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EMPIR Page 1 of 30 15NRM01 Sulf-Norm Annex 1 v1.0 Annex I – JRP protocol Version Date: 31 May 2016 15NRM01 Sulf-Norm Metrology for sampling and conditioning SO 2 emissions from stacks Start date: 01 July 2016 Duration: 36 months Coordinator Marc Coleman NPL
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Page 1: Annex I – JRP protocol › smlouva › soubor › 209161 › 1... · EMPIR Page 1 of 30 15NRM01 Sulf-Norm Annex 1 v1.0 Annex I – JRP protocol Version Date: 31 May 2016 15NRM01

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Annex I – JRP protocol

Version Date: 31 May 2016

15NRM01 Sulf-Norm

Metrology for sampling and conditioning SO2 emissions from stacks

Start date: 01 July 2016

Duration: 36 months

Coordinator Marc Coleman

NPL

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Glossary CEN Comité Européen de Normalisation SRM Standard reference method SO2 Sulphur dioxide IED Industrial emissions directive CO Carbon monoxide NOx Mono-nitrogen oxides (NO and NO2) HCl Hydrogen chloride TOC Total organic compounds LNG Liquefied natural gas UNECE United Nations Economic Commission for Europe CLRTAP Convention on Long-range transboundary air pollution O2 Oxygen TS Technical Specification QA/QC Quality assurance/quality control EN European norm AM Alternative method AMS Automated measuring system ISO International Standardisation Organisation MCERTS Monitoring Certification Scheme QAL2 Quality assurance level 2

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Contents

Section A: Key data ..................................................................................................................................... 4 A1 Project data summary ........................................................................................................................... 4 A2 Financial summary ................................................................................................................................ 5 A3 Work packages summary ...................................................................................................................... 5

Section B: Overview of the research ......................................................................................................... 6 B1 Scientific and/or technical excellence ................................................................................................... 6

B1.a Summary of the project ........................................................................................................... 6 B1.b Overview of the scientific and technical objectives ................................................................. 8 B1.c List of deliverables .................................................................................................................. 8 B1.d Need for the project ................................................................................................................ 9 B1.e Progress beyond the state of the art ..................................................................................... 10

B2 Potential outputs and impact from the project results ......................................................................... 10 B2.a Projected early impact on industrial and other user communities ........................................ 10 B2.b Projected early impact on the metrological and scientific communities ............................... 11 B2.c Projected early impact on relevant standards ....................................................................... 12 B2.d Projected wider impact of the project .................................................................................... 13

B3 The quality and efficiency of the implementation ................................................................................ 13 B3.a Overview of the consortium .................................................................................................. 13

Section C: Detailed project plans by work package .............................................................................. 15 C1 WP1: Unconditioned Sampling of SO2 Standard Reference Method ................................................. 15

C1.a Task 1.1: Survey of SRM Industry Issues and Regulatory Perspective ............................... 15 C1.b Task 1.2: Testing SRM Unconditioned Sampling under Laboratory Conditions .................. 16

C2 WP2: Conditioned Sampling of SO2 P-AMS ....................................................................................... 16 C2.a Task 2.1: Comparison of SRM and P-AMS PT Data and Impact on EN 14181 QAL2 Calibration ....................................................................................................................................... 16 C2.b Task 2.2: Laboratory and Field Testing of Conditioned Sampling Systems and Modelling of SO2 Losses ..................................................................................................................................... 17

C3 WP3: Creating impact ......................................................................................................................... 19 C3.a Task 3.1 Knowledge transfer ................................................................................................ 19 C3.b Task 3.2 Training .................................................................................................................. 20 C3.c Task 3.3 Uptake and exploitation ......................................................................................... 20

C4 WP4: Management and coordination .................................................................................................. 21 C4.a Task 4.1: Project management ............................................................................................. 21 C4.b Task 4.2: Project meetings ................................................................................................... 21 C4.c Task 4.3: Project reporting .................................................................................................... 21

C5 Gantt chart ........................................................................................................................................... 23

Section D: Risk and risk mitigation ......................................................................................................... 27 D1 Scientific/technical risks ...................................................................................................................... 27 D2 Management risks ............................................................................................................................... 28 D3 Ethics ................................................................................................................................................... 29

Section E: References ............................................................................................................................... 30

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Section A: Key data

A1 Project data summary

Coordinator contact details:

Coordinator: Marc Coleman

Address: NPL, Hampton Road, Teddington, Middlesex, TW11 0LW, United Kingdom

Phone: +44 (0)208 943 6828

Email: [email protected]

Participant details:

a. Partners (participants who will accede to the Grant Agreement)

no. Participant Type Short Name Organisation legal full name Country

1 Internal Funded Partner NPL NPL Management Limited United Kingdom

2 Internal Funded Partner CMI Cesky Metrologicky Institut Czech Republic

3 Internal Funded Partner VTT Teknologian tutkimuskeskus VTT Oy Finland

4 External Funded Partner EA Environment Agency United Kingdom

5 External Funded Partner HLNUG Hessisches Landesamt für Naturshutz Umwelt und Geologie

Germany

6 External Funded Partner NAB Nab Labs Oy Finland

7 External Funded Partner Ramboll Ramboll Finland Oy Finland

8 External Funded Partner STA The Source Testing Association United Kingdom

9 External Funded Partner Uniper Uniper Technologies Ltd United Kingdom

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A2 Financial summary

Internal Funded

Partners

External Funded

Partners

Unfunded Partners

Total

Labour (€) 275 310.00 71 900.00 347 210.00

Subcontracts (€) 5 000.00 5 000.00

T&S (€) 32 295.00 14 200.00 46 495.00

Equipment (€)

Other Goods and Services (€) 37 701.00 1 000.00 38 701.00

Large Research Infrastructure (€) 22 246.00 22 246.00

Indirect (€) 18 377.60 21 775.00 40 152.60

Total eligible costs (€) 390 929.60 108 875.00 499 804.60

Total eligible costs as % of total costs 78 % 22 % 0 %

EU contribution (€) 390 929.60 108 875.00 499 804.60

EU contribution as % of total EU contribution 78 % 22 % 0 %

Months 41.2 7.9 49.1

The subcontracting described above is needed for the accredited tests for sulphate analysis in A2.3.3 carried out in Finland, these are required as VTT do not have these facilities and this is the standard process that would be carried out in usual practise.

