Enforcement of IED and MCP ELVs and next generation Techniques

The aim of this work package is to allow the enforcement of ELVs for newly regulated measurands, to assess the industry’s capability to enforce ELVs for key existing measurands, to provide an evidence base for future reference by the industry and opinion pieces over future direction, whilst also developing techniques to lay a path for enforcement of increasingly stringent ELVs. Specifically, the four areas of work will be:

• To develop new reference methods for HF, NH₃ and formaldehyde and write these into protocol documents for promulgation at CEN/TC 264/WG 3, ISO/TC 146/SC1/WG 33 and CEN/TC 264/WG40, respectively (promulgation will take place under WP4 Impact). (Task 1.1)
• To determine the limitations of the existing SRMs for dust, HCl and SO₂ for enforcing IED (and adopted BAT Conclusions) and MCP emission limit values. (Task 1.2)
• To peer review publish discussion papers providing metrological opinion on the uncertainties in emissions monitoring on industrial process, the limitation of existing SRMs, and how this effects the ability to enforce existing and introduce increasing stringent legislation in the future. (Task 1.3)
• To carry out fundamental work on optical techniques with supporting spectroscopy, laying a path towards future validation and standardisation enabling future legislation to be introduced. (Task 1.4)

Task 1.1: Development and testing of HF, NH3 and formaldehyde reference methods and a “wet” in-situ calibration approach

The aim of this task is to develop new reference methods for HF, NH₃ and formaldehyde and write these into protocol documents for promulgation at CEN/TC 264/WG 3, ISO/TC 146/SC1/WG 33 and CEN/TC 264/WG40, respectively. This will start with a literature review of existing methods at a national level and outside of Europe for HF, NH₃ and formaldehyde. Work will include tests of various possible approaches on Stack Simulator facilities for the latter two measurands. These data will then guide the development of measurement methods written into protocol documents under Task 1.3. In addition, this task will address an important issue within Europe about the in-field calibration testing of the sampling system integrity (i.e. for loss of sample / biases). Under this task a method for generating wet test gas in the field will be developed and characterised. If shown as successful this could form the basis of future CEN standards for reactive measurands at risk of sampling bias such as NH₃ and HCl.

Task 1.2: Limitation of existing SRMs for enforcing new emission limit values

The aim of this task is to characterise the limits of the exiting SRMs for enforcing increasingly stringent ELVs under the IED (and adopted BAT Conclusions) and the MCP, and to carry out an intercomparison of European Stack Simulator facilities, as a precursor to work at CEN standardising inter-laboratory comparisons based on such facilities. Initial work carried out under ENV60 IMPRESS will be built upon it terms of analytical studies of existing HCl and SO₂ datasets and will be combined with SO₂ sampling uncertainty work being carried out under 15NRM01 Sulf-Norm as appropriate. Furthermore, this SRM work will be fed into a model of annualised mass emissions initially developed under ENV60 IMPRESS to determine the impact of the limitations of SRMs on process plant operator annualised reporting.

In addition, the NPL Stack Team will be used as a transfer standard and carry out measurements on the NPL Gas Stack Simulator Facility before repeating the exercise at the INERIS Stack Simulator in France. This will provide pertinent data of performance that will be fed into the CEN Working Group tasked with standardising inter-laboratory comparisons based on such facilities.

Task 1.3: Documentary support for CEN, national regulators and other end users

The aim of this task is to build on the work carried out under Task 1.1 and write developed measurement methods for HF, NH₃ and formaldehyde into protocol documents. These three documents will then be promulgated into standards under WP4 Impact being developed by CEN/TC 264/WG 3, ISO/TC 146/SC1/WG 33 and CEN/TC 264/WG40, respectively.

This task will also produce key discussion papers contributing metrological input into the debate over uncertainties in emissions monitoring and the limitations of the existing suite of SRMs for enforcing increasingly stringent ELVs. Such publications and debate are important in terms of providing an evidence base that policy makers can draw upon in formulating future legislation driving down emissions.

Task 1.4: Next generation techniques and supporting spectroscopy

The aim of this task is to look beyond the immediate legislative need and prepare for legislation of the future. A step change in sensitivity is needed if in the future even more stringent legislation is introduced in an effort to meet WHO air quality guidelines by 2050. Optical techniques potentially offer the sensitivities required as features such as multi-pass gas cells enable very low concentrations to be detected. Whilst technology in principle exists this has not been developed to allow application to the very harsh environment of an industrial stack. This task will carry out fundamental work of technique development and supporting spectroscopy with a view to laying the path towards future validation and standardisation.