An important requirement of licence condition OL_G5 is for you, the duty holder, to document your risk management and monitoring program (RMMP). The documentation serves two purposes: to provide you with a systematic way of identifying and managing risk to human health and the environment at your site; and to demonstrate to EPA how you are complying with licence condition OL_G5 and how you are meeting the GED.
Your environmental documentation may include, but not be limited to:
- conceptual site model;
- risk assessment documents;
- operational control procedures;
- environmental work instructions;
- monitoring results;
- instrument calibration records;
- incident reports;
- training records;
- EPA licence; and
- Permission Information and Performance Statement (PIPS) (formerly the Annual Performance Statement), National Pollutant Inventory (NPI), and National Greenhouse and Energy Reporting (NGER) reports.
Your environmental management documentation should be:
- readily available;
- suitable for use;
- held in a secure place (with copies readily accessible);
- protected from inadvertent or malicious alteration or destruction;
- available to all personnel;
- regularly revised;
- supplied to EPA on request; and
- retained for a minimum of five years.
Monitoring
Monitoring is conducted to provide you with information on the effectiveness of your environmental risk controls, to determine if your emissions are within licence limits, and to determine that the GED is being met. Your monitoring activities may have both strategic and compliance objectives and must be documented in your RMMP.
Depending on the complexity of your activities and your operational control procedures, you may have one or more activities that require monitoring. You should have a monitoring schedule that lists all monitoring requirements for your activities, incorporating upstream, intermediate, and downstream stages. You may need to include lead (proactive) monitoring, for example of materials before they are accepted at your activity site. The frequency of monitoring is set according to the nature of the risk, how critical the control equipment is for managing the risk, how often the control equipment is used, equipment operation and maintenance specifications, industry standard practice, and regulatory requirements, etc.
Monitoring records are an important part of your environmental management and contribute to your evidence of meeting the GED. Your monitoring records might take the form of monitoring logs for individual monitoring stations, electronic process control records (from SCADA/CEMS), a combined log for the site, or analysis reports from monitoring consultants; for example, stack gas analyses. Your monitoring records must be in a legible form, kept in a secure place, and available in a legible form for supply to EPA on request.
The monitoring results need to be reviewed at the time of monitoring to check for compliance with environmental performance objectives, and at intervals to look for trends that might indicate a change in the performance of your environmental protection measures. When looking at the result, check it for general consistency – is it similar to previous results or does it seem to be greatly different. If it does appear to be an odd result, retest the monitoring point to confirm the result (you should have checked the calibration of your monitoring equipment before you conduct the monitoring).
Your monitoring log may include fields for entry of:
- identity of monitoring point;
- location;
- date and time of sampling or observation;
- name of person taking the sample or making the observation;
- monitoring result;
- comments;
- margins of error;
- quality control.
In some circumstances you may need to include monitoring of background conditions where your monitoring requires a reference point. Examples include (but not limited to) background air, soil or groundwater quality.
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