AIR MONITORING


Table 1 summarises the representative regimes required for different purposes of ATA.


Purpose of ATA


Demonstration of compliance with EL


Representative regime


Regime with the highest emissions (rated capacity/maximum normal operating capacity)


Mass fl ow determination Representative regime in terms of year-round operation


Combination


Representative regime both for the determination of mass fl ow and for demonstrating compliance with ELV


Table 2: An overview of the required number of measurements for ATA Technology


Measurand


Measurement period in minutes


Method Number


First measurement Repeated measurement


Continuous, emissions stable, discontinuous Continuous, emissions variable Mass concentration, mass fl ow Up to 59 min 60 and more Up to 59 min A M A M A


2 1


10 5


60 to 179 min 180 and more M A M A M


Number of particular measurements in series on one measurement place 5 3 3 2


5 3


A – continuous instrumental method (e.g. emission analyser) M – manual method (e.g. gravimetric dust sampling)


5) Reporting of the ATA result


- Specifi c content of the report – the report must include all information required by the standard EN ISO/IEC 17025 and standard EN 15259, as well as additional legislative requirements. For example: the report must contain a statement about whether the measurement result complies with emission limits or not


- Statement of conformity with the requirements.


National specifi city and professional capacity In comparison with the prevailing European approach, the Slovak legislative framework for emission monitoring may be considered relatively strict. Particularly in terms of the requirements imposed on authorised and responsible persons.


These requirements go beyond formal measurement competence. They require a thorough understanding of industrial technologies, operating conditions and applicable legislative.


While this approach increases demands on personnel and organisations performing ATA, it has contributed to the development of a highly qualifi ed professional community capable of critically assessing measurement conditions, interpreting results in their technological context and providing meaningful feedback to operators.


This level of expertise enables constructive technical dialogue with operators and often contributes to more reliable emission data and a clearer mutual understanding of monitoring results.


A clearly defi ned framework of professional responsibility and sanctions further reinforces the demanding nature of the Slovak system.


Authorised persons bear material liability for damage caused by improper performance of ATA. This includes damage resulting from the actions of their employees.


In practice, this may include cases where penalties imposed on operators due to incorrect or defi cient measurements are fully or partially borne by the authorised person.


In addition, the Ministry of the Environment may revoke the authorisation of a responsible person. Especially in cases where false or misleading information is provided or where serious or repeated breaches of professional obligations occur despite prior warnings.


This system of accountability signifi cantly strengthens impartiality and reinforces the credibility of emission monitoring results.


The high level of technical expertise achieved under this system is also refl ected in the ability of Slovak authorised persons to successfully operate beyond the national context.


Several authorised entities regularly perform emission measurements abroad. They successfully compete in international tenders, often delivering results with a high level of accuracy and technical reliability.


Slovak Environmental Inspectorate


In addition to ATA performed by external entities, an essential component of the Slovak emission monitoring system is the direct involvement of public authorities in technical control and verifi cation.


An important role in this respect is played by the Slovak Environmental Inspectorate (SEI).


Through its specialised inspectors responsible for technical activities, the SEI carries out its own control measurements of emissions from air pollution sources and performs inspections of AMS.


These activities are conducted under accreditation in accordance with EN ISO/IEC 17025 and EN ISO/IEC 17020, in the same manner as authorised persons.


In addition to these technical activities, the SEI also performs oversight of ATA conducted by authorised and responsible persons.


As a result, the Inspectorate acts as an equal and competent partner in technical and methodological discussions. And it plays a key role in maintaining the overall quality, credibility and consistency of emission monitoring in Slovakia.


History and future


With around three decades of experience in emission monitoring, Slovakia has undergone signifi cant legislative development in this fi eld.


While European Union legislation provides general principles and core obligations, many detailed requirements related to emission monitoring have been developed at a national level.


As practical experience accumulated, Slovak legislation evolved not only to refl ect European requirements where applicable, but also to establish clear and uniform rules and to address practical implementation issues through legislation.


This approach aimed to ensure that emission-monitoring requirements are consistently applicable across all categories of air pollution sources.


For example, from our history, between the years 2003- 2009, Slovak legislation included provisions that considered measurement uncertainty when demonstrating compliance with emission limits.


Decree 706/2002 Coll., as amended by decree 410/2003 Coll., section 3(4) laid down following paragraph:


“4. The emission limit expressed as mass concentration, mass fl ow, smoke darkness or emission level is considered to be complied with in discontinuous authorised measurement and in technical calculation if no individual value after adding the justifi ed value of uncertainty of the measurement result or the result of the technical calculation after adding the uncertainty of the calculation does not exceed the emission limit value..”


This approach was abandoned in Slovakia after a relatively short period. Regulations had to be harmonised with EU law. And, more


The Slovak emission monitoring system currently achieves a high level of quality. This is largely as a result of strict national requirements placed on authorised and responsible persons


Conclusion


importantly, because the wide variety of technologies and waste gas types made it overly complex to defi ne justifi ed uncertainty values for discontinuous measurements, while simultaneously increasing the administrative burden on state authorities.


Here is why we believe this approach is problematic


- Measurement uncertainty involves a signifi cantly higher degree of subjectivity than the measurement process itself, which is largely governed by well-defi ned technical standards. The subjectivity arises due to individual approaches assessing uncertainty contribution and the diverse specifi c infl uences in the fi eld (season, weather, specifi c conditions at the measurement site, etc)


- We think that decreasing measurement uncertainty is a sign of progress in measurement techniques; therefore, subtracting uncertainty from measured results may unintentionally motivate operators to favour measurement approaches associated with higher uncertainty values, which could be advantageous for them


- Indirectly, this could represent a step back in improving the overall quality of emission measurements, while at the same time acting as a demotivating factor for the development of better measurement procedures and equipment


- Another key concern – perhaps specifi c to Slovakia – is that when legislation incorporates elements that are partially subjective, diffi cult to regulate and we cannot ensure consistent control, then such provisions lose their meaning. This creates more uncertainty rather than clarity.


The Slovak emission monitoring system currently achieves a high level of quality. This is largely as a result of strict national requirements placed on authorised and responsible persons.


The key question for the future is how this level of quality can be maintained and preserved over the long term.


These concerns are not unique to Slovakia. They refl ect a broader challenge faced across Europe and beyond, particularly in ensuring the availability of highly qualifi ed personnel for technically demanding work performed outdoors, often under adverse weather and overall risky conditions and with signifi cant responsibility for the resulting data.


In this context, the efforts of the European Union to establish harmonised and generally applicable rules for emission monitoring are highly appreciated.


A more unambiguous and precise defi nition of measurement timing and operating regimes is essential to support high-quality emission monitoring to sustain the professional standards on which such systems ultimately depend. Only then will monitoring results be comparable across Europe.


Mária Machaj,


Ministry of the Environment of the Slovak Republic


Maria.Machaj@enviro.gov.sk


www.minzp.sk/ovzdusie/ochrana- ovzdusia/monitorovanie-emisii/


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