Role of local authorities
Local authorities decide whether to give a permit. If they do so, they must write down how the pollution is to be minimised.
In the law, the premises are known as "installations". Some are called 'Part B', and local authorities can only deal with air pollution from them. Many different sorts of pollution are controlled at 'Part A2' installations.
Many operators of Part A2 and B PPC installations have permits that contain air emission limits values and conditions requiring continuous and/or periodic monitoring to demonstrate compliance. Emission limits values are generally sector specific and often derived from requirements in BREFs or Sector Guidance notes.
Operators are required to carry out continuous and/or periodic compliance monitoring to demonstrate compliance with air emission limits values.
The Inspectorate also carries out periodic check monitoring to check compliance with air emission limits values and reassure the public. The frequency and scope of check monitoring is risk based and is not a substitute for compliance monitoring carried out by operators.
For more information, view the Environmental permitting general guidance manual on policy and procedures for A2 and B installations on GOV.UK:
Environmental permitting general guidance manual on policy and procedures for A2 and B installations
Demonstrating compliance with air emission limit values in PPC permits
Many operators of Part A2 and B Pollution Prevention and Control (PPC) installations have permits that contain air emission limits values and conditions requiring periodic monitoring to demonstrate compliance.
From 1 January 2014, reports of periodic tests provided by operators to demonstrate compliance with air emission limits values in permits will only be acceptable from stack testing laboratories accredited to ISO 17025 meeting the requirements of DD CEN/TS 15675 and BS EN 15259, (which cover working safely and providing reliable data).
Reports of periodic tests from incinerator, co-incinerator and large combustion plant installations already have to meet this requirement.
UKAS accreditation to ISO 17025 requires stack testing laboratories:
- to have competent staff, appropriate equipment and procedures, [note -NIEA’s preference is for those to be MCERTS standard]
- to supply clients with a site test plan in advance , (in effect site specific protocol (SSP))
- to carry out dynamic risk assessments of test platforms prior to carrying out stack testing work
All operators should provide their site inspector with 14 days advance notice of periodic tests to demonstrate compliance with air emission limit values in PPC permits.
From 1 January 2014, all operators should also provide their site inspector with a SSP produced by the stack testing laboratory 14 days in advance of periodic tests or at least have it available for inspection by their site inspector upon request.
Operators are advised to carry out an audit of their stack testing facilities using Annex 1 - Check sheet of sample facility requirements for plant designers/operators and address any deficiencies.
Safe working monitoring platforms
Operators of Part A2 and B PPC installations are required to provide safe access to facilitate compliance monitoring carried out on their behalf or check monitoring on behalf of the Chief Inspector.
The Environment Agency’s Technical Guidance Note (Monitoring) M1 on Sampling requirements for stack emission monitoring specifies the standards for safe working platforms and obtaining reliable data, which is based upon the requirements of BS EN 15259.
NIEA’s policy in relation to M1 is as follows:
- all new plants need to meet the requirements of M1 prior to operating
- all existing incinerator, co-incinerator and large combustion plant installations should have already been upgraded to meet the requirements of M1
- all existing installations should aim to meet at least the basic health and safety requirements of M1, by ensuring that working platforms and access to them meet the requirements of The Work at Height Regulations (NI) 2005.
The degree of flexibility that can be afforded to operators for deviations from any criteria in M1 will be determined on a site by site basis and it may be necessary to consult Health and Safety Executive NI if it involves the best way to minimise risk.
BS EN 13284, (the most appropriate standard for particulate monitoring requiring bulky equipment), specifies the size, floor loading and access requirements, which effectively rules out most mobile elevated work platforms, (MEWPs or cherry pickers), or ladders as they usually do not provide safe enough working conditions. Guidance issued by the Source Testing Association, the appropriate body for the monitoring industry states that
“mobile elevated work platforms are usually inappropriate for the majority of stack emissions monitoring work … sampling from ladders is always unacceptable”.
NIEA’s preference is for permanent working platforms, however, scaffolding certified to Scafftag© “Heavy Duty” category is an acceptable alternative to permanent platforms for particulate emissions monitoring.
The equipment required to carry out particulate emission monitoring is bulky so the main health and safety concerns are as follows:
- safe access to the platform
- safely lifting bulky equipment onto the platform (note that cherry pickers and fork lifts are acceptable techniques)
- size of the platform to allow bulky equipment to be safely maneuvered around
- work/load capacity of the platform that has been checked by an appropriately qualified person
- rest station(s) if ladder is more than 9m high
- ladder with safety hoops and properly attached
- toe guards and hand rails
- no gaps between top of ladder and the platform
- no reaching over hand rails to insert equipment
- no slipping or tripping hazards, (for example no slippery/sloped floors, no upturned handles on the floor)
Records of inspections of working platforms by competent persons are important requirements of The Work at Height Regulations (NI) 2005, which should be available upon request, especially prior to use.