Gasmet EMISSIONS MONITORING HANDBOOK

Emissions monitoring
handbook
Waste incineration / Waste-to-energy /
Co-incineration of waste / Large combustion plants /
Cement kilns / Chemical plants and related industries
Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Emissions monitoring handbook
Introduction
This handbook is designed to give you an overall picture of the requirements, regulatory
framework, practicalities, and solutions in gas emissions monitoring. The focus is on European
regulatory requirements and how they are applied in practice. The same or similar requirements
are also used in many other countries, for example, in South-East Asia and the Middle East.
Therefore, the information presented here can be useful also outside of Europe. US EPA and
similar EPA requirements are not covered by this handbook.
Applications covered in this handbook include mainly large industrial plants requiring
continuous emissions monitoring. Main applications covered are waste incineration (WI), also
referred to as waste-to-energy (WtE), co-incineration of waste (co-WI), large combustion plants
(LCP), cement kilns, and chemical plants. Smaller installations, such as small power plants and
marine industry, are not included.
The handbook is based on the wide experience gathered by Gasmet over decades. For any
comments or additional information, please reach out to contact@gasmet.fi.
In Helsinki, Finland
November 2022

Emissions monitoring handbook
Contents
Industrial emissions monitoring regulations and practices...................................................................... 1
Industrial Emissions Directive (IED) sets the upper level targets ..................................................................... 1
Industries have their own BAT processes .......................................................................................................... 3
Emissions monitoring standards determine the technical details ................................................................... 4
Quality Assurance Levels (QALs) ensure the standards are followed ............................................................. 5
National authorities issue environmental permits ............................................................................................. 8
Common practices for emissions monitoring ................................................................................................... 9
Emissions monitoring for waste incineration or waste-to-energy is a demanding task .......................... 10
Typical characteristics of waste incineration .................................................................................................. 10
WI BREF describes the best available techniques in waste incineration .......................................................10
Emissions monitoring in practice ..................................................................................................................... 13
Large combustion plant (LCP) emissions monitoring is easier to control .............................................. 17
Typical characteristics of large combustion plants (LCPs) ............................................................................ 17
LCP BREF describes the best available techniques for large combustion plants .........................................17
LCP emissions monitoring in practice ............................................................................................................. 21
Emissions monitoring in other facilities ................................................................................................ 22
Cement kilns ...................................................................................................................................................... 22
Chemical plants and related industries ............................................................................................................ 22
Smaller installations .......................................................................................................................................... 23
The most commonly used emissions monitoring technologies ............................................................. 24
FTIR..................................................................................................................................................................... 24
NDIR .................................................................................................................................................................... 25
Laser ................................................................................................................................................................... 26
Mercury monitoring technologies ..................................................................................................................... 27
Continuous or discontinuous mercury emissions monitoring ........................................................................28
Dioxin sampling technologies ........................................................................................................................... 29
Other typical technologies ................................................................................................................................ 30
The future of emissions monitoring ...................................................................................................... 31
Gasmet Technologies ........................................................................................................................... 32
CEMS II e /ef for demanding applications ...................................................................................................... 32
CMM AutoQAL and CMM for continuous mercury monitoring .......................................................................33
GT90 Dioxin+ for long term dioxin sampling ................................................................................................... 33
DX4000 for applications with multiple gas compounds ................................................................................. 34

1 / 34 Emissions monitoring handbook
Industrial emissions monitoring regulations and practices

In the era of bustling industrial activity and growing number of industrial plants, regulation and
continuous monitoring of emissions have become increasingly important.
Despite the fact that emissions monitoring is a standard and fairly straightforward process for
all industrial plants, it is of utmost importance: it protects nature and human beings proactively
and ensures the safety of us all. In addition, by effective process optimization we can save a lot
of valuable resources.
Emissions monitoring is challenging because of the operational environment, where regulations,

standards, and processes are always changing and evolving. As the operational environment
changes, the emission limits and allowed gas concentrations change, too. This, in turn, requires
the emissions monitoring stakeholders to be able to continuously adapt and reassess the
procedures and technologies.
In this chapter, we will look at the different regulations and practices for emissions monitoring.
Industrial Emissions Directive (IED) sets the upper level targets

Directive 2010/75/EU of the European Parliament and the Council on industrial emissions (the
Industrial Emissions Directive or IED) is the main EU instrument for regulating pollutant
emissions from industrial installations.
There are around 50,000 installations taking part in industrial activities that must be operated in
accordance with a permit (granted by the authorities in the Member States). This permit should
contain conditions set in accordance with the principles and provisions of the IED.
The measured components depend on various factors, such as the industry, the burned fuel,
and the size of the plant. The environmental permit of a plant defines which gases and
components must be monitored and what their set limits are. For example, both small and large
coal-fired power plants have their own, separate regulations.

The IED is based on five main principles:
1. Integration: Full environmental effect of the plant needs to be considered. This includes,
for example, emissions to air, water and land, generation of waste, use of raw materials
and energy efficiency.
2. Best Available Techniques: The plant emission limit values must be based on the Best
Available Techniques (BAT). BAT documents describe the best available techniques for
controlling, reducing, and monitoring the environmental effects of the plant.
3. Flexibility: Competent local authorities have some flexibility to set higher emission limit
values in cases where following the BAT conclusions would lead to disproportionately
high costs considering the local conditions.
4. Inspections: Facilities need to be inspected and the quality of the operations and
systems followed regularly.
5. Openness: The public has a right to participate in the decision-making process and to be
informed of its consequences.
The IED was adopted in November 2010 and came into force January 2011. It replaced seven
previously existing directives with the aim of a higher level of protection of human health and
the environment as a whole.
On April 2022, the European Commission (EC) released a proposal to revise the IED. Some of
the key changes proposed by the Commission include:
> National authorities should, by default, assign the lowest possible emission limit values
(ELVs) that the facility can reasonably achieve. Currently, 80% of installations have the
ELVs set according to the highest possible emission limit enabled in the BAT document
(BAT-AEL). The EC would like to change this and make it substantially more difficult to
justify high ELVs. Also, the relevant justifications for exceptions would be harmonized
among the member states.
> The scope of IED would be expanded to include the mining industry and gigafactories.
Also, additional farming activities would be part of IED.
> Information sharing to public about ELVs and actual emissions would be more
automatic and facilitated (E-PRTR).
A European Industrial Emissions Portal is already available with limited open data on pollutant
releases.

The proposition will be subject to discussion and modifications. Preparing new BAT documents
is estimated to begin in 2024.
Industries have their own BAT processes

IED relies heavily on the process of establishing the Best Available Techniques (BATs) for each
industry. IED-regulated industries are inherently different, making it impossible to establish one
set of detailed emission limits, abatement techniques, and other similar guidance to cover them
all. However, the aim is the same – to reach the best possible performance, taking into account
the specific conditions of each industry. This aim is reached through the BAT documents where
these conditions are considered.
To define BAT and the BAT-associated environmental performance at the EU level, the
Commission organizes an exchange of information with experts from the Member States,
industry, and environmental organizations. This work is coordinated by the European IPPC
Bureau at the EU Joint Research Centre in Seville, Spain. This process, often referred to as the
Sevilla process, produces the BAT Reference Documents (BREFs). The BAT conclusions
contained in the BREFs are adopted by the Commission as Implementing Decisions. The IED
requires that these BAT conclusions are the reference for setting permit conditions.
BREFs impose, for example, what kind of emission limits each industry must have and how they
need to be measured, either continuously or periodically.
As of September 2022, there are 35 BAT reference documents published in

https://eippcb.jrc.ec.europa.eu/reference. For gas emissions control from large industrial sites,
the most substantial ones include WI BREF for waste incineration and LCP BREF for large
combustion plants.
The aim has been to revise the BAT documents every 8–10 years. With the new IED, the aim is
to make the update circle more frequent to make sure the current best available techniques are
always included to the documents.
Essential terms:
BAT = Best Available Technique, a technique or limit that, based on experience, has proven to be
effective in a certain industry to meet IED requirements
BREF = Best Available Technique reference document, an official document collecting all
industry-specific BATs together
BATC = Best Available Technique conclusion document, a conclusion or abridgment document

with the most essential information in a BREF.

