make submissions or
question us as we go through the day's presentations.
Contrary to the agenda Dara Lynott is not doing the introduction, I’m doing the introduction!
My name is Kieran O’Brien. I’m Programme Manager for the Office of Environmental Enforcement
and my area of activity is enforcement of IPPC and waste licences
First of all I’d like to go through a general introduction of the Office of Environmental Enforcement.
As part of the EPA we’re tasked with the enforcement of environmental legislation.
And the particular area that I’m working on has 5 regional enforcement offices
Castlebar, Kilkenny, Dublin, Wexford and Cork; scattered throughout the country.
So we have a regional presence for enforcement of licences within that region
and backing up that regional enforcement, which are general enforcement activities,
we have 4 thematic teams: an Air team, a Water team, a Waste team and a
Land and ELD; ELD is a Environmental Liabilities Directive –we won’t deal with that today
but the Air team in particular is dealing with a specialised small team based in Dublin
that will support regional enforcement activities and will also deal with
atmospheric emission monitoring and also outside contracting for emission monitoring
Just a point on how we enforce within the EPA
We have a risk assessment methodology, I'm sure a lot of you are familiar with it already
which effectively assesses the risk to environmental impact
from a number of different activities.
In particular we look at complexity, emissions, location, operator management
and enforcement record.
We categorise those activities then into high, medium and low
in terms of the enforcements categories
And the enforcement category then determines how we enforce and
what effort we put into the enforcement.
So we focus our activities on the highest enforcement risk
So if you're at a high enforcement category then you're going to get more enforcement.
If you're low you're going to get less enforcement.
So effectively the enforcement category will determine
what audit and inspection we carry out on a particular facility,
what monitoring the EPA do, and also will effect what monitoring we require the licensee to carry out
and it will effect what agreements we would have
and agree with individual licensees on reductions or changes to monitoring
All of that effects costs and charges
If we look at the monitoring and assessment of our activities generally that we're licensing
the vast majority of the monitoring and assessment is done by the operator
and it's only a very small proportion carried out by the EPA
The EPA inspection & check - it's only a check monitor
so in effect there's a vast majority of the data we're collecting
an assessment of compliance and impact assessment of emissions
are done by the operator.
In general, any monitoring that we do, which is very small in comparison to the overall monitoring
is carried out by the EPA, we do our own emission monitoring to water
which is done mainly by one of the other offices which is the Office of Environmental Assessment
they have regional laboratories as well in similar locations to our regional offices.
The air emission monitoring is carried out under contract for the EPA
and we have two contracts running at the moment for the north and the south of the country
You'll get more details on that later on in the discussions
There's additional assessments that we carry out as well
both internally ourselves, sometimes by the specialised air team, but also under contract
for specialised investigations or other monitoring that we feel is necessary
to determine a particular issue or where there's a particular investigation we're carrying out.
The cost of monitoring is recovered by the EPA. As a general rule
what we are required to do under legislation is to recover costs of our enforcement effort.
And in that sense, that any monitoring or reduction in monitoring
will have an impact on the costs both to the operator and to ourselves
which will be forwarded back onto the individual licencee.
Just a small bit on the monitoring requirements
The monitoring requirements are initially set out in the licence
and once that's set, there is flexibility within the licence
which does require agreement from the EPA
but it does really depend on operator control.
Effectively you have to make a case for a change or a reduction in emission monitoring
or operator control monitoring and in that sense the agency may agree a reduction
which again will reduce costs and
in effect that depends very much on the operator control
or the environmental performance of the activity.
Compliance history and a compliance with emission limit values set in the licence
also is quite important obviously. If we have non-compliances
we're not going to agree reductions in monitoring
The quality of monitoring and reporting to the agency, which we'll talk about a lot today,
is a significant issue, in that if we are not satisfied the quality of monitoring
or the reports we're getting do not reflect the actual emissions
then we're not going to be satisfied that we can reduce monitoring
and the use of new technology and IT is something that we are quite happy to discuss.
and new methodologies that may reduce cost or
improve our assessment of the emissions, we're quite happy to look at those as well.
When we look at the quality of monitoring
self monitoring is a huge amount of data that's being collected
Is there a question mark on it and the answer is yes there is a question mark on it
and we do have concerns
and there is significant variation in the quality of monitoring reports submitted
In looking at the data we're getting in, we're not satisfied we're up to standard in all cases
there's a gap that needs to be addressed - one of the reasons why we have this conference
There's poor correlation between self monitoring and EPA check monitoring
in a number of areas and that's something that, while we do investigate it,
it is difficult to ensure that the actual monitoring that is carried out reflects the emission
In effect once we do check monitoring, we're only checking very very occasionaly
and we have to ensure that the monitoring that's done by the operator actually reflects the emission
and our check monitoring should end up with the same data in the same set
We did do a number of specialised audits and inspections on
the quality of monitoring or self monitoring. In particular looking at laboratory operations
good laboratory practices etc.
There are required improvements identified during those inspections and audits
We have done them in particular during 2009 and 2010
Just a reminder that the licensee is responsible for ensuring that the licence conditions
in relation to monitoring are complied with including requirements that
any subcontracted laboratory or subcontracted contractor is competent
Now the question is - what does competent mean, and this is the wording in the licence
Our licences that are in force at the moment, some of them go back 15 years
and some of them are very much up-to-date and there's slight variations in them
but generally there is a requirement in all licences
that the monitoring is up to a particular standard and that any subcontracting
is the responsibility of the licensee to ensure that standards are maintained
I'm sure we'll talk about that later on - about what is competent
What we have been doing in the last few years is that we have been looking at
how can we address the concerns that we have in relation to self monitoring
We have issued a letter to licensees in February 2009
setting out the licence requirements, reminding the licensees that they are required to
produce data which is of a certain quality and a certain standard
and the fact that we are going to assess that during audits and inspections
and there's also recommendations to licensees in that circular
on what they should do to address and ensure that the quality of the monitoring
is carried out to the standard required, including sub contractors
We also have put on the website a number of guidance documents
which relate to quality of sampling, monitoring and information for individual licensees
to use in relation to the monitoring
We have two conferences this year. Today is the air conference
and we also intend to have a water conference before the year end
Now that water conference will mainly deal with water emissions
but will also deal with analysis in the laboratories much more than this one
I think that, judging by the attendance here today, a lot of the licensees that are here
are really related to air emission monitoring
I think there is a slight difference between water emission monitoring and air emission monitoring
in the sense that air emission monitoring is much more difficult to do
to the standard required and a lot of companies subcontract it out
A lot of the water stuff is done by in-house staff
That's something we can discuss later on.
This conference is intended to provide practical information
and the related issues. We have 3 sessions
The first session which is the first session this morning
is air emission monitoring legislation, licence requirements and
later we'll have quality requirements in monitoring
General, practical information about how the monitoring is carried out.
Session 2 is practical aspects of monitoring
and in the afternoon session we have associated PRTR,
emission inventories, ambient air quality and
finally we'll also have in the afternoon the licensee perspective
What does it mean to be a licensee and be subject to the requirements of a licence
and how to monitor.
After each session we'll have a Q&A and I would request that you interact
Q&A will not be published later on so we should have an open discussion.
We encourage feedback today but also we'll provide for feedback
There's a feedback circular on your chair but we'll also provide feedback through the net.
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Kieran O Brien, Programme Manager, Office of Environmental Enforcement, EPA
Introduction to Industrial Air Emissions Conference 2010