Surrogate and alternative monitoring at waste incinerators and co-incinerators
Published 21 September 2021
Applies to England
© Crown copyright 2021
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This guidance explains what you must do if the following fail:
-
your MCERTS certified, continuous emissions monitoring systems (CEMS) that measure particulate matter, carbon monoxide or total organic carbon
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a peripheral measurement needed to express results at the same reference conditions as the emission limit values (ELVs)
Surrogate monitoring during periods of abnormal operation
Abnormal operations are periods of time when CEMS are unavailable or abatement plant has failed.
During abnormal operations, permits specify that the following emissions must not exceed ELVs that have been put in place for periods of abnormal operation:
- particulate matter
- carbon monoxide
- total organic carbon
You may use surrogates as a substitute for particulate matter, carbon monoxide and total organic carbon.
If you wish to use a surrogate you must demonstrate there is a sufficiently strong correlation between the surrogate and the pollutant it is a surrogate for. You will need to submit this to us for approval.
For example, you may use carbon monoxide as a surrogate for total organic carbon if you can demonstrate a sufficiently strong correlation between them.
Surrogates do not need to comply with the uncertainty budget applied to CEMS.
You must take peripheral measurements of the following to correct results to the same reference conditions that the ELV is expressed at:
- oxygen
- water vapour
- stack temperature and pressure
You may use a substitute for these if they fail.
There is information on substituting missing peripheral measurements in EN 17255-1 Stationary source emissions – Data acquisition and handling systems – Part 1: Specification of requirements for the handling and reporting of data.
Alternative monitoring when CEMS fail for more than 4 hours
Here we describe what you must do when CEMS fail for more than 4 hours.
You may use alternative monitoring as a substitute to CEMS.
Alternative monitoring must meet the same quality requirements as the installed CEMS. This includes the measurement uncertainty requirements specified in the permit for CEMS.
You may use back-up standby CEMS serving the same stacks as the principal CEMS. The standby CEMS must be MCERTS certified for the determinands and ranges that apply. They must also be calibrated for the processes they are monitoring.
You may also use transportable CEMS (T-CEMS). The T-CEMS must be MCERTS certified for the determinands and ranges that apply. They must also be calibrated for the processes they are monitoring.
You may also use manual standard reference methods that can provide real time data. These must be performed by a test laboratory accredited to EN ISO/IEC 17025 for the MCERTS performance standard for manual stack emissions monitoring organisations and the applicable monitoring standards.
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