BAT-AEL = BAT-associated emission limit value, an emission limit value that can be set based
on the requirements on the BREF
Emissions monitoring standards determine the technical details

While the IED sets the upper-level targets for reducing and following industrial emissions and
the BAT process sets the abatement technologies to be used and subsequent ELVs, the
technical details on how different gas components should be measured cannot be set in these
documents. The technical details are determined in an open standardization process, managed
by CEN, the European Committee for Standardization.
In the CEN working groups, industry experts gather to standardize the methods of how gas
emissions can be measured. Anyone can propose new work items, and existing standards will
be reviewed and updated every five years, if needed.
The table below includes selected essential emissions monitoring standards. They have been
divided into two parts. First part consists of standards relating to automated gas measurement
or collection systems. AMS refers to the measurement system, which is often also called CEMS,
continuous emissions monitoring system. The second part lists the standard reference
methods (SRMs), which are often manual methods used to provide a result accurately, so that it
can be used as a reference for other, more automated methods.
Standard Explanation
EN 15267-1 General principles on the certification of an automated measurement system (AMS)
EN 15267-2 How to assess and monitor the quality system of an AMS manufacturer
EN 15267-3 How to certify a stationary AMS
EN 15267-4 How to certify a portable AMS
EN 14181 How to ensure the quality of an AMS after installation during its lifetime
EN 14884 How to ensure the quality of a mercury-AMS
EN 17255 Requirements for data handling and acquisition (DAHS) systems
EN 1948 How to determine the amount of dioxins in flue gas
EN 13284-2 How to ensure the quality of a particulate matter-AMS
EN 16911-1 SRM for velocity and volume flow rate
EN 13284-1 SRM for particulate matter
EN 13211 SRM for mercury
EN 14791 SRM for sulfur dioxide
EN 14792 SRM for nitrogen oxides
EN 21258 SRM for nitrous oxide
EN 21877 SRM for ammonia
EN 15058 SRM for carbon monoxide

CEN/TS 17405 RM for carbon dioxide

EN 1911 SRM for hydrogen chlorides
EN 12619 SRM for hydrocarbons (FID)
Quality Assurance Levels (QALs) ensure the standards are followed

Due to their high importance, continuous emissions monitoring systems (CEMS) have strict
quality criteria. Their fit for purpose and accuracy over their entire lifespan is ensured by several
quality assurance steps. Quality Assurance of CEMS is divided into four Quality Assurance
Levels: QAL1, QAL2, AST (Annual Surveillance Tests) and QAL3.
QAL1
QAL1 refers to the type approval that ensures the fit for purpose for a CEMS. The procedure of
how to obtain a QAL1 certification is described in EN 15267. A CEMS system requires a QAL1
certificate to be able to use it in a regulated emissions measurement.
QAL1 requires that instruments are shown to be suitable for purpose based upon a set of
laboratory and field tests. Testing must be carried out by an approved laboratory accredited to
EN ISO/IEC 17025 by a national body. In practice, QAL1 testing is conducted in Europe mainly by
TÜV in Germany and MCERTS in the UK.
QAL1 aims to find out whether the selected measuring equipment for a plant is effective enough
and meets not only the required legal criteria, but also the needs of an industry operator. This
includes the analyzer system itself as well as the sample delivery and sample conditioning
system, so it is an assessment of a complete measuring system.
QAL1 certificates are public and can be found on TÜV (www.qal1.de) and MCERTS
(https://www.csagroup.org/en-gb/services/mcerts/mcerts-product-certification/mcerts-
certified-products/) databases respectively.
For an operator, it’s important to examine the certificate of any potential supplier carefully to
make sure there are no inconvenient limitations on the use of the CEMS for the desired
application.
QAL2
Once the most suitable certified system for the continuous emissions monitoring has been
decided, purchased, and commissioned, the quality and accuracy of the installed system needs
to be verified. This part of the quality assurance is called QAL2.

QAL2 consists of calibrating the installed CEMS and verifying its accuracy and completeness.
QAL2 is done independently by a test organization typically accredited to EN ISO/IEC 17025 by a
national body. These organizations are sometimes called “stack testers”.
The calibration of the CEMS is done against nationally approved analytical methods. These are
either standard reference methods (SRMs) as described by international standards or
alternative methods (AM) that have been shown to provide similar data quality as the SRMs. For
example, the SRM might be based on wet chemistry method where the sample is collected at
the stack and subsequently analyzed in a lab. The AM for the component might be a portable
FTIR system giving the results in real time.
The verification of the system accuracy and quality is done after the calibration as described in
EN 14181. The tests include, for example, a leak test, zero and span checks, linearity test,
interferences tests and drift tests. For mercury and dust, also complementing standards have
been formed.
Typically, QAL2 tests are carried out every 5 years (as defined in the site’s environmental
permit). However, it is important to point out that if there are any major changes made to the
plant or the process being measured that might affect the emissions (either positively or
negatively) or the ability of the CEMS to measure a parameter, an operator must have the CEMS
re-evaluated and conduct another QAL2 assessment. A major change could mean, for example,
a change in the fuel types, an alteration to the combustion or incineration processes, or anything
that might radically change the emissions.
While the QAL1 tests are being conducted in a controlled manner in a limited amount of sites by
a few people, QAL2 tests are being done in different countries by different organizations and
different testers. This makes the exact testing practices less uniform and causes variability on
the results obtained. Therefore, the QAL2 tests are a very important extension of QAL1 tests in
determining the fit for purpose of the system. The higher the system quality including accuracy,
repeatability, and real-application endurance, the higher its chances are to passing the QAL2
tests without issues.
AST (Annual Surveillance Test)
While the CEMS doesn’t need to be calibrated every year against the SRMs, it has been seen
necessary that a 3rd party verifies the performance of the CEMS annually. This test is called the
Annual Surveillance Test (AST).
Annual Surveillance Tests are very similar to the system verification part of QAL2 tests, but they
are carried out in a smaller scale. These mini-QAL2 tests are functional laboratory spot tests
that map out the performance of a CEMS.

Their purpose is to verify the continuing validity of the calibration function. The requirements
and responsibilities for carrying out the AST tests are the same as for the QAL2. The tests are
described in the EN 14181 standard and the same test laboratories perform both tests.
Part of the AST is to examine the QAL3 results obtained during the operational year.
QAL3
QAL3 refers to the ongoing monitoring of a CEMS between the QAL2 and AST tests. Operators
are required to follow the stability and performance of their monitoring systems.
With QAL3 monitoring, industrial plants can spot any drifts in the zero/span levels and point out
if the system has any needs for maintenance.
QAL3 consist of zero and span checks. In a zero check, a gas matrix without the measurement
gas component present is measured. For example, for the FTIR method, the zero check is done
with nitrogen. The purpose is to make sure the system can accurately measure zero values.
In span checks, a controlled amount of a measurand is introduced into the system and the
result given by the system is compared to the known concentration. The span gas can be
introduced from a gas bottle with traceable gas concentration (for example carbon monoxide in
nitrogen) or the span gas can be created using a test gas generator (for example mercury
chloride in mercury-CEMS). The practices on which gases to use in span tests differ from
country to another and depend on the CEMS.
In principle, span checks should be made with all the measurands the system is measuring,
according to its certification. In practice, some components might be skipped due to the
inability to have a span gas with a reliable concentration. Hydrogen fluoride, HF, is a common
example. Mercury-CEMS are spanned with ionic mercury, in practice with mercury chloride.
EN 14181 recommends that plant operators start collecting data for QAL3 immediately after the
CEMS has been installed and commissioned. This ensures that there is enough reported
information of the performance and functionality of the monitoring system and helps reduce the
chances of the measurement system not meeting the requirements as set out in QAL2. This
bedding-in period is typically around 3 months, though on very stable processes with good
performing systems, this period is often reduced.
The minimum interval for QAL3 is defined in the QAL1 field test. QAL3 tests need to be
performed at least once per the maintenance interval of the CEMS. Typical maintenance
intervals span between 1–12 months. It is typical for many CEMS to have 1–2 maintenances
per year while the other possible maintenances in between are merely visual checks and span
checks.
Roles and responsibilities in quality assurance
QAL1, QAL2, AST and QAL3 require co-operation of several parties.