A3 Work packages summary

WP No Work Package Title Active Partners (WP leader in bold) Months

WP1 Unconditioned Sampling of SO2 Standard Reference Method

NPL, STA, EA, HLNUG, VTT, NAB, RAM 9.6

WP2 Conditioned Sampling of SO2 P-AMS VTT, NPL, CMI, HLNUG, Uniper, Ramboll

NAB 22.7

WP3 Creating impact CMI, NPL, VTT, STA, EA, Uniper, HLNUG,

Ramboll, NAB 9.7

WP4 Management and coordination NPL, CMI, VTT, STA, EA, Uniper, HLNUG,

Ramboll, NAB 7.1

Total months 49.1

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Section B: Overview of the research

B1 Scientific and/or technical excellence

B1.a Summary of the project

This project will deliver the pre-normative work without which full implementation of the EU’s Industrial Emissions Directive will not be possible negating some of the health and the environmental benefits it is designed to deliver. Furthermore, this project will support CEN / TC 264, Air Quality, in terms of laying the platform necessary to develop a new Standard Reference Method (SRM) for regulatory monitoring of SO2 emissions from industrial processes.

With an economic cost of €102 – 169 billion due to air pollution in the EU [1] and the Aphekom project [2], establishing a linear relationship between SO2 pollution and mortality, the need for the increasingly stringent emission limits coming into force under the Industrial Emissions Directive (IED) [3] is clear. However, if the European Commissions’ projections of a reduction of 13,000 premature deaths and 125,000 years of life lost [4] as a consequent of successful implementation of the IED are to be realised, there must be put in place measurement capability to enable national regulators to administer enforcement.

CEN / TC 264, Air Quality, produces standards under mandate from the European Commission to support emissions measurements across a raft of industrial processes covered by various directives. In the early 2000s, to support the predecessor directives to the IED (waste incineration directive [5], large combustion plant directive [6], etc.), the European Commission mandated CEN / TC 264 to produce and validate a suite of Standard Reference Methods (SRMs) to cover the regulated pollutants (SO2, CO, NOx, HCl, dust and TOC). Such mandated standards produced by CEN / TC 264 being passed directly into, or referred to, in member state legislation meaning they are not voluntary and carry significant standing.

With the publication of the IED it has become clear that for SO2 (although this measurand is not alone), the existing SRM may no longer be fit for purpose for enforcing the decreased emission limits applicable to some process types. The original mandated validation of the SRM found an associated uncertainty of ±1.7 mg.m-3 (95 % confidence), whereas, for example, in LNG combustion gas processes, the IED now requires an uncertainty of ±1.0 mg.m-3 (95 % confidence). Such observations bring into question the ability to fully enforce the IED and also the future accuracy of national reporting into the European Pollutant Release and Transfer Register [7]: a key mechanism by which the EU honours it commitment to limit and reduce air pollution as a signatory to the UNECE Convention on Long-Range Transboundary Air Pollution (CLRTAP) [8].

This issue has been recognised by the standardisation community with CEN / TC 264 identifying the following future work items [9]: the new measurement requirements of the IED; the ability of the existing SRMs to meet these; and a need to develop automated methods for measuring emissions. Consistent with this, CEN / TC 264 / WG16 Reference measurement methods for NOx, SO2, O2, CO and water vapour measurements, have begun drafting a CEN SO2 Technical Specification (TS) document providing a potential Alternative Method which, if validated, could in principle form the basis of a replacement to the existing SRM, bringing the required improvement in measurement capability.

The project objectives are:

1. To determine a benchmark sampling performance for a range of industrial processes that use the existing Standard Reference Method for SO2 (EN 14791). This will include a critique of the impact of the findings on the capability for enforcing decreased emission limits under the Industrial Emissions Directive;

2. To investigate appropriate materials (e.g. stainless steel, borosilicate glass, ceramic) for conditioned sampling for use with different stack gas matrices i.e. in order to avoid sample alteration e.g. due to catalysing surface reactions. The stability of sampled gaseous components will be investigated in order to determine the consequences of short term affects;

3. To evaluate the performance of chiller versus permeation based drying technologies for conditioned sampling to determine which processes are at risk of sample bias. The mechanism of sample bias shall also be determined;

4. To contribute to a revision of EN 14791 by providing the data, methods and recommendations, which are necessary for the standardisation of SO2 sampling, to CEN / TC 264. Outputs will be communicated through a variety of media to the standards community and to end users;

5. To contribute to the production of CEN Technical Specification SO2 being drafted by CEN / TC 264 / WG16 and data to move standard closer towards EN status.

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The project will bring together a consortium of institutions and individuals representing CEN / TC 264, national regulators, plant operators, accredited stack testing organisations, emission proficiency testing providers and a trade association with a membership representing an even broader spectrum of the emissions community. Much of the work the project will deliver will be geared towards supporting the SO2 TS document being developed by WG16. This is because the scope of this standard is to provide QA/QC of portable automated measuring systems (P-AMSs), where such systems are comprised of an analytical instrument (e.g. non-dispersive infrared (NDIR) and gas filter correlation (GFC)) coupled with a conditioned sampling system. Whilst in principle techniques such as NDIR and GFC can deliver the required uncertainties, they cannot handle hot and wet gas streams (e.g. 400 °C, up to 40 % vol H2O) and hence conditioned sampling is required where the physical and chemical properties are changed without causing bias in the SO2 quantification. As the SRM is based on passing the extracted gas stream through a series of glass impingers to dissolve SO2 as sulphate, the presence of water vapour presents no issues and hence unconditioned sampling is used. As the unconditioned sampling system validated under mandate for the SRM cannot be used, alternatives are required. Proposed conditioned sampling systems are available, but there is, as yet, insufficient evidence that they can transfer the extracted gas stream without the physical and chemical changes of cooling and drying causing bias resulting in non-compliant levels of uncertainty.

