Annual Guide 2021 I SOURCE TESTING ASSOCIATION


Here are a few remaining thoughts on the process for refl ection:


Whole environment impact/cross-media effects Industry is keen to play its part in reducing its whole environmental impact and emissions where it is appropriate to do so. A weakness of the BREF process is that it focuses solely on techniques for minimising emissions and reducing emissions limit values. No consideration is given to the wider environmental burdens associated with obtaining and maintaining lower emissions limits, including climate change impacts. For example, a 2 mg/m3


reduction in permitted HCl


emissions could require an additional 4,000 tonnes of lime to be consumed and require recovery annually. In environments where local HCl concentrations are already a very long way below the relevant air quality standard, any marginal change in local air quality should be justifi ed against the increased raw materials consumption, transport and residue recovery impacts. Cross- media impacts were never intended to be considered as part of the BREF review process by the EUIPPC, which seems a strange omission.


CEMS measurement uncertainty


Lowering of emissions limit values will result in increased challenges of meeting the measurement uncertainty requirements of the applicable monitoring standards. These MU requirements are generally a function of the ELV and therefore as the ELV is reduced, so is the acceptable MU. There will likely need to be a further evolution of monitoring systems to facilitate measurements at ever lower emissions if we are to avoid problems of impacting apparent compliance with standards and limits which are essential in maintaining public confi dence in industry.


Standard reference methods (SRMs)


Lower continuous (and periodic) emissions limit values will place additional challenges to SRMs, many of which were developed and validated on emissions that are signifi cantly greater than those that are currently observed. SRMs will need to evolve and adapt to the lower levels of emissions or there will be a need to adopt more management approaches to achieving valid measurements until the technology evolved. For example, operators currently struggle to calibrate particulate emissions under EN 14181 as plant emissions are frequently <0.5 mg/Nm3


with little apparent variability and there are


no suitable surrogates available to challenge the whole measurement system. Work is underway to refi ne the current regulatory position on “indicative CEMS” measurements for particulates and it must achieve the twin objectives of not unfairly penalising operators for reducing emissions to the point where they cannot be reliably measured and providing reassurance to a sceptical public and NGOs that operators are not obfuscating compliance.


Monitoring during OTNOC


Experience to date has shown that this poses considerable challenges to operators and test houses in terms of scheduling the monitoring and undertaking isokinetic sampling on a system that is rapidly changing. It also produces results which are obtained at in stack oxygen concentrations (14% – 19% O2


) that can be a long way from the relevant reference condition (11% O2


) thereby affecting reporting requirements.


It is likely that regulators will take this into consideration in any fi nal position and this could include reporting emissions on a mass-emissions basis.


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