Suppliers and Manufacturers of CEMS:

> QAL1 certificates for CEMS
> Appropriate and safe installation of a CEMS
> Cooperation with the plant operator before QAL2 and AST tests (and during, if
necessary).
Test Laboratories / “Stack testers”:

> Maintenance of accredited Standard Reference Methods for QAL2 and ASTs.
> Functional tests (QAL2 and AST): sampling or auditing the test results by other parties.
Note: Functional tests can be carried out by the manufacturer, the supplier, or the system
integrator. It is the responsibility of the Test Laboratory to ensure that such tests are carried out
correctly.
Industrial Plants / Process Operators:

> QAL2, QAL3 & AST reporting to regulators and local authorities
> Performing QAL3
Regulators / Local Emissions Authorities:

> Assessing operator compliance
> Assessing test laboratories
> Providing guidance on EN 14181
National authorities issue environmental permits

The environmental permit is the official document a facility needs to follow to fulfill its
environmental requirements. The permit dictates, for example, the emission limit values (ELVs)
for the gas emissions and whether the emissions need to be monitored continuously or whether
periodic measurements suffice. The national authorities in each country are responsible for
issuing these environmental permits.
While the permits are based on the requirements set in the IED, the BAT documents and the
standards, there is still room for substantial national consideration and adaptation. In the end,
it’s the national authorities that will consider the local special conditions in the country overall
and for each facility in particular.
In its proposal for an updated IED the European Commission is limiting the ability of the national
authorities to make exceptions to the environmental permits. In any case, the national
authorities will, in the end, issue the environmental permit.
In addition to the ELVs, the practices approved or disapproved by local authorities could include
questions, such as when the ELV conditions are seen to be met and which technologies are

approved. For instance, the total volatile organic carbon (TVOC) has flame ionization detector
(FID) as its standard reference method. However, in some countries also FTIR is approved for
the same measurement while in others it cannot be used. Another typical example are the
detailed practices of QAL 2 / AST / QAL 3 measurements that can differ country by country due
to local interpretations.
Common practices for emissions monitoring

It is paramount that plants choose appropriate technologies and devices for the emissions
monitoring. It should be ensured that the device is sensitive enough to detect even the smallest
levels of a component, as some industrial plants have very low and strict emission limit values
for certain gases.
Independent of the monitoring technology, there are common practices that should be
considered.
Typical set-up and representative measurement site
Suitable measurement sections and measurement sites are necessary in order to obtain reliable
and comparable emission measurement results. Therefore, appropriate measurement sections
and sites must be planned when designing a plant.
1. Measurement sections and sites

The measurement section must be selected based on the location where the
disturbance of the gas flow is as minimal as possible. However, the most important
thing to consider is the homogeneity of the sample gas. Therefore, the foot of a stack is
not necessarily the most favorable location for measurement, as gas flow and
monitoring can be affected by the turbulent circumstances of the foot area that make
the gas ununiform.
2. Measurement ports and working platforms

Emission measurements also require appropriate measurement ports and working
platforms. Therefore, the installation of measurement ports and working platforms must
be taken into account in the planning phase of a measurement section.
3. Equipment and safety conditions

Sufficient and safeguarded power connections need to be installed at the measurement
site in accordance with the national requirements. Compressed air, water connections,
and wastewater disposal should also be considered, if necessary. The instalments of
measurement sites must comply with national safety at work requirements.
Plant operators and measurers should consider the following aspects:

> Easy and safe access to the measurement site

> Ensuring that personnel carrying out the emission measurements are informed of any
operating faults which would endanger them
> Protection of the working area from heat and dust
> Weather protection and heating to ensure the necessary environmental conditions for
the personnel and the equipment
Emissions monitoring for waste incineration or waste-to-

energy is a demanding task
Typical characteristics of waste incineration
Waste incineration (WI), or Waste-to-Energy (WtE), is a demanding application for emissions
monitoring. Compared to most other incineration types, the fuel is more heterogeneous and
contains more materials that can potentially form harmful gases during the process. As a result,
WtE plants have strict emission limit values and a broad responsibility to measure many gas
components continuously.
Measurement requirements may also depend on what kind of waste is being incinerated.
Hospital waste and hazardous waste have typically the strictest requirements. Mixed municipal
waste varies in content and often also has strict requirements. For sorted mono streams of
waste, the requirements may be less strict if the content of the waste stream is controlled well.
If the incinerated waste contains treated wood, the plant may be required to measure
formaldehyde emissions in addition to the typical measurements.
WI BREF describes the best available techniques in waste incineration

The latest WI BREF was accepted by European Integrated Pollution Prevention and Control
Bureau (EIPPCB) in summer 2019 and the WI BAT conclusions published on December 3rd,
2019, under the IED Directive 2010/75/EU.

The revised BREF defines the technical basis and BAT-associated emission levels (BAT-AELs)
for national authorities in the EU to set operating permits for installations. The BAT-AELs work
as a framework for authorities to set plant-specific ELVs (Emissions Limit Values). WI BREF
applies for facilities incinerating more than 3 tons per hour of non-hazardous waste or more
than 10 tons per day hazardous waste. Smaller facilities are under national legislation.
Regardless of whether the BAT-AELs change or not, all environmental permits of existing waste
incineration installations in Europe need to be reviewed during the implementation period of
four years. This may cause changes in the plant-specific ELVs (within the limits defined by the
BAT-AELs). In practice this means all facilities need to comply with the requirements by
December 2023.
New installations must comply with the new requirements immediately without any
implementation period. Even though in different countries and plants the specific ELVs may
differ, they need to be set according to the BAT-AEL requirements.
Key findings for emissions monitoring
The table below compares the ELVs from 2006 WI BREF to the IED limits and 2019 WI BREF
ELVs for the components that should be measured continuously. It should be noted that the
2006 WI BREF values were not legally binding and were determined from actual average
operational values. However, the IED limits are legally binding.
2006 2019
Daily average for Daily average for
Component Daily average IED limit Unit
new plant existing plant
HF <1 1(±0.4) <1 <1 mg/Nm3
HCl 1-8 10(±4) <2-6 <2-8 mg/Nm3
SO2 1-40 50(±10) 5-30 5-40 mg/Nm3
NH3 <10 - 2-10 2-10 mg/Nm3
NOX 40-100 200(±40) 50-150 50-150 mg/Nm3
CO 5-30 50(±5) 10-50 10-50 mg/Nm3
TOC 1-10 10(±3) <3-10 <3-10 mg/Nm3
Hg - - <5-20 <5-20 µg/Nm3
Dust 1-5 10 <2-5 <2-5 mg/Nm3
BAT-associated emission levels (BAT-AELs) for continuously measured channeled emissions to air