The project will carry out the key tasks of establishing a stakeholder community and conducting an industry survey to ensure all issues of SO2 emissions monitoring are captured and considered. The project will also carry out laboratory and field testing of both the SRM unconditioned and proposed P-AMS conditioned sampling systems in order to determine the SRM performance at the significantly lower levels of SO2 emissions seen today; to provide the SRM unconditioned sampling as a benchmark for comparison; to compare different conditioned sampling systems for P-AMS; and to compare P-AMS against the SRM. The findings will also be considered in terms of the sampling uncertainties impact on the calibration of plant operators instrumentation installed for permanently monitoring emissions in accordance with EN 14181. A modelling tool will also be developed in order to facilitate improved manufacturer design of conditioned sampling systems in the future. All work shall be disseminated via industry and project workshops, peer review publications, uncertainty spreadsheet tools for download and importantly via close interaction with WG16 and other CEN working groups at various stages of standardising methods for measuring various regulated pollutants also reliant on conditioned sampling.

The results from this project will enable all those involved with emissions measurement from stacks to move beyond the state of the art. They will be achieved by carrying out the necessary prenormative work to characterise conditioned sampling approaches in both laboratory and field testing as well as evaluating the performance of unconditioned sampling against the low emission levels seen today. This work will facilitate CEN standardisation activities towards standardising the use of P-AMS affording the accuracy required for enforcement of increasingly stringent emission limits.

The project will lead to benefits to the following stakeholders:

Standardisation community: Work to develop and characterise conditioned sampling, allowing robust development of the SO2 Technical Specification under CEN / TC 264 / WG16, will provide a necessary step towards the elevation to an EN level standard.

Plant operators: Stack testing organisations will have improved monitoring tools allowing more accurate calibration of permanently installed emission monitoring equipment complying with directive uncertainty requirements for SO2.

National regulators: Development of measurement capability will enable enforcement of increasingly stringent emission limits under the IED and, in the future, under the proposed Medium Combustion Plant directive.

Stack testing organisations: P-AMS will provide labour savings over the application of the SRM. Also, as many plants expected to be regulated under the proposed Medium Combustion Plant directive poses sampling ports incompatible with SRM sampling systems.

Instrument manufacturers: As P-AMS cannot be used without an accepted method (e.g. the SO2 TS) for the ongoing QA/QC, publication of such a method opens up the market.

Member state governments: Developed measurement science and apparatus, coupled with method standardised at CEN, will facilitate full implementation of the IED, increasing the prospects of realisation the European Commission’s projections of a reduction of 13,000 premature deaths and 125,000 years of life lost.

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B1.b Overview of the scientific and technical objectives

The overall aim of the project is to compare conditioned sampling approaches to the unconditioned sampling approach associated with the incumbent SRM (EN 14791). There is currently insufficient evidence that proposed conditioned sampling approaches are able to transfer extracted gas streams without physical and chemical changes occurring resulting in unacceptable levels of bias. If P-AMS systems are to be used and standardised at CEN and their potential realised it, must first be demonstrated that conditioned sampling can be carried out compliant with current and future uncertainty requirements.

The specific objectives of this project are therefore:

1. To determine a benchmark sampling performance for a range of industrial processes that use the existing Standard Reference Method for SO2 (EN 14791). This will include a critique of the impact of the findings on the capability for enforcing decreased emission limits under the Industrial Emissions Directive (WP1);

2. To investigate appropriate materials (e.g. stainless steel, borosilicate glass, ceramic) for conditioned sampling for use with different stack gas matrices i.e. in order to avoid sample alteration e.g. due to catalysing surface reactions. The stability of sampled gaseous components will be investigated in order to determine the consequences of short term affects (WP2);

3. To evaluate the performance of chiller versus permeation based drying technologies for conditioned sampling to determine which processes are at risk of sample bias. The mechanism of sample bias shall also be determined (WP2);

4. To contribute to a future revision of EN 14791 by providing the data, methods and recommendations, which are necessary for the standardisation of SO2 sampling, to CEN / TC 264. Outputs will be communicated through a variety of media to the standards community and to end users (WP3);

5. To contribute to the production of CEN Technical Specification SO2 being drafted by CEN / TC 264 / WG16 and data to move standard closer towards EN status (WP3).

The two key outcomes of this project will be to determine the performance of proposed conditioned based sampling and to make a leading contribution to moving standardisation of P-AMS SO2 monitoring forward at CEN. With respect to the latter, to achieve this rather than totally re-write EN 14791 for P-AMS, the appropriate process under CEN / TC 264 is to develop an Alternative Method and publish this as a CEN Technical Specification (i.e. the AM is developed in parallel, whilst the SRM continues to be used). This has begun under CEN / TC 264 / WG16 and NPL are leading this drafting process. The following steps are then to gather validation data for the TS over time and then put the TS forward with the data and petition for elevation to an EN level document. If accepted, then the EN level document may be designated the SRM (replacing the incumbent version), the final stage being for member states to alter national regulation / legislation accordingly. All these steps are very involved and take many years to complete (representing the importance that such legislative standards hold). Hence, where this project will contribute to this process will be in terms of feeding findings and data into the drafting of the SO2 TS and towards its elevation from a TS to an EN level standard.

B1.c List of deliverables

Relevant objective

Deliverable number

Deliverable description Deliverable type Partners (Lead in bold)

Delivery date

1 D1 Summary report on an industry survey of issues in the application of the existing SO2 Standard Reference Method (SRM) (EN 14791)

Summary report STA, NPL,

CMI, VTT, EA, HNLUG, NAB, Ramboll, Uniper

May 2017

(M11)

1 D2 National regulator position paper on the current state of SO2 emissions monitoring using the SRM and P-AMS from a regulators perspective

Position paper EA July 2017

(M13)

All D3 Summary report on the capabilities of unconditioned vs conditioned sampling and the implications for the SRM and P-AMS for enforcing emission limits

Summary report NPL, VTT June 2019

(M36)

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3 D4 Summary report on the mathematical model for prediction of SO2 loses in conditioned sampling

Summary report CMI, NPL April 2019

(M34)

4,5

4

5

D5 Letter from CEN / TC 264, Air Quality, acknowledging project consortium input into standardisation activities.

