Combining UK and German emissions monitoring proficiency testing data based on stack simulator facilities to determine whether increasingly stringent EU emission limits are enforceable

Abstract

We report an examination of the capability of the existing measurement infrastructure in the industrial emissions sector for successfully enforcing emission limits across three generations of legislation: the Waste Incineration Directive and Large Combustion Plant Directive (WID and LCPD); the Industrial Emissions Directive (IED) which superseded the aforementioned directives in 2013; the Waste Incineration and Large Combustion Plant Best Available Technique Reference documents (BREFs) where the former is currently at the draft stage (WI BREF and LCP BREF). The significant volume of proficiency testing data based on semi-tech stack simulator facilities operated by the National Physical Laboratory in the UK and the Hessian Agency for Nature Conservation, Environment and Geology in Germany were combined into a unique database. The emission species considered and their associated standard reference methods (SRMs) were: CO EN 15058; NOx (NO + NO2) EN 14792; total organic carbon EN 12619; total dust EN 13284-1. Collectively analysing participant distributions from 2002 to 2015, it was found that emission limits: under the WID and LCPD could be enforced (the directives for which the SRMs were originally designed); under the IED could in principle be enforced; under the WI BREF and LCP BREF would struggle to be enforced. This evidenced the need for improvements in the existing measurement infrastructure, without which test laboratories would struggle to provide the data quality needed by process plant operators for reporting into national emission inventories, and for national regulators who are legally responsible for enforcing emission limits aimed at improving European health and environmental impact.