As can be seen on the table, the requirements for HF, CO, and TOC have remained the same.
HCl and SO2 have slightly reduced ELVs especially in new plants. NOX and dust have reduced
limits compared to the IED but similar to the values in WI BREF 2006.
There are two notable changes. First one is the inclusion of ammonia to the requirements.
Continuous measurement of ammonia is required when SNCR (Selective Non-Catalytic
Reduction) or SCR (Selective Catalytic Reduction) technology is used in the abatement of flue
gases to reduce NOX levels. Ammonia slip will need to be measured to show the proper
performance of the abatement.
The second one, which has the biggest impact, is the addition of mercury (Hg) to the list of
required monitored gases. The BAT-AELs set for mercury emissions for incineration and co-
incinerations of waste happens for the first time at the EU level. Continuous monitoring of
mercury is required with the exception defined in the BREF document:
“For plants incinerating wastes with a proven low and stable mercury content (e.g. mono-
streams of waste of a controlled composition), the continuous monitoring of emissions
may be replaced by long-term sampling (no EN standard is available for long-term
sampling of Hg) or periodic measurements with a minimum frequency of once every six
months. In the latter case the relevant standard is EN 13211.”
It is up to the national authorities to decide for each installation whether the conditions for the
exception apply or if continuous measurement is required.
In addition to the components that are required to be measured continuously, there are also
components that are required to be measured periodically or by long-term sampling. The
components include PCDD/F (Polychlorinated dibenzo-p-dioxins and -furans, often simply called
dioxins), dioxin-like PCBs (polychlorinated biphenyls), metals, and nitrous oxide N2O.
BAT-AEL
Parameter Unit Monitoring frequency
New plant Existing plant
<0,01-0,04 <0,01-0,06 Once every six months
PCDD/F (1) ng I-TEQ/Nm3
<0,01-0,06 <0,01-0,08 Once every month
PCDD/F+ dioxin- ng WHO- <0,01-0,06 <0,01-0,08 Once every six months
like PCBs (1) TEQ/Nm3 <0,01-0,08 <0,01-0,1 Long-term sampling period (2)
0,005–0,02 0,005–0,02
Metals and
(Cd+Tl), (Cd+Tl),
metalloids except
0,01–0,3 0,01–0,3
mercury (As, Cd, mg/Nm3 Once every six months
(Sb+As+Pb+ (Sb+As+Pb+
Co, Cr, Cu, Mn, Ni,
Cr+Co+Cu+ Cr+Co+Cu+
Pb, Sb, Tl, V)
Mn+Ni+V) Mn+Ni+V)

Once per year if using incineration

of waste in fluidized bed furnace,
N2O - - -
or incineration of waste when
SNCR is operated with urea
BAT-associated emission levels (BAT-AELs) for periodically measured or long-term sampled channeled
emissions to air
(1) Either the BAT-AEL for PCDD/F or the BAT-AEL for PCDD/F + dioxin-like PCBs applies.
(2) The BAT-AEL does not apply if the emission levels are proven to be sufficiently stable.
With PCDD/F and dioxin-like PCBs the situation is similar to mercury. Long-term sampling is
encouraged but short term sampling twice a year can be used if the emission levels are proven
sufficiently stable. It’s again up to national consideration to determine what is a sufficiently low
and stable emission level.
It should also be noted that all results must be reported in normalized values: as a dry gas, at a
temperature of 273.15 K, at a pressure of 101.3 kPa, at 11 dry vol-% of oxygen and as
concentration. This means that also the humidity level, temperature, pressure, oxygen
concentration, and gas flow need to be measured to be able to normalize the results.
To summarize, plant operators need to prepare for the following changes and actions:
1. For the first time in history, BAT-AELs for Mercury were introduced for incineration and
co-incinerations of waste. Continuous Mercury Monitoring will become obligatory,
unless it can be proven that the waste incinerated has a low and stable mercury content.
2. Ammonia becomes a new component for many measurement sites.
3. All environmental permits will be reviewed by 2023, which might cause changes to plant-
specific ELVs.
4. Long-term sampling of dioxins is preferred over short-term sampling.
Emissions monitoring in practice

Due to the large amount of different measurement components in WtE, emissions monitoring is
typically done using a multicomponent analyzer that reduces the need for different analyzers for
different components. Due to its flexibility to different components, FTIR technology is by far
the most used in WtE.
Ammonia is measured most cost-efficiently using the same analyzer as the other common
gases. Also, nitrous oxide can be measured continuously without further investments which
gives more information about the process and removes the need for annual 3rd party manual
sampling. A single FTIR system can therefore be used for measuring HF, HCl, SO2, NH3, NOX, CO,
and N2O, as well as assisting parameters H2O and CO2. FTIR systems are typically fitted with a

separate oxygen analyzer, and in countries where FID technology is required to measure TVOC,
an FID analyzer.
This leaves mainly dust, flow, and mercury to be measured continuously using separate
systems. Increasingly often also dioxins are sampled long-term with a separate device.
When choosing any analyzer, it’s important to remember that in WtE, the system needs to be
QAL1 certified to a maximum of 1.5 times the ELV set for the facility. For example, if the
environmental permit says the CO ELV is 50 mg/Nm3, the system used for measuring it needs to
have a certified range of 0…75 mg/ Nm3 or smaller for CO.
In practice in most cases, HF forms an exception to this rule. Due to the difficult nature of HF in
sampling, calibration, and field testing, an established practice has been to accept
multicomponent systems with a certified range of 3 mg/Nm3 for HF.
If none of the systems available on the market can fulfill the accuracy criteria due to low ELV
values, local authorities should give guidance on what kind of emissions monitoring set-up is
required.
The strictest requirements apply to the facilities under the WI BREF. WI BREF applies to facilities
incinerating more than 3 tons per hour of non-hazardous waste or more than 10 tons per day of
hazardous waste. Small facilities fall under national regulation and have less strict
requirements. National regulation differs substantially between different countries.
ELVs in practice
There is some variation in the ELVs set for facilities based on the national guidance and local
conditions at the plant site. However, in around 80% of cases the ELVs are set to the upper limit
of the BAT-ELVs as criticized by the new IED proposal.
The table below gives examples of typical daily ELVs in practice for existing WtE plants.
UK, WI BREF plant UK, small plant Germany, WI BREF plant Unit
Dust 5 10 5 mg/Nm3
NOX 150 200 150 mg/Nm3
SO2 40 50 40 mg/Nm3
TVOC 10 10 10 mg/Nm3
HCl 8 10 8 mg/Nm3
HF 1 1 1 mg/Nm3
CO 50 50 50 mg/Nm3

NH3 10 Not required 10 mg/Nm3

Hg 20 50 10 µg/Nm3
Mercury as a new continuous measurement
The amount of mercury and its steadiness is strongly linked to the fuel being used. While there
are waste mono-streams with well-controlled composition, most incinerated waste streams
vary in composition.
While most gas components are measured in mg/Nm3, mercury is present in µg/Nm3, that is, in
concentrations of 1/1000 compared to most other components. This means even a small
variation in the fuel composition can give raise to major changes in the mercury level in the flue
gas.
Continuous mercury monitoring data can show this variation. Below you can see real-life
mercury data from a waste incinerator. During the day, new feed is introduced approximately
every four hours, resulting in mercury peaks as the waste is incinerated.
For this reason, in most European countries, including Germany, France and Finland, continuous
mercury monitoring is required for most waste incineration starting December 2023.
The UK has taken a different approach and has established a step-by-step process on how the
operator can prove “low and stable” mercury content by making six consecutive periodic
measurements. If all the results are below half the ELV (ELV typically set to 20 µg/Nm3 for
continuous monitoring so below 10 µg/Nm3), the site is eligible for periodic measurements

twice per year. If a periodic measurement should fail later, corrective actions need to be
performed or continuous mercury monitoring installed. The benefit of periodic measurements
over continuous measurement is the lower cost.
The issue in getting steady results is apparent from the mercury concentration graph above. It
remains to be seen if the operators can prove and keep the periodic values in less than half of
the ELV. Each periodic measurement leads to substantial costs and proving the low and stable
values might become a cumbersome and expensive task.
The ELVs set to 10–20 µg/Nm3 mean the mercury CEMS needs to be certified to 15–30 µg/Nm3
maximum. It should be noted, however, that while high peaks often occur, most of the time in a
well-operating WtE facility the mercury values are in the range of 1–3 µg/Nm3. To measure
these values accurately, which is required to pass the QAL2/AST tests successfully, a much
higher accuracy is preferred.
Dioxins – short-term or long-term sampling?
As with mercury, WI BREF encourages long-term dioxin sampling but leaves the option for short-
term sampling open if the dioxin levels are proven low.
However, with dioxins unlike mercury, most plants in Europe are expected to be eligible for
periodic measurements. Dioxins don’t have a similar dependency on the fuel composition as
mercury and a well-functioning WtE plant can maintain the dioxin levels low in normal
conditions.
However, plants are not always in normal operating conditions (NOC) but sometimes in so-
called other than normal operating conditions (OTNOC). This happens, for example, during
incineration process start-up and close-down. In these conditions, the dioxin emissions can be
substantially higher which is not visible in the periodic measurements done in NOCs.
For this reason, there is a growing number of WtE sites that are either required to, or voluntarily
decide to, start long-term sampling of dioxin emissions. It’s evident how long-term sampling
(approximately 8,500 hours annually) gives a more realistic picture of the dioxin emissions than
two periodic 8 hour measurements annually. Long-term sampling also gives eligibility for lower
dioxin ELVs than periodic measurements.
The ELVs are usually set according to the higher limit of the BAT-AEL range.