This letter should acknowledge input concerning two topics:

1) Unconditioned sampling findings relevant to EN 14791.

2) Conditioned sampling findings relevant to P-AMS based measurements that can contribute to a new CEN Technical Specification.

Letter from the Technical Committee

NPL, CMI,

VTT, EA, HNLUG, NAB, Ramboll, STA, Uniper

June 2019

(M36)

n/a D6 Examples of early uptake of project outputs by end users (including via uncertainty pro-forma spreadsheet tool on STA website, submitted manuscripts, reports, conference paper slides, workshop material)

Reporting documents

CMI, NPL,

VTT, EA, HNLUG, NAB, Ramboll, STA, Uniper

June 2019

(M36)

n/a D7 Delivery of all technical and financial reporting documents as required by EURAMET

Reporting documents

NPL, CMI,

VTT, EA, HNLUG, NAB, Ramboll, STA, Uniper

June 2019

(M36

+ 60 days)

B1.d Need for the project

CEN / TC 264, Air Quality, produces standards under mandate from the European Commission for the enforcement of increasingly stringent emission limits across a raft of industrial processes. Such standards are passed into, or referred to, in member state legislation. Hence they are not voluntary and carry significant standing. In the early 2000s, CEN / TC 264, under mandate from the European Commission, developed and validated a suite of Standard Reference Methods (SRMs) to cover key pollutants (SO2, NOx, CO, HCl, TOC and dust), supporting 7 directives in force at the time designed to limit emissions from industrial process plants. The Industrial Emissions Directive has replaced these previous directives and is bringing in increasingly stringent emission limits across a range of industrial processes. It has become clear that the SRMs may no longer be fit for purpose for enforcing decreased limits across all regulated process plants. An observation recognised by the standardisation community with CEN / TC 264 highlighting in document N2204 [9] the following future work items: “identify new monitoring requirements of the IED”; “assessment of current SRM to meet stricter limit values”; and “automated methods for measuring emissions”. Also, at the 2014 Plenary meeting of CEN / TC 264, member state delegates agreed Decision 894 [10] formerly tasking CEN / TC 264 Task Force Emissions to consider the issues behind these work items. Work in this area is consistent with CEN’s commitment to support EU policies in relation to air quality and climate as described in the CEN/CENELEC Work Programme 2015 [11].

With regard to SO2, the SRM described in EN 14791[12] involves extracted stack gas being passed through a series of glass impingers filled with H2O2(aq) in which the SO2 is dissolved as sulphate. Off-line analysis of each sample run in a chemistry laboratory gives a sulphate concentration, which can be related back to the in-stack concentration. The original mandated validation work found an associated uncertainty with the SO2 SRM of ±1.7 mg.m-3 (95 % confidence), whereas, for example, for LNG combustion gas processes the IED now requires ±1.0 mg.m-3 (95 % confidence). Furthermore, at many industrial processes, the plant operator is now required to install an Automated Measuring System (AMS): a sampling system and instrumental technique (e.g. Fourier transform infrared spectroscopy) that continuously monitors the stack emissions all year round. It is a regulatory requirement that the AMS is calibrated (or calibration checked) annually via parallel measurements between the AMS and SRM in accordance with EN 14181 [13]. Hence, the role of the SRM has become increasingly two-fold providing both a one-off annual ‘snap-shot’ of emissions (commonly referred to as ‘compliance monitoring’ as it’s an accredited independent check that emissions are below levels licensed by the national regulator) and annual calibration of AMS permanent installations for continuous emissions monitoring. Also, this latter role highlights a further issue in that the AMSs must pass type approval in accordance with EN 15267-3 [14], and in order to be awarded a certificate (and therefore permitted for use) it

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must be demonstrated that the combined expanded uncertainty is 75 % of the directive requirement of the measurand. So for the example of SO2 at LNG process this would be ±0.75 mg.m-3, bringing into question the metrological validity of calibration against the SRM at some processes. Ultimately, these issues risk loss of emission limit enforcement and compromise of the accuracy of the European Pollutant Release and Transfer Register [7] and commitments under the CLRTAP [8].

In principle, there are portable automated measuring systems (P-AMSs) that could be used as an alternative to the current wet chemistry based SRM and achieve the uncertainties required (and these are discussed in greater detail in the following section). However, the barrier to widespread uptake and standardisation is that these P-AMSs are only able to measure filtered and dried (i.e. conditioned) stack gas streams. It is this sampling and conditioning of extracted gas streams that has not been sufficiently characterised and developed to allow standardisation and, therefore, where prenormative metrology is required.

B1.e Progress beyond the state of the art

As mentioned above, there are instruments that in principle are capable of measuring SO2 to a greater accuracy than a series of glass impingers filled with hydrogen peroxide solution. These instruments are based on optical techniques such as non-dispersive infrared (NDIR) or gas filter correlation (GFC). Enabling use of these instruments would allow the stack testing community to progress beyond the current state-of-the-art, however, in order to do this, there must be sampling technology and methodology that delivers a representative sample of the stack gas stream to the instrument. In terms of representative sample this means that the stack gas which is generally hot (e.g. 400 °C), wet (up to 40 % vol H2O) and contains dust of a wide variety of compositions, must be filtered, dried and cooled without effecting (or at least to a level well within uncertainty requirements) the measured result of the measurand (SO2 in this case). By definition a Portable Automated Measuring System (P-AMS) is a complete ‘measuring system’, i.e. a system that comprises of sampling apparatus coupled with an analyser. Whilst there exists proposed sampling configurations based on technologies such as condensation and permeation drying, there has, as yet, been insufficient evidence that they can reliably transfer a representative sample to the instrument. Until this can be demonstrated beyond refute (as ultimately such standards become national legislation), improvements in the accuracy of SO2 emissions measurements will be limited. This project aims to test such sampling approaches and understand biases in various configurations laying the necessary prenormative foundation for standardisation work to progress.

