M1 Changes / Requirements
Posted on: April 20, 2010
The have been several changes to the Environment Agency’s (EA) Technical Guidance Note M1 “sampling requirements for stack emissions monitoring” (Version 6, January 2010) which MCERTS contractors and process operators need to be aware of when looking to plan a monitoring exercise, assessing OMA compliance in relation to sampling locations and sampling facilities, or looking to install an MCERTS CEMS system. The correct sampling locations and provision of suitable sampling facilities are key fundamental elements in ensuring good quality test data for use by process operators and associated regulators.
Sampling Locations
EA TGN M1 now has more emphasis on the requirements of the standard “BS EN 15259: 2007 Requirements for Measurement Sections and Sites for the Measurement Objective, Plan & Report”, with further information on its application being provided by an additional EA Method Implementation Document (MID 15259) published in February 2010. One of the key elements, is the assessment of the sampling location for manual sampling as well as for the positioning of CEMs and the requirement to undertake a homogeneity assessment. If a sampling location is not suitable, then the quality of the data produced will have increased levels of measurement uncertainty than that associated with compliant locations.
Note 1: All deviations from standard methods, no matter what the impact on the measurement result, have to be reported as part of the final MCERTS report and as part of the Site Specific Protocol (SSP) / site review document (See EA TGN M2 Version 6, Section 4.10.6).
Sampling Locations - Homogeneity Test
The homogeneity test is applicable mainly to combustion processes. This includes, but is not restricted to, those regulated under the Waste Incineration Directive (2000/76/EC) and the Large Combustion Plant Directive (2001/80/EC).
Note 2: It should be noted though that if Permit requirements dictate, non combustion processes also need to be assessed.
The homogeneity test is usually carried out at a measurement location once only. This must be done at conditions that are representative of the normal operation of the process. However, it may have to be repeated if there is a significant operational change in the process, such as a long term change in load, fuel, abatement technology or ductwork. This is especially critical when looking to install a CEMS system as the results of the test could impact on the type of technology suitable for that location and associated process conditions (e.g. is in-stack or out-stack the best option?)
Note 3: The test is not usually required for stacks with sampling plane areas of <1 m2 (i.e. below 1.13 m in diameter for circular ducts).
Note 4: The homogeneity test is not usually required if the emissions of a pollutant are less than 30% of the ELV (seek approval from the regulator authority to ensure permit compliance)
Note 5: The test should be carried out by an MCERTS contractor at least once.
Sampling Facilities
The Annex 1 section of TGN M1 provides a very useful checklist of “sample facility requirements for plant designers and operators”. This checklist highlights some of the requirements that MCERTS contractors look for as part of the Site Review and will also be documented in the SSP document issued prior to any manual stack emissions monitoring exercise. These requirements are just some of those that the Environment Agency will look for when conducting an OMA Audit. These requirements are re-enforced by the publishing of the new “Applications under the Environmental Permitting Regulations - Assessment of Monitoring Arrangements: Emissions to Air - Version 3, January 2010″ which is the underpinning document that the Environment Agency will use as part of OMA Section 2, element A “Sampling facilities”, one of the key “fundamental elements” of the OMA Version 3 Guidance Document issued by the Environment Agency in April 2009.