A SWIP needs a Permit to Operate issued by a Local Authority (LA), rather than the UK Environment Agency (EA), following Schedule 13a of the Environmental Permitting Regulations (EPR) issued by DEFRA. The emissions monitoring requirements are based on the Emission Limit Values (ELV) for specific process types, size and fuel variety with recognisable Quality Assurance guidelines to be adhered to. The Industrial Emissions Directive (IED) forms the basis of the requirements which are also used for much larger plant
It is important to discuss the absolute requirements for CEMS with the Local Authority responsible for regulation of the site. The IED allows for certain derogations, or relaxations, to be applied based on the pollution potential of the process. By consideration of plant operations, like fuel composition and abatement plant deployed to reduce emissions, some of the parameters normally requested for continuous measurement may be relaxed to periodic measurement to reduce the regulatory burden on both Operator and Inspector.
Some common combinations of CEMS parameters:
CO, NOx, TOC & Particulates
CO, NOx, TOC, SO2, HCl & Particulates
CO, NOx, TOC, SO2, HCl, HF & Particulates
It is important to start this discussion as early as possible with the Regulator so that clarity of requirements is given in good time. For small processes, the relative capital cost of CEMS, and subsequent Cost of Ownership, can seem disproportionate when compared to Medium and Large combustion processes.
By careful consideration of the Measurement, Operational and Regulatory goals of the process, it is possible to manage all stakeholders’ expectations and efficiently demonstrate on-going compliance.
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