This project will progress beyond the state-of-the-art by carrying out the prenormative work to characterise the proposed sampling in both laboratory and field testing. These data will feed into developing and validating sampling methodology for the SO2 Technical Specification under CEN / TC 264 / WG16. This project will facilitate the development of the SO2 Technical Specification to an EN level standard under CEN mandate, positioning it to replace the incumbent SRM and be passed into member state legislation. This will progress SO2 emissions monitoring both in terms of compliance and EN 14181 calibration of AMS used for continuous monitoring to the levels of accuracy required for the enforcement of increasingly stringent emission limits.

B2 Potential outputs and impact from the project results

B2.a Projected early impact on industrial and other user communities

Plant Operators and National Regulators.

In addition to the benefits of this project enabling the enforcement of lower emission limits, there is also the advantages of P-AMS providing real-time data. When the SRM is used for carrying out an annual calibration (or calibration check) of an AMS, in accordance with EN 14181, then, after several days of sampling, the samples are despatched to a chemistry laboratory. The results are then returned, typically after a few weeks. In contrast, with a P-AMS, the data are instantly available and so if, for example, there is an issue with the AMS, meaning it will fail the calibration procedure, this can be detected in the first few hours of measurement. This allows the plant operator to take immediate corrective action with often only a 24 h delay to the calibration procedure. This reduces the amount of time that the AMS may have been reporting inaccurate data, which is important to the national regulator in terms of public perception that pollution from industry is both tightly and promptly controlled and also to the plant operator in terms of demonstrating that they take their impact on the environment seriously. Very few plant operators would underestimate the impact on their business if they gained a reputation as an unscrupulous polluter. There is also a financial benefit in that with the SRM, the EN 14181 calibration procedure is completed before it is known that there is an issue with the AMS; consequently once corrected, the stack testing company will need to be brought back in to repeat the entire

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procedure once again, i.e. the plant operator has to pay for two calibrations in this scenario rather than a 24 h delay.

Stack Testing Organisations

Stack testing organisations will benefit from the regulatory acceptance of P-AMSs due to the lower labour requirements and a higher quality of service. An EN 14181 calibration of an AMS requires a minimum of 15 parallel measurements spread across 3 days. Generally a 30 minute run is carried out every 60 minute, hence once per hour the glass impinger train is brought down from the stack, the solutions decanted into bottles ready for despatch to the chemistry laboratory, the glassware cleaned following procedures in the SRM, re-filled with new H2O2(aq) and then returned to the top of the stack. Within the time limit, this is generally not possible with one set of glassware, so most stack testing organisations would despatch two members of staff to the site and have one at the top of the stack carrying out the measurement run, while the other decants samples and prepares the next set of glassware. With a P-AMS, once set-up, the system logs data continuously and only requires one member of staff to monitor data acquisition, significantly reducing resource costs. Furthermore, as little intervention is needed with the P-AMS, the staff member has time to start processing the data, allowing early identification of issues (as described above) and reducing data processing time post the field work, bringing a further financial benefit.

Instrument Manufacturers

For a P-AMS to be used for regulatory monitoring, there must be an associated method document to QA/QC ongoing operation. Hence, while portable NDIR and GFC etc. instruments exist, the European market will not be open to manufacturers of such instruments until an applicable method is accepted. By supporting the development of the SO2 Technical Specification under WG16, this project is addressing this need. Currently the global market for AMS is estimated as being in excess of $1 billion p.a. (11th International Conference and Exhibition on Emissions Monitoring), with Europe making up a significant portion, giving an indication of the potential market size if all these AMS were calibrated by P-AMSs.

Stakeholder Engagement

The project has representation from national regulators, plant operators, stack testing organisations and many other interested parties via the STA, also the NMI partners provide strong links into CEN, all of which provides direct impact routes into the emissions community. However, in order to ensure as broad a reach of this project as possible and early uptake the STA will take the lead in putting together a stakeholder committee that will provide invaluable feedback and guidance in addition to benefiting from the project outputs. There will also be two project workshops enabling the consortium to disseminate and clearly explain project outputs and the opportunities these outputs create for all stakeholders moving forward.

B2.b Projected early impact on the metrological and scientific communities

There will be impact on the metrological community in that many NMIs and DIs provide proficiency testing schemes. Traditionally many of these use reference artefacts, i.e. certified binary gas cylinders of SO2 in N2 that participants measure to demonstrate they are proficient. The issue with such schemes is that they only test the organisation’s analytical accuracy and make no account of their sampling proficiency under real conditions. With an increasing number of stack testing facilities having been established (e.g. HLNUG and NPL), or currently being built (e.g. VSL, under EMRP JRP ENV60 IMPRESS), the community has the chance to test the entire accredited measurement that the stack testing organisation is providing (sampling and analysis). This project will provide new data on conditioned sampling, critical to understanding what level of performance should be expected by teams participating in stack simulator based proficiency testing using P-AMS. Moreover, work on the unconditioned sampling associated with the SRM may provide new data influencing the setting of performance levels for SRM too. This work will go forward into the newly created WG tasked by CEN / TC 264 to standardise proficiency testing based on stack simulator facilities.

There will also be impact on the wider scientific community in terms of addressing the relative dearth of peer review literature in the emissions area. The validation data in annexes provided in CEN standards summarises the final results from the European Commission mandated validation exercise. However, what is not provided (as this would be inappropriate for a standard) is details of all the fundamental and prenormative work that led up to that point. The CEN mandated funding rarely funds as part of the validation work, production of peer review publications, hence as there is no funding, those contracted (national laboratories, instrument manufacturers and stack testing organisations) rarely publish the work. Consequently, the work is not visible in standard electronic library searches risking unnecessary repetition and inefficient progression of scientific endeavour in the area. The consortium will play its part in addressing this by peer review publishing the prenormative work carried out under this project, which will also for perpetuity document on searchable academic databases, the history of the development of the SO2 Technical Specification under WG16.