Large combustion plant (LCP) emissions monitoring is

easier to control
Typical characteristics of large combustion plants (LCPs)
Compared to WtE, LCPs are characterized by their much higher level of fuel homogeneity.
Because of it, it is easier to control the incineration process and abatement. Consequently, the
requirements for emissions monitoring depend on the fuel being used, as well as the power of
the combustion plant. The emission limits can be lower than in WtE, but fewer components may
need to be measured continuously.
LCP BREF describes the best available techniques for large combustion plants
Members of the European Union accepted new air pollution limits for large combustion plants in
April 2017. The new limits required many utilities to invest in new pollution reduction
technology. This strengthens the requirements of the Industrial Emissions Directive (DIRECTIVE
2010/75/EU) for both reduction and monitoring requirements, both of which are addressed in
the “Best Available Techniques Conclusions for Large Combustion Plants” (BATC LCP).
The LCP BAT Conclusions explained new emission limit values (ELVs) for sulfur dioxide,
nitrogen oxides, mercury, and particulate matter, and required large combustion plants in
Europe to comply with those limits by 2021.
BAT-AELs are set as a range and based on evidence from plants that are in operation all over
the world. The concept of BAT covers not only the environmental performance of the technique
but also that it is currently used and economically viable. The BAT-AEL ranges shall be the
reference for setting these emission limit values, taking into account fuel type, combustion
technology and other relevant conditions.
Abbreviations:
> LCP BREF: Best Available Techniques Conclusions for Large Combustion Plants
reference document.

> LCP BATC / LCP BAT Conclusions: A document containing the parts of a BAT reference
document (LCP BREF) laying down the conclusions on best available techniques.
What is covered in the LCP BAT conclusions document?
LCP BAT conclusion concerns combustion installations with a total rated thermal input
exceeding 50 MW taking place at combustion plants. Plants with 50 MWth or under are also
discussed, where technically relevant, because smaller units can potentially be added to a plant
to build one larger installation that exceeds 50 MW. These BAT conclusions also concern the
following activities:
> Gasification of coal or other fuels in installations with a 20 MWth or more, only when this
activity is directly associated with a combustion plant.
> Disposal or recovery of waste in waste co-incineration plants for non-hazardous waste
with a capacity exceeding 3 tons per hour or for hazardous waste with a capacity
exceeding 10 tons per day, only when this activity takes place in combustion plants.
In most cases, medium sized power plants with under 50 MW power are covered in the MCP
directive (2015/2193/EU) and not in IED / LCP BREF.
Different variations of conventional power plants used for mechanical power and heat
generation are covered in the BREF. Industrial combustion installations are covered if they use
conventional fuel. The conventional fuels considered in these BAT conclusions are any solid,
liquid and/or gaseous combustible material including:
> solid fuels (for example coal, lignite, peat)

> biomass
> liquid fuels
> gaseous fuels
> industry-specific fuels (for example by-products from the chemical, iron, and steel
industries)
> waste (excluding mixed municipal waste)
New continuous measurement requirements in the LCP BREF
In cases of the following components, a continuous emissions monitoring came into effect as a
new requirement:
> Ammonia NH3, when SCR and/or SNCR is used

> Mercury Hg, when LCP is 300 MWth or more, when coal and/or lignite is used, including
waste co-incineration
> Hydrogen chloride HCl, when solid biomass and/or peat is used in LCP, or waste co-
incineration

Compound Measurement requirement

NH3 (when SCR and/or SNCR used) Continuous
Hg (LCP ≥ 300 MWth) Continuous
HCl (solid biomass and/or peat used) Continuous
HCl (waste co-incineration) Continuous
HCl (coal, lignite, process fuels from chemical industry) Once every three months
HF (waste co-incineration) Continuous
HF (coal, lignite, process fuels from chemical industry) Once every three months
TVOC (waste co-incineration with coal, lignite, solid biomass
Continuous
and/or peat)
New emission limits in the LCP BREF
LCP BREF included a substantial amount of ELV changes. The list below contains the most
relevant changes for continuous emissions monitoring, excluding dust monitoring.
In conclusion, the relevant changes to the new emission limits concern:
> mercury emissions to air*

> hydrogen chloride and hydrogen fluoride from the combustion of solid fuels in LCPs
> pollutants including sulfur dioxide (SO2) and nitrogen oxides (NOX).
*BAT-AELs for mercury emissions to air are specified for coal and lignite burning power plants.
For example, a new coal-fired power plant with 300 MWth or under has a BAT-AEL of <1–2
μg/Nm3 mercury (yearly average), and an existing lignite-fired power station with a thermal input
under 300 MW has a BAT-AEL of <1–10 μg/Nm3 mercury.
BAT-AELs (µg/Nm3)
Combustion plant total rated thermal input Yearly average or average of samples obtained
(MWth) during one year
Coal <300 <1-3 <1-9
Coal ≥300 <1-2 <1-4
Lignite <300 <1-5 <1-10
Lignite ≥300 <1-4 <1-7
BAT-associated emission levels for mercury emissions to air from the combustion of coal and lignite

BAT-AELs (mg/Nm3)
Combustion plant total rated thermal input Yearly average or average of samples obtained
(MWth) during one year
<100 <1-7 <1-15
100-300 <1-5 <1-9
≥300 <1-5 <1-5
BAT-associated emission levels for HCl emissions to air from the combustion of solid biomass and/or peat
BAT-AELs (mg/Nm3)
Combustion plant total rated thermal input (MWth) Yearly average
<100 100-150 100-270
100-300 50-100 100-180
≥300, FCB boiler combusting coal and/or
50-85 <85-150
lignite and lignite-fired PC boiler
≥300, coal-fired PC boiler 65-85 65-150
BAT-associated emission levels for NOX emissions to air from the combustion of coal and/or lignite
BAT-AELs (mg/Nm3)
Combustion plant total rated thermal input (MWth) Yearly average
<100 150-200 150-360
100-300 80-150 95-200
≥300, boiler 10-75 10-130
≥300, fluidized bed boiler 20-75 20-180
BAT-associated emission levels for SO2 emissions to air from the combustion of coal and/or lignite

BAT-AELs (mg/Nm3)
Combustion plant total rated
Yearly average NOX Yearly average SO2
thermal input (MWth)
New plant Existing plant New plant Existing plant
50-100 / <100 (SO2) 150-200 150-360 15-70 15-100
100-300 80-150 95-200 <10-50 <10-70
≥300 10-75 10-130 <10-35 <10-50
BAT-associated emission levels for NOX and SO2 emissions to air from the combustion of solid biomass
and/or peat
LCP emissions monitoring in practice

Facilities are gradually starting to meet the new LCP BREF requirements. In national
interpretations, the ELVs set out in the updated environmental permits have mostly focused on
the upper limits of the BAT-AELs.
The most notable change has been the strict mercury monitoring requirement in coal and lignite
LCPs. As a result, active facilities in countries like Poland have been fitted with continuous
mercury monitoring to comply with the increased regulation.
For many other measurement components, some measurement systems have been updated
while other sites have had future-proof systems already installed without the need for new
hardware.
In some cases, exceptions to the new limits have been made for plants facing closure in the
near future due to the efforts to reduce carbon dioxide emissions.
Large plants with more requirements are typically fitted with FTIR emissions monitoring
systems whereas smaller plants with less requirements are often fitted with NDIR system
instead.

