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Monitoring & Reporting Guidelines

This article provides guidelines and solutions for monitoring and reporting uncertainties in the context of environmental regulations. It addresses challenges in various industries and explores the importance of accuracy and precision in measurements.

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Monitoring & Reporting Guidelines

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  1. Monitoring & Reporting Guidelines remarks on Reporting, Uncertainties, CEMs Chris Dekkers Directorate of Climate Change & Industry Ministry of Environment (VROM)

  2. Definitions in M&R Guidelines Definitions & Principles not sufficiently precise for translation into national legislation-regulation: • Level of assurance: what level of assurance obliged by the verifier? • Materiality: the exact and precise definition of what is required? • Monitoring methodology: QA and QC part of the permit? • Legal requirements not clearly and consistently formulated and not sufficiently precise in legal sense • Precise criteria lacking: “technically not feasible” , “economically not justified” • Difference Uncertainty – Accuracy - Precision not clearly explained • How to use “cost effectiveness” in practical situations? • How to use principles of Good Governance in practical situations?

  3. Uncertainty Aspects VROM initiated two studies by KEMA: Assess uncertainty approach in M&R Guidelines and propose solutions • Current practice • Practicability of TIER approach • Practical experiences • Assess improvements to be made

  4. Current Practices • Required tier achievable in Power Plants and in general: industries buying fuels from outside • Problems arise in sectors generating their own fuels: refineries, production of base chemicals, coke in steel manufacturing • Current practice built on technical assumptions on uncertainties

  5. Sectors with own fuels Major differences between various refineries, chemical plants and steel producing plants: • Uncertainties directly related to type of internal produced fuel, variations in these fuels and number of measure points • Uncertainties often installation specific, depending on the number and type of processes • Tiers reported based on assumed uncertainties of various meters • Uncertainties of meters rarely tested for wear & tear: reported uncertainties have an “artificial” element

  6. Leads to following Questions: • Uncertainties of meters rarely tested for wear & tear: Should we require that: • real world uncertainties be measured? • measured values be used? • reported uncertainties be demonstrated? • If so, how? • When is uncertainty acceptable and when should further investments in new meters be justified? • How can we make concept of cost effectiveness applicable in real world situations? • On what basis does Competent Authority decide that further improvements are justified?

  7. Other observations Requirements on verification are not sufficiently clear and defined in legal terms • What level of assurance is to be provided by the verifier, what does it imply and what is the basis for that? • Accreditation: should MS have their own accreditation schemes or should there be common standards and procedures? • How does the requirement of accreditation comply with the draft directive on services? In category C installations all sources to be measured with highest tier. This may result to odd decisions • How to decide for which situation highest tier for all sources is justified - when not? De-minimis criterion not always applicable • How to assess uncertainty and further improvements in complex installations?

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