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B2.c Projected early impact on relevant standards

CEN / TC 264 / WG16 are in the process of developing a CEN Technical Specification covering SO2 emissions monitoring from stacks and flues using P-AMS. This standard will be published in the next few years as a Technical Specification because there is currently insufficient validation data for an EN level document. The key area where validation data are lacking is in terms of sampling of the gas matrix and successful transfer of a representative sample from the stack to the analytical technique. This project is addressing this need and hence a significant portion of the activities under WP3 Impact are geared towards supporting and leading the work under this WG. The work under this project will achieve the two key aims of determining the performance of proposed conditioned based sampling systems and to make a leading contribution to moving standardisation of P-AMS SO2 monitoring forward at CEN.

However, this project will have broader impact at CEN beyond WG16, as conditioned based sampling is also relevant to the following working groups concerned with HCl (WG3, see below – mandated work) and WG36 (FTIR, see below). Furthermore, CEN / TC 264 have recently activated a new Working Group to standardise proficiency testing in the emissions area where it is based on stack simulator facilities. Such facilities, being widely regarded as the most representative way to determine emission proficiency as reference matrices, can be created at representative flow, temperature and typical water vapour concentrations. The analysis of historical proficiency testing data that will be carried out by NPL and HLNUG will feed into this WG in terms of setting realistic performance levels for accredited stack testing organisations using P-AMSs, or equally the SRM.

There may be further opportunities for the project to maximise influence and impact as there are currently New Work Item Proposals being discussed at CEN / TC 264 (at plenary meetings) concerning developing standards for NH3 and HF measurements from stacks and flues. Sampling work under this project will be relevant to the development of such standards and will be communicated to new groups as appropriate.

Standards Committee / Technical Committee / Working Group

Partners involved

Likely area of impact / activities undertaken by partners related to standard / committee

CEN / TC 264 / WG16

NPL, EA,

VTT WG16, Reference measurement methods for NOx, SO2, O2, CO and water vapour emissions.

NPL will lead, with support from the EA, the drafting of a CEN Technical Specification for SO2 monitoring by P-AMS.

VTT will provide the Finnish national expert to this working group.

NPL, EA and VTT will report to this WG the results of conditioned based sampling work under this project. These partners will also contribute to future re-drafts of the SO2 TS as it progresses from a TS to EN level document.

CEN / TC 264 / WG3

NPL, EA WG3, HCl emission – manual method

(Work mandated by the European Commission to support the Industrial Emissions Directive 2010/75/EU. Mandate M/513 – HCl in Waste Gases).

NPL and EA will provide national experts to this WG.

This working group are tasked with standardising P-AMS for HCl where data evaluating conditioned based sampling is likely to be of significant use. EA and NPL will report project findings on conditioned based sampling to this WG.

CEN / TC 264 / WG36

NPL WG36, Measurement of stack gas emissions using FTIR instruments.

NPL will chair this WG.

NPL will report to this working group findings on conditioned based sampling.

CEN / TC 264 / WGXX

NPL,

HLNUG WGXX, Air quality – Requirements on proficiency testing schemes for emission measurements

A new working group in CEN / TC 264 is to be formed, this has been discussed and agreed but is yet to be formed.

NPL and HLNUG will provide UK and German experts to this working group.

NPL and HLNUG will report the results of the analyses of historical proficiency testing data for both SRM and P-AMS from WP1 and WP2.

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CEN / TC 264 Annual Plenary

NPL NPL will provide the vice chair and / or lead the UK delegation to the annual CEN / TC 264 Plenary. VTT will lead the Finnish delegation.

NPL and VTT will report project outputs both directly and indirectly via the individual WG reports.

NPL with support from appropriate partner will table an Amendment for EN 14791 to TC 264 for any technical flaws found during this project.

B2.d Projected wider impact of the project

Societal Impact

As reported by the European Commission in Towards an Improved Policy on Industrial Emissions (COM(2007), 843 final) [4] successful implementation of the Industrial Emissions Directive will lead to a reduction in premature deaths / years of life lost in Europe of 13,000 and 125,000 respectively. A key element in achieving this significant impact is achieving the targeted lower emissions of SO2, the importance of which is further emphasised by the Aphekom project, which has established a linear relationship between SO2 air pollution and mortality [2]. In terms of the global significance, the World Health Organisation estimates that there are currently 235 million asthma sufferers [15] and furthermore, that this is now the most chronic disease amongst children.

Economic Impact

Overall the economic cost of EU air pollution is in the region of €102 – 169 billion highlighting the financial consequences associated with not taking mitigating steps [1]. Towards reducing this cost, the European Commission have estimated that successful implementation of the Industrial Emissions Directive will contribute savings of €7 – 28 billion per annum [4].

Environmental Impact

A key impact associated with SO2 is acidification of water and soil and despite marked progress since the 1990’s, significant risks still remain. This is partly because improvements in methodology to determine risk [16] have shown that previously the risk was underestimated. Consequently, work enabling further reductions in SO2 emissions is now even more important the previously thought.

Proposed EU Medium Combustion Plant Directive

In June 2015, a provisional agreement was reached between the European Parliament and Committee of Permanent Representatives of the Council for a new directive to regulate the emissions from medium combustion plants (between 1 MW and 50 MW) [17]. This is seen as a ‘closing of the gap’ given that to date, combustion plants in this capacity range have not been regulated at the European level (the IED and its predecessors regulating larger plants). Currently limits for SO2, NOx and dust are expected to come into force from 2025 for 5 MW – 50 MW plants and from 2030 for 1 MW – 5 MW plants. If by this time the existing SRM has been withdrawn in favour of P-AMS then the industry will avoid a significant cost penalty. This is due to the fact that many plants in this size range possesses sampling ports too small to be compatible with the unconditioned sampling apparatus associated with the existing SRM; consequently, the industry is currently facing the prospect of a European wide replacement programme.

