Due to the current global pandemic of Coronavirus (COVID-19) spreading to the UK, we feel it necessary to update all current and potential clients about what ECL is doing as a company to support and protect the health and safety of both our staff and their families as well as yours.
ECL remains committed to supporting you and your business throughout this very difficult time.
In order to protect our workforce and our clients, we have temporarily postponed all non-essential routine periodic monitoring. We can and will, however, respond to clients’ needs to undertake essential site-based survey work provided that it is possible to comply with the Government guidelines and those stated in the latest COVID-19 RPS.
In order to comply with Government guidance to meet the conditions of the Covid-19 Lockdown:
- Stay at home
- Protect the NHS
- Save lives
- Only go outside for food, health reasons or work (but only if you cannot work from home)
- If you go out, stay 2 metres (6ft) away from other people at all times
- Wash your hands as soon as you get home
- Do not meet others, even friends or family
- You can spread the virus even if you don’t have symptoms
The Environment Agency has released the following COVID-19 RPS (Regulatory Position Statement) which is active until 30 June 2020 and may be extended if required:
Guidance – Published 16 April 2020
Conditions You MUST Comply With
If you continue to monitor and become aware of exceeding an emission limit value, discharge limit, or other compliance limit value you must notify your Environment Agency area regulatory officer or site inspector immediately.
Here are the conditions you must comply with for each type of monitoring you may be required to do and other general conditions:
Periodic Monitoring of Emissions to Air
You may delay or cancel periodic monitoring if you cannot meet the requirements in your permit because of COVID-19.
- annual and 6 monthly monitoring – you can move this to later in the year
- quarterly monitoring (or any other shorter frequency) – if you cannot complete this in the required period, you may cancel it, rather than reschedule
Continuous Monitoring of Emissions to Air
We consider the following to be business-critical equipment:
- continuous emissions monitoring systems (CEMS), including associated alarms
- for radioactive substances activities, any system used to continuously monitor and sample discharges of radioactive waste to the atmosphere
To minimise travel to site by service engineers who maintain and repair CEMS, and continuous radiological monitoring and sampling systems, you may suspend routine servicing. However, you should make sure you repair essential systems where possible.
If CEMS or continuous radiological monitoring and sampling systems are no longer able to operate and you do not have a spare system, you must contact your area regulatory officer or site inspector immediately. You must explain the situation and how you will minimise the risk to human health and the environment during the time you cannot do continuous emissions monitoring.
You may delay, as required by your permit:
- annual calibrations of CEMS (QAL2 and AST)
- routine calibrations of continuous radiological monitoring and sampling systems required by your permit
You must then reschedule them as soon as you can.
You must continue ongoing quality control (QAL3) of CEMS. As part of your contingency planning you should make sure you have enough calibration and fuel gas.
A COVID-19 RPS means that the Environment Agency will not normally take enforcement action against you provided:
- your activity meets the description set out in this COVID-19 RPS
- you comply with the conditions set out in this COVID-19 RPS
- your activity does not, and is not likely to, cause environmental pollution or harm human health
- you have taken all reasonable steps to comply with your permit
If you operate under this COVID-19 RPS, but think you may no longer be able to comply with its conditions, you must tell the Environment Agency immediately.
The Environment Agency will monitor how operators use and comply with this COVID-19 RPS through its proportionate, risk-based inspection and monitoring activity.
When To Check Back
This COVID-19 RPS will be withdrawn on 30 June 2020 unless we extend it. After this date you must comply with your permit.
Further guidance regarding Monitoring emissions to water, Environmental monitoring and Other general conditions are provided within RPS C7
ECL remains and will always be committed to supporting you and your business throughout this difficult time. If you have any questions or concerns please don’t hesitate in contacting myself or your usual ECL consultant.
We will continue to update you via this blog post and email.
Environmental Compliance Limited
Email: firstname.lastname@example.org– Phone: 01443 841760