Guidance on Ensuring High Quality Emissions Monitoring Data

One of the primary aims of the IPPC licensing system is to prevent, reduce and eliminate pollution and the IPPC Directive specifically requires that a permit/licence should ensure that no significant pollution is caused. Many industrial activities emit pollutants to the atmosphere and to surface waters/sewers. In these situations the quantity of pollutants which can be released are typically specified in the licence, with the emission limits being set at a level where it is considered that no significant environmental impact will be caused (e.g. impact on humans and on the wider ecosystem).

IPPC licences also include requirements for periodic check monitoring of emissions to verify that emissions are below the specified Emission Limit Value (ELV), while some licences also include requirements for continuous monitoring of emissions. It is in the interests of both the EPA and the licensee that such periodic and continuous sampling and any subsequent laboratory analysis is carried out in such a way that the results produced are accurate and reliable and are representative of emissions from the activity.

There is flexibility in licences which allows for a reduction in the frequency and scope of monitoring, and also in the methods used. Ultimately, providing a high level of confidence in the monitoring data submitted to the Agency could potentially strengthen the case for a licensee in requesting a reduction in the frequency of monitoring (where the reported results are consistently compliant). This could provide significant cost saving benefit for licensees.

This web page provides some informal guidance to licensees on ensuring quality of monitoring data in relation to monitoring of emissions to air and water.

There are several measures which a licensee can easily take as a means of improving the quality of self monitoring data:

Ensure that personnel/companies carrying out sampling and analysis have appropriate training, qualifications and experience. Ask the contractor for evidence of experience and expertise;
Ensure in-house staff and also contractors carry out monitoring in line with documented procedures that meet the requirements of EPA best practice guidance and/or applicable standards;
Ensure monitoring procedures are suitable for the matrix being analysed;
Ensure monitoring procedures have been assessed for their suitability for the test matrix i.e. wastewater, potable or saline water procedures;
Ensure monitoring procedures are suitable in terms of their range and limit of quantification to adequately determine compliance;
Ensure monitoring procedures are fit for purpose, which is to say they adequately demonstrate compliance within acceptable performance characteristics. The need for expensive complex procedures may not always be necessary, where other methods can be shown to be suitable;
Ensure monitoring equipment is calibrated and maintained in such a manner as to ensure the quality of the data produced;
Ensure all monitoring conducted is subject to a programme of analytical quality control (AQC);
Carry out occasional audits/assessments of the work that a contractor is doing at your site. Identify and request information on quality control measures in place, e.g. how is the chain of custody maintained for collected samples?
Critically review the reports from contractors (or from in-house monitoring) to familiarise yourselves with the monitoring process and also to compare the methods used against best practice;
Ensure that the report produced is concise and self explanatory, and contains an Executive summary which clearly sets out the type of monitoring undertaken on site and the main findings and recommendations from the results obtained;
Ensure that the report produced includes a note on the units of measurement, the sample collection and analysis date and where applicable, the chemical form the parameter was measured as e.g. NH₄/NH₃/N or VOCs (as C). The ‘measured as’ in which the parameter is reported should be sufficient to demonstrate licence compliance;
Have a system in place to tabulate and graphically present monitoring and quality control data on an ongoing basis. This will allow any significant variations in emissions or control standards to be easily noted and the causes identified, whether it be related to the monitoring itself or to problems within the process.

The licence itself includes several conditions requiring emissions monitoring to be carried out to a high standard. Typical conditions include:

6.1 The licensee shall carry out such sampling, analyses, measurements, examinations sampling, analyses, measurements, examinations, maintenance and calibrations as set out below and as in accordance with Schedule C: Control & Monitoring, of this licence.

6.1.1 Analyses shall be undertaken by competent staff in accordance with documented operating procedures.

6.1.2  Such procedures shall be assessed for their suitability for the test matrix and performance characteristics shall be determined.

6.1.3  Such procedures shall be subject to a programme of Analytical Quality Control using control standards with evaluation of test responses.

6.1.4  Where any analysis is sub-contracted it shall be to a competent laboratory.

6.2 The licensee shall ensure that:

(i) sampling and analysis for all parameters listed in the Schedules to this licence; and

(ii) any reference measurements for the calibration of automated measurement systems;

shall be carried out in accordance with CEN-standards. If CEN standards are not available, ISO, national or international standards that will ensure the provision of data of an equivalent scientific quality shall apply.

6.3 All automatic monitors and samplers shall be functioning at all times (except during maintenance and calibration) when the activity is being carried on unless alternative sampling or monitoring has been agreed in writing by the Agency for a limited period. In the event of the malfunction of any continuous monitor, the licensee shall contact the Agency as soon as practicable, and alternative sampling and monitoring facilities shall be put in place. The use of alternative equipment, other than in emergency situations, shall be as agreed by the Agency.

6.4 Monitoring and analysis equipment shall be operated and maintained as necessary so that monitoring accurately reflects the emission/discharge (or ambient conditions where that is the monitoring objective).

Other conditions which are relevant to monitoring include:

6.5 The frequency, methods and scope of monitoring, sampling and analyses, as set out in this licence, may be amended with the agreement of the Agency following evaluation of test results.

6.6 The licensee shall, within six months of the date of grant of this licence, develop and establish a Data Management System for collation, archiving, assessing and graphically presenting the monitoring data generated as a result of this licence.

6.7 The licensee shall record all sampling, analyses, measurements, examinations, calibrations and maintenance carried out in accordance with the requirements of this licence and all other such monitoring which relates to the environmental performance of the installation/facility.

6.8 The licensee shall clearly label and provide safe and permanent access to all on-site sampling and monitoring points and to off-site points as required by the Agency. The requirement with regard to off-site points is subject to the prior agreement of the landowner(s) concerned.

For specific advice in relation to ensuring the quality of air emissions monitoring data click here.

For specific advice in relation to ensuring high quality aqueous emissions monitoring data click here.

To access videos of the presentations given at the EPA's Industrial Air Emissions Conference in October 2010 please click here.

To access the presentations and checklists given at the conference for the Quality of Aqueous Monitoring Data Reported to the EPA, in March 2011 please click here