B3 The quality and efficiency of the implementation

B3.a Overview of the consortium

The consortium brings together internal and external partners providing: internationally leading capabilities (e.g. stack simulators, instrument test and dynamic multi-component test gas generation); significant experience with CEN standardisation (leading roles in relevant working groups as listed in the table above); unique experience in proficiency testing; input from plant operators; input from users (accredited stack testing organisations and trade associations); and the regulatory perspective (important as ultimately the national regulator has the responsibility for ensuring that emission limits are enforced). This representation of all sides of the emissions community will ensure that all technical aspects of the project work will be thoroughly addressed and this representation will also provide conduits to all parts of the emissions community ensuring rapid communication of project outputs and maximisation of project impact.

Furthermore, NPL has worked with all the partners on previous projects and many of the partners have also worked with each other before, so strong relationships are already in place between all parties. The consortium

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is based on complimentary skills, knowledge and capabilities, which will enable all aspects of project objectives to be fully addressed and would not be possible for any single institution alone.

The consortium is comprised of the following:

NPL will coordinate the project and bring a broad experience of the practice and theory of measuring emissions from stacks and flues. NPL possesses dynamic wet reference gas generation capabilities both on a laboratory and stack simulator scale, years of experience in standard development at CEN, its own IEC / ISO 17025 accredited stack testing team with a full capability in terms of SRM measurements and sampling and analysers needed for P-AMS based monitoring of SO2. NPL also brings significant management and coordination experience having led several EMRP/EMPIR and other grant based projects. This experience of leading projects involving multiple institutions from different countries will facilitate the smooth execution of WP4, ensuring a timely delivery of all project outputs. NPL will lead WP1 and WP4 and make significant contributions to WP2 and WP3.

CMI has the capability for mathematical modelling of processes in gases inside stacks and gas conditioners with use of both analytical tools and numerical tools such as OpenFoam or MATLAB software and CMI’s supercomputing unit. CMI will bring this to the project under WP2, where losses of SO2 in gas dryers will be modelled. CMI will lead WP3 and contribute to WP2 and WP4.

VTT has field experience in designing and delivering multi-participant field trails at real stacks and will bring this to WP2. VTT has written several national guidelines in Finland related to quality assurance of emission measurement. VTT also have significant experience in standards development at CEN and will participate in many of the CEN based activities described in the project. VTT will lead WP2 and contribute to WP1, WP3 and WP4.

EA, in addition to providing a regulatory perspective, will also bring unique experiences. EA has permitted more instances of use of P-AMS for SO2 measurements (used instead of the SRM) than most other regulators across Europe. Consequently, they have built up an experience base of significant value to this project from anecdotal observations acquired from audits and interactions with plant operators. This experience will be brought to WP1 and EA will contribute to WP3 and WP4.

Uniper will bring significant experience in operating plants, carrying out in-house stack testing of plants and leading plant operator groups in drafting guidance documents to facilitate compliance with existing and future regulation. As a plant operator, Uniper has a wealth of experience in receiving SO2 emissions monitoring data from stack testing organisations (e.g. after carrying out the SO2 SRM) and then executing its responsibility in terms of applying a calibration function to the permanently installed AMS. Uniper will bring this experience to bear in activities in WP2 and will contribute to WP3 and WP4.

HLNUG is the federal state provider of proficiency testing (using a stack simulator facility) for accredited stack testing organisations across Germany. HLNUG possess the greatest dataset in Europe of stack simulator based proficiency testing of organisations accredited to carry out the SO2 SRM. This wealth of experience brings to the project a capability to measure the performance of the SRM using data acquired from real stack testing teams operating using apparatus exactly as they would in routine regulatory monitoring. These data and experience will contribute to WP1 and WP2; and HLNUG will contribute to WP3 and WP4.

NAB is an accredited stack testing organisation who has more than 20 years of experience of emission measurement campaigns, both in Finland and abroad. NAB will bring their experience in carrying out emission measurements from different types of processes, such as waste incinerators, pulp mills and power production to WP2 and will contribute to WP1, WP3 and WP4.

Ramboll is an accredited stack testing organisation that has long history in carrying out emission measurements, both in Finland and abroad. Ramboll will bring their experience in carrying out stack testing to WP2 and they will share the experiences that they have about the use of EN 14791 and its challenges in different circumstances. They will also contribute to WP1, WP3 and WP4.

STA will bring, in addition to its own expertise, the combined experience of its membership of all technical and regulatory issues in emissions monitoring. STA will provide a valuable conduit for dissemination and is ideally placed to contribute opinion across the project, but specifically to leading a survey of community issues with the regulatory monitoring of SO2. STA will contribute to WP1, WP3 and WP4.

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Section C: Detailed project plans by work package

C1 WP1: Unconditioned Sampling of SO2 Standard Reference Method

The aim of this work package is to determine a benchmark in terms of the sampling performance of the SRM (unconditioned sampling) so that its capability to enforce increasingly stringent emission limits coming into force under the Industrial Emissions Directive (IED) can be characterised; and to provide a basis for comparison of the work on P-AMS (conditioned sampling) under WP2. The SRM was developed under mandate from the European Commission around 15 years ago in order to support emissions directives that preceded the IED. The validation work carried out as part of producing the SRM determined an associated uncertainty of ±1.7 mg.m-3 in the concentration of SO2 whereas, for example, the IED on LNG combustion processes requires ±1.0 mg.m-3. Hence, for rationale such as this, the SRM may no longer be fit for purpose for all processes regulated under the IED. Recognising this, CEN / TC 264, Air Quality, have listed under their document of future work items [9] that the following should be addressed: “identify new monitoring requirements of the IED”; “assessment of current SRM to meet stricter emissions limit values”; “automated methods for measuring emissions”. This work package will support these needs by carrying out activities to determine the sampling performance at much lower levels of SO2 (in contrast to the original validation work 15 years ago) setting a benchmark of sampling performance for comparison to upcoming directive requirements and work on P-AMS under WP2.

C1.a Task 1.1: Survey of SRM Industry Issues and Regulatory Perspective

The aim of this task is to start by ensuring that the consortium is fully appraised of all issues facing stack testing organisations (who carry out the SRM) and regulators.