Emissions monitoring in other facilities

Cement kilns
Cement production is an extremely energy-intensive application. Since the energy used forms a
substantial amount of the costs involved, most cement kilns are utilizing waste as a substantial
part of their energy source. This is why they are often classified as a waste co-incineration plant
(co-WI).
In co-WI plants, the waste is incinerated for the purpose of generating energy or producing
material products. Most often, these plants fall under the BREF document that regulates the
main purpose of the plant rather than WI BREF.
Cement, lime, and magnesium oxide production has its own CLM BREF established in 2013.
Generally, the emission limits are higher compared to WI BREF even though the fuel can be
similar. Typical components that need to be measured continuously include NOX, NH3, SOX, CO,
dust, HCl, HF, and TVOC. Dioxins and mercury may be eligible for periodic measurements.
Due to the requirement to measure difficult water-soluble gases ammonia, hydrochloric acid,
and hydrogen fluoride, the FTIR method is typically used. Continuous mercury monitoring may
be locally imposed depending on the circumstances, but many plants have also chosen to
voluntarily use a mercury CEMS to be able to control their process better and to be able to show
their emission levels to public more openly.
Chemical plants and related industries

A major application group requiring continuous emissions monitoring is the chemical industry.
The industry consists of a large number of installations with different requirements depending
on what is being produced, with what scale and by what kind of energy. There is a general need
to control emissions of potentially hazardous gases presented and emitted in the process.
Several BREF documents exist for chemical production. There is, for instance, SIC BREF for the
production of specialty inorganic chemicals, OFC BREF for the manufacture of organic fine

chemicals and LVIC-AAF BREF for large volume inorganic chemicals – ammonia, acids and
fertilizers. Each of these have specific requirements. In addition, local regulation may pose
additional requirements for the plants and particularly control smaller facilities. There are also
major industries utilizing chemicals in their production that need to follow and report their
emissions.
Wood-based panel production has its own WBP BREF where dust, TVOC, formaldehyde, and
NOX are relevant. Production of pulp, paper, and board (PP BREF) has relevant emission control
for example for dust, NOX, and SO2. Glass manufacturing has GLS BREF with requirements for
dust, NOX, SOX, HCl, and HF, sometimes also for formaldehyde, ammonia, and TVOC. Aluminum
production is part of NFM BREF for non-ferrous metals industries.
Petrochemical industry similarly has requirements to follow emissions in refineries and for
instance in the production of polymers. The specialties of the application are the ATEX
requirements set by ATEX directives. They describe specific requirements for systems intended
to be used in areas with potentially explosive atmospheres.
Typical emissions monitoring technologies include FTIR, NDIR, and lasers. Lasers are
particularly used when the amount of measurement components is low but the requirement for
the accuracy high. FTIR is used when the amount of measurement components is high and
includes water-soluble gases like HCl, ammonia, formaldehyde, or HF. NDIR is commonly used
when the measurement requirements consist mainly of CO, NOX, SOX, and similar components.
Smaller installations
Most small and even medium-sized plants are not governed by a joint EU-level regulation but by
national regulation in different member states. The exceptions to this rule are medium-sized
combustion plants. They are governed in the MCP directive and have considerably less strict
requirements for ELVs and emissions monitoring than LCPs.
Smaller installations that have emissions monitoring requirements include also marine
application and crematoriums.

The most commonly used emissions monitoring

technologies
While there are many technologies that can be used to monitor gas emissions, in practice the
choice is limited by the requirements of which gases need to be monitored and what are the
ELVs. This sets requirements for the certification of the CEMS that typically doesn’t leave many
technological choices.
The next chapters summarize a selection of the most typical continuous emissions monitoring
technologies used in the context of the applications presented earlier.
FTIR
FTIR (Fourier Transform Infrared spectroscopy) is one of the most commonly used
technologies for emissions monitoring. Its strength is the ability to measure simultaneously a
wide spectrum of gases including water-soluble components. This makes it the industry
standard in emissions monitoring applications where the number of measured components is
high and/or some of the more challenging gases HF, HCl, ammonia, formaldehyde, or nitrous
oxide need to be monitored.
Examples of emissions monitoring applications where FTIR is commonly used:
> Waste Incineration / Waste-to-Energy

> Large Combustion Plants
> Cement Kilns
> Aluminum Production
> Fertilizer & Nitric Acid Production
Nearly all molecules can be identified by their characteristic absorption spectrum as each
molecule absorbs infrared radiation at its characteristic frequencies. Every molecular structure
has a unique combination of atoms and bonds between them, which produces a unique
spectrum when exposed to infrared light. The only exceptions are noble gases and diatomic

elements such as O2, which do not absorb IR light. IR absorption spectrum can be thought of as
a fingerprint unique to each molecule.
FTIR spectrometer measures all the IR wavelengths simultaneously and produces a full
spectrum. All components can be analyzed from a single measurement and interferences are
resolved.
FTIR is a hot-wet extractive technology, which means the sample is extracted from the stack
and kept at a high temperature (typically 180 °C) throughout the sampling system and analyzer
to prevent any condensation. This is required to be able to also measure all water-soluble gas
components.
Main parts of the system are a heated probe, a heated sample line and a cabinet that includes
the analyzer, necessary electronics and I/Os, sampling system and other required components.
Main pros and cons of FTIR in emissions monitoring
+ Multicomponent capability
FTIR is the only technology that measures such a wide range of gases simultaneously. A
typical emissions monitoring setup can measure simultaneously H2O, CO2, CO, N2O, NO,
NO2, SO2, HCl, HF, NH3, CH4, C2H6, C3H8, C2H4, C6H14, and CH2O. In addition, FTIR CEMS
systems can be fitted with an external FID and oxygen analyzer to measure TVOC and
O2.
+ Proven accuracy
FTIR CEMS have been QAL1 certified with low ranges to match all essential applications.
+ Reliability
FTIR as a technology has been used for emissions monitoring for decades. It’s a robust
technology with low maintenance needs and a long system lifetime.
- Investment cost
Due to the more complicated structure of the analyzer and the need to keep the full
sampling system heated, the initial investment cost is higher than for NDIR.
NDIR
NDIR (Non-Dispersive Infrared spectroscopy) is a commonly used technology in emissions
monitoring particularly in simpler applications. It can measure many gases at the same time but
is lacking especially on the water-soluble gases compared to FTIR.
Examples of emissions monitoring applications where NDIR is commonly used:
> Medium-sized/Small Combustion Plants

> Marine
> Gas turbines

> Medium-sized/Small Boilers
NDIR, much like FTIR, is based on infrared absorption of gas molecules. The system is simpler
since only separate wavelength bands are measured instead of the entire spectrum as in FTIR.
NDIR is typically a cold-dry extractive method. This means the sample is extracted from the
stack, cooled, and the water is removed. This strongly limits the analysis of water-soluble
components but makes the analysis of other components easier.
Main parts of the system are a probe, a sample line, and a cabinet that includes the cooler, the
analyzer, necessary electronics and I/Os, sampling system and other required components.
Main pros and cons of NDIR in emissions monitoring
+ Cost-efficiency
NDIR systems have a lower initial investment cost than lasers or FTIR.
+ Several components can be measured
For applications requiring the monitoring of a limited amount of components, an NDIR
system can measure them all.
- Inability to measure complicated gases
NDIR has limitations in measuring water-soluble gases like ammonia, HCl and HF. This
makes it unsuitable for applications like waste incineration where these are required.
Laser
There are different laser technologies being used for emissions monitoring. They are generally
in-situ technologies where the number of measured gases per laser is low but the accuracy
high. They are best suited for applications where the main interest is towards a few gas
components and the need for precision is high.
Examples of emissions monitoring applications where lasers are commonly used:
> Ammonia slip in cement/power industry

> HF measurement in aluminum production
> Demanding HCl/HF/NH3 measurements in different industries
Laser technologies are based on the “absorption fingerprint” formed by different gas molecules
when exposed to a laser. Because of the properties of laser compared to IR, the accuracy of the
analysis can be higher while the amount of components that can be measured is low.
Laser technologies are typically in-situ, meaning that the flue gas is not being extracted from the
stack for analysis. This means no heated sample lines or similar sampling components are

needed. On the other hand, the components need to be fixed to the hard conditions of the stack
directly.
Lasers are used more commonly in process control than emissions monitoring but also have a
position in emissions monitoring in special applications.
Main pros and cons of lasers in emissions monitoring
+ Very high accuracy

The accuracy level is typically higher than in IR-based methods, enabling following very
small changes in the gas concentrations.
+ No heated lines and other sampling components needed
The risks and maintenance related to sampling in extractive technologies can be
avoided.
- Limited gas components
One laser can typically measure only a few gases, making it impractical for applications
requiring the monitoring of a wide range of gases.
- Investment costs
Laser-based systems are usually heavy on investment costs, particularly when several
lasers are needed to accommodate several gases.
Mercury monitoring technologies

There are several technologies used in continuous mercury monitoring systems. The most
common ones used in QAL1-certified systems include
> Cold Vapor Atomic Absorption spectroscopy, CVAA

> Cold Vapor Atomic Fluorescence spectroscopy, CVAF
> Differential Optical Absorption Spectrometry, DOAS
All these technologies are spectrometric. For instance, in CVAF, a UV light source is used to
emit radiation at a wavelength specific to mercury. When the UV light meets mercury atoms, the
atoms are excited and start to radiate the absorbed energy as fluorescence. A photon-counting
detector measures the amount of light emitted. The amount of light is linearly dependent on the
amount of mercury and is transferred into mercury concentration by a calibration.
Mercury can occur in various forms and can even be bound to dust particles. Flue gas includes
elemental mercury Hg0 and oxidized mercury Hg2+ in the form of HgCl2. As most measurement
methods are based on measuring elemental mercury, it means that the oxidized mercury
compounds must be converted to elemental mercury. The conversion is generally done with a
thermal or catalytic converted placed prior to the measurement cell.
Mercury monitoring technologies are predominantly a hot-wet extractive. The sample is
extracted from the stack and kept at a high temperature (typically 180 °C) throughout the

sampling system and analyzer to prevent any condensation. Main parts of the system are a
heated probe, a heated sample line and a cabinet that includes the analyzer, necessary
electronics and I/Os, sampling system and other required components.
Mercury is present in the flue gas in concentrations less than 0.1% of other typical gas
components. Therefore, the interference from other gases needs to be taken into account and
minimized. Each technology has their own way of doing this, for example diluting the flue gas
sample prior to analysis.
For all CEMS, sampling is the part of the system where most issues occur. For mercury, this is
particularly true. Especially oxidized mercury is prone to absorbing to the sampling system,
making the analysis unrepresentative and response times slow. Therefore, especially high-end
mercury CEMS include means to avoid this effect. These means could include, for example,
absorption-resistant coatings and blowback systems to get rid of the particulate matter in the
sampling system.
All in all, the differences between the analytical technologies are in practice more minor than
when comparing FTIR, NDIR, and lasers. The system design and sampling capabilities have a
greater effect on the performance. Independent of the technology, the fit for purpose of the
system for the given application should be checked by examining the accuracy and limitations
stated in the QAL1 certificate. Differences occur also in practical details on how calibrations
and QAL3 checks are being handled.
Continuous or discontinuous mercury emissions monitoring

The options for mercury monitoring include continuous measurement, long-term sampling with
the sorbent trap method, and periodic measurements. While for many facilities the continuous
sampling has been imposed, other facilities have a choice in which technology to utilize.
Each one has their pros and cons.
Continuous monitoring
+ Real-time emission data available, giving the most comprehensive view of the emissions
+ Possibility to control abatement according to the emissions.
+ Makes the facility usually eligible for higher emission limits
- Higher investment costs
- Need to consider QAL2/AST/QAL3 checks
Long-term sampling
+ Results representative of the facility operations
+ Lower costs than with continuous monitoring but higher than with periodic
measurements
- Sorbent trap method is not validated in Europe yet, which means it officially cannot
currently be used

- No possibility for process control and no visibility to mercury peaks

- Results not available real-time
Periodic measurements
+ The lowest costs associated
+ The regulatory minimum for part of facilities
- Results not necessarily representative of the facility operations
- No possibility for process control and no visibility to mercury peaks
- Results not available real-time
Dioxin sampling technologies

EN 1948 standard series describes the commercially available dioxin monitoring technologies.
The available technologies are

> Dilution method
> Cooled probe method
> Filter/Condenser method
As opposed to continuous measurement technologies like FTIR, all these methods above are
not for the measurement but for the sample collection of PCDD/PCDFs. EN 1948-1 describes
their use in short term sampling while EN/TS 1948-5 describes the process for long term
sampling.
What’s common for all the methods is that the dioxins are collected in a filter structure which is
then subsequently analyzed in an accredited test laboratory to extract the dioxin concentration
from it. In order to calculate the concentration, auxiliary information such as flue gas volume is
required. This information is typically provided by the dioxin sample collector.
Main parts of the system consist of a sampling probe, a sample line, necessary electronics and
other required components.
For example, in the dilution method, the sample is collected from the stack isokinetically. This
means the extraction flow velocity of the flue gas is made to match the flue gas flow velocity in
the stack. The extracted gas is diluted to cool it down without forming a condensate. The
diluted flue gas passes through treated filters that are placed in the probe. The flue gas then
continues to the cabinet where its volume and other auxiliary data is measured.
Short term sampling is typically done manually for 6–8 hours. Long-term sampling is typically
done for 4 weeks. As expected, the long term sampling is superior in providing a comprehensive
and a representative view of the dioxin emissions (8,500 hours of sampling vs 16 hours of
sampling annually) whereas short term sampling twice a year results in lower operational costs.

Other typical technologies

In addition to the presented technologies, there are additional measurement methods used for
complementing the emissions monitoring data.
Particulate matter (dust) content on the flue gas is measured with a separate system. Separate
systems are available for dry and wet stack conditions and the dominant technology is light
scattering. Systems meant for wet conditions are considerably more complicated. The systems
can be based on back- or forward scattering depending on the setup. Both extractive and in-situ
dust meters are available, extractive being the main technology.
FID (flame ionization detection) is a technology meant for measuring the total volatile organic
carbon (TVOC) content in flue gas. TVOC is sometimes referred to as TOC or THC. FIDs use a
fuel gas to burn the hydrocarbons present in the flue gas. TVOC value is established by
detecting the ions that form during the combustion of the hydrocarbons. TVOC can also be
measured with FTIR but in regulated applications, this is permitted only in part of the countries.
FIDs can be integrated to FTIR cabinets to complement its measurement capabilities.
Oxygen O2 is an important auxiliary parameter that needs to be measured to be able to fix the
emissions results to a constant oxygen volume, generally 11 vol-%. Main technologies used for
oxygen detection include zirconium oxide and paramagnetic technologies. Oxygen analyzers
are often integrated to other analyzers such as FTIR.
Flue gas flow is also measured continuously to be able to calculate the gas component
concentrations. Typical technologies include differential pressure principle and ultrasonic
method.
DAHS (data acquisition and handling system) is a software that finalizes the emissions
monitoring capabilities. It gathers the data from the measurement systems and normalizes it
according to the regulatory requirements to a format where it can be sent to the authorities.

The future of emissions monitoring

Emissions monitoring requirements have originally initiated from national authorities. With the
formation and expansion of the EU, the requirements for emissions monitoring and air quality
improvement have been increasingly coming from the commission and the parliament. The
direction enabled by improved technology and increased awareness to air quality has been to
gradually lower the emissions on all key industries.
The key directive, Industrial Emissions Directive IED, is under review. Taking into account the EU
policies of zero pollution and carbon net-zero, gas emission limits will keep decreasing. This
requires constant improvements both from the gas abatement technologies as well as from the
emissions monitoring technologies to be able to reduce and monitor the emissions properly.
The waste-to-energy sector is growing as there is a need to reduce landfilling and at the same
time, with the technologies maturing, the emission limits are decreasing. WI BREF that becomes
effective in December 2023 is currently being implemented to environmental permits and
results in additional needs for lower limits for example for ammonia, mercury, hydrochloric acid,
and sulfur dioxide.
The new IED proposition would cause another major decrease in the ELVs even if the BAT
document itself would not have any major changes. The default ELV value would be set from
the bottom of the BAT-AEL range instead of the top as it is today. This would result in major ELV
decreases and a need to invest more on emissions control and monitoring.
In addition to lower ELVs, it is expected that over time more parameters need to be measured or
collected continuously instead of by periodic measurements. This is already showing in
parameters like mercury and dioxins and is increasingly expected in components like
formaldehyde and nitrous oxide.
The investments made today on emissions monitoring instrumentation will face changes in the
monitoring requirements over the system lifetime. With the fast-paced changes, it has become

increasingly important to take into account how future-proof the acquired emissions monitoring
technologies and systems are.
Gasmet Technologies
Gasmet is a technology group from Finland founded in 1990. It consists of the parent company
and five subsidiaries located abroad. It has over 120 employees and has delivered over 6,000
FTIR gas analyzers worldwide. Gasmet designs and manufactures world-class gas analysis
systems and emissions monitoring solutions to measure gaseous emissions from industrial
processes, gases released from natural sources into the atmosphere, and gases present in
working environments.
Gasmet is part of the Nederman Group and stands under the Monitoring & Control Technology
division with Neo Monitors and Auburn FilterSense. Nederman is an environmental technology
company and the global leader in industrial air filtration. Nederman’s expertise and turnkey
solutions are dedicated to capturing, measuring, controlling, and cleaning air to make industrial
production more efficient, safer for people, and sustainable for the planet.
CEMS II e /ef for demanding applications

Gasmet Continuous Emissions Monitoring System CEMS II e is a solution for a broad range of
demanding emissions monitoring applications. CEMS II e has both TÜV and MCERTS QAL1
certificates. All parts of the system are heated to 180 °C and this extractive system is ideal for
measuring pollutants from hot, wet, and corrosive gas streams.
Gasmet CEMS II e is typically used to simultaneously measure the following 16 gases: H2O, CO2,
CO, N2O, NO, NO2, SO2, HCl, HF, NH3, CH4, C2H6, C3H8, C2H4, CH2O, and C6H14. Also, TVOC and
NOx are calculated. Oxygen analyzer and FID can be optionally fitted.

Key benefits of CEMS II e:
> Certified (QAL1) according to standards EN 15267-1 (2009), EN 15267-2 (2009), EN

15267-3 (2007) and EN 14181 (2004)
> 6-month maintenance interval for all certified components
> Excellent annual availability of 98.4%
> Modular design to handle lowering ELVs and for 24/7 availability
> Gasmet’s own design, manufactured with 30 years of experience
CMM AutoQAL and CMM for continuous mercury monitoring

Gasmet offers two solutions for Continuous Mercury Monitoring, the CMM and CMM AutoQAL.
Both systems provide the highest sensitivity and annual availability on the market. CMM
AutoQAL is the only TÜV and MCERTS certified solution with automatic and truly integrated
QAL3 validation tool. The systems offer certified measurement with the lowest certified range in
the world (0–5 μg/m3). The highest certified measurement range of the system is 1,000 μg/m3
and even higher concentration peaks can be measured without any hardware changes.
CMM has both TÜV and MCERTS (QAL1) certificates.
Key benefits of CMM AutoQAL and CMM:
> Certified (QAL1) according to standards EN 15267-1 (2009), EN 15267-2 (2009), EN

15267-3 (2007) and EN 14181 (2014)
> The lowest certified range (the highest accuracy) in the world
> AutoQAL module saves more than 5,000 € annually on operating costs
> Excellent annual availability of 99%
> Proven real-life performance with worldwide local technical service and support
GT90 Dioxin+ for long term dioxin sampling

The GT90 Dioxin+ is designed specifically for long-term sampling of dioxin emissions. The
automatic system represents the cutting-edge technology for dioxin sampling and fulfills all
requirements of the dioxin measurement standard. Monitoring is done in conformity to the
European standard EN 1948-1 and EN TS 1048-5.
The GT90 Dioxin+ was designed to sample even the lowest dioxin and dioxin-like compound
concentrations in harsh industrial environments. The system has been performance tested and
validated, allowing measurements down to 0.0003–0.252 ng I-TEQ /m3.
Key benefits of the GT90 Dioxin+:
> Long-term isokinetic sampling

> Conformity to EN 1948-1 / EN TS 1048-5

> Sampling of dioxins, furans, and other persistent organic pollutants (POPs)
> High sensitivity
> Availability of 100%
DX4000 for applications with multiple gas compounds

Gasmet DX4000 is a portable FTIR gas analyzer for applications where multiple gas compounds
need to be accurately monitored in hot and humid sample gas. It is the world’s smallest FTIR
emissions monitoring system. The DX4000 is typically set up to measure H2O, CO2, CO, NO, NO2,
N2O, SO2, NH3, CH4, HCl, HF, and different VOCs. It can measure up to 50 gases simultaneously.
The DX4000 is commonly used for QAL2/AST measurements of stationary CEMS systems like
CEMS II e.
Key benefits of DX4000:
> MCERTS certified

> Portable and easy set-up
> No sample pre-treatment needed
> Easily configurable for new gas components and ranges
> Simultaneous measurement of all key emissions components
> Proven to endure blaze and burning

Gasmet’s solution package for gas measurements and analysis
Buy with confidence – As your potential gas analysis partner, we offer a complete solution for
your gas measurement needs. Our very own technology ensures laboratory grade results, ease
of use and reliable, high quality products.
Mutual trust and years of expertise – We strive to provide a smooth partnership for every step.
We walk you through the whole process from consultation to first measurements, and all the
way to service and support.
Local support – Our global multi-disciplined teams and vast distributor network ensures that
professional and fast service and support are available to you locally.
For more information, please contact us at
Gasmet Technologies Oy
contact@gasmet.fi
+358 9 759 00 400
Mestarintie 6, 01730 Vantaa, Finland
www.gasmet.com

Gasmet EMISSIONS MONITORING HANDBOOK

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Emissions monitoring

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Industrial emissions monitoring regulations and practices

Emissions monitoring is challenging because of the operational environment, where regulations,

Industrial Emissions Directive (IED) sets the upper level targets

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

The IED is based on five main principles:

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Industries have their own BAT processes

As of September 2022, there are 35 BAT reference documents published in

BATC = Best Available Technique conclusion document, a conclusion or abridgment document

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Emissions monitoring standards determine the technical details

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

CEN/TS 17405 RM for carbon dioxide

Quality Assurance Levels (QALs) ensure the standards are followed

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

AST (Annual Surveillance Test)

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Roles and responsibilities in quality assurance

QAL1, QAL2, AST and QAL3 require co-operation of several parties.

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Suppliers and Manufacturers of CEMS:

Test Laboratories / “Stack testers”:

Industrial Plants / Process Operators:

Regulators / Local Emissions Authorities:

National authorities issue environmental permits

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Common practices for emissions monitoring

Typical set-up and representative measurement site

1. Measurement sections and sites

2. Measurement ports and working platforms

3. Equipment and safety conditions

Plant operators and measurers should consider the following aspects:

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

> Easy and safe access to the measurement site

Emissions monitoring for waste incineration or waste-to-

WI BREF describes the best available techniques in waste incineration

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Key findings for emissions monitoring

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Once per year if using incineration

Emissions monitoring in practice

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

NH3 10 Not required 10 mg/Nm3

Mercury as a new continuous measurement

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Dioxins – short-term or long-term sampling?

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

Large combustion plant (LCP) emissions monitoring is

Gasmet Technologies Oy / contact@gasmet.fi / +358 9 759 00 400 / www.gasmet.com

What is covered in the LCP BAT conclusions document?

> solid fuels (for example coal, lignite, peat)

New continuous measurement requirements in the LCP BREF