Activity number

Activity description Partners (Lead in bold)

A1.1.1 STA will lead, with the support of all partners, a survey of the stack testing community (a minimum of 10 participants) to assimilate real world examples of issues in the application of the existing SRM for SO2 (EN 14791). The survey will capture issues in its application across a broad range of process types to ensure a comprehensive evidence base of examples. The survey will be conducted via a combination of face to face and telephone interviews with key stakeholders in the stack testing community from the Stakeholder Committee, as well as outside the project via STA’s contacts. Additionally, EA has access to stack testing site information and data, which they will feed into this survey.

STA, NPL, CMI,

VTT, EA, HNLUG, NAB, Ramboll, Uniper

A1.1.2 STA, with support of all partners, will write a summary report on an industry survey of issues in the application of the existing SO2 Standard Reference Method (SRM) (EN 14791) using the survey findings (from A1.1.1) summarising the stack testing community opinion on the subject of SO2 emissions monitoring commenting on the regulation and available methods / techniques for enforcement.

STA, NPL, CMI,

VTT, EA, HNLUG, NAB, Ramboll, Uniper

A1.1.3 Once complete the STA, on behalf of all partners, will send the coordinator the D1 “Summary report on an industry survey of issues in the application of the existing SO2 Standard Reference Method (SRM) (EN 14791)”. The coordinator will then submit this to EURAMET as D1.

NPL, STA, CMI,

VTT, EA, HNLUG, NAB, Ramboll, Uniper

A1.1.4 EA will build an evidence base from its perspective as a national regulator, drawing on its history of SO2 regulatory experience (e.g. scheduled and un-announced audits, seminars with plant operators / stack testing organisations) containing examples of issues in the enforcement of regulation using both the SRM and proposed P-AMS.

EA

A1.1.5 Using the evidence base compiled in A1.1.4, EA will write a position paper (a non-peer-reviewed report that can be used as supporting information for the findings of Task 1.1) on the current state of SO2 emissions monitoring from stack and flues commenting as applicable on the merits of SRM and P-AMS based monitoring approaches.

EA

A1.1.6 EA will send the coordinator D2 “National regulator position paper on the current state of SO2 emissions monitoring using the SRM and P-AMS from a regulators perspective”. The coordinator will then submit this to EURAMET as D2.

EA, NPL

A1.1.7 HLNUG will extract from their proficiency testing database data of participants using the SRM when participating in SO2 proficiency testing based on the HLNUG stack simulator facility.

HLNUG

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C1.b Task 1.2: Testing SRM Unconditioned Sampling under Laboratory Conditions

The aim of this task is test the fundamental limits of the SRM under carefully controlled laboratory conditions where reference mixtures are known to a high level of accuracy.

Activity number

Activity description Partners (Lead in bold)

A1.2.1 NPL will design and construct a temporary laboratory based facility to generate well characterised reference gas matrices of SO2 including water vapour. This will be used for testing the sampling performance of the EN14791 SRM applicable to the significantly decreased levels of SO2 seen from current industrial processes.

NPL

A1.2.2 NPL will carry out a series of carefully controlled measurements (collection of samples via bubbling gas through H2O2(aq)) using the facility from A1.2.1 to test the sampling performance of the SRM. A dataset will be acquired where the SRM has been tested down to levels of SO2 representing some of the lowest emitting processes (e.g. ~6 mg m-3) and with significant amounts of water vapour (>20 % vol) causing a dilution effect making the measurement increasingly challenging. In excess of 10 independent measurements will be carried out.

NPL

A1.2.3 All samples acquired in A1.2.2 will be analysed by NPL for sulphate content by the chemistry laboratories at NPL (ISO/IEC 17025 accredited for sulphate analysis).

NPL

A1.2.4 The data from A1.2.1, A1.2.2 and A1.2.3 will be used by NPL to characterise the sampling performance of the SRM and the analysis will go forward into WP2 (A2.2.9 and A2.2.14) in order to provide a comparison for the sampling performance of the proposed P-AMS. VTT, NAB and Ramboll will review this and feedback to NPL.

NPL, VTT, NAB,

Ramboll

A1.2.5 VTT will extract data from trials carried out at their medium speed diesel engine facility in autumn 2015 as a part of a Finnish research project carried out by VTT. During these tests, EN 14791 was applied to determine the SO2 concentrations in the emissions of the engine when diesel fuels with different sulphur content (0.1 %, 0.5 % and 2.5 %) were used.

VTT

A1.2.6 VTT will analyse the data from A1.2.5, comparing the SRM (EN14791) to FTIR and this analysis will go forward and be combined with data taken on a real process plant under A2.2.2 and used as appropriate in petition to the Finnish national regulator under A2.2.4.

VTT

C2 WP2: Conditioned Sampling of SO2 P-AMS

The aim of this work package is to acquire test data for conditioned sampling for comparison to the unconditioned sampling data generated under WP1. Although more limited, participants able to operate P-AMS as well as SRM have taken part in proficiency testing and hence these data shall be extracted for comparison to analogous data provided by HLNUG from WP1. This analysis will provide understanding in terms of the capability up to this point in time that the emissions monitoring community possess for P-AMS based monitoring. This will then allow an assessment to be made in terms of the quality of a QAL2 EN 14181 calibration that would be achieved compared to unconditioned sampling, important as providing traceable calibration under EN 14181 is a key function of the SRMs.

C2.a Task 2.1: Comparison of SRM and P-AMS PT Data and Impact on EN 14181 QAL2 Calibration

The aim of this task is to make use of a large history of proficiency testing data available at NPL and HLNUG. Using these data, it will be possible to determine: how the industry’s capability for carrying out the SRM has changed with time; how the industry’s ‘typical’ uncertainties in unconditioned sampling compare to uncertainty requirements for effective enforcement of new emission limits under the IED; and how the data from conditioned sampling compare to those for unconditioned. These determinations will show clearly how the emissions monitoring community’s capability stands at this current point in time. Also, a further important element of the task will be to determine using the data the quality of a QAL2 calibration of an AMS when carried

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out with unconditioned (SRM) or conditioned (P-AMS) approaches. A key question given the importance of accurate, traceable calibration of AMSs relied upon by plant operators, and national regulators, for continuous monitoring of emissions to air.

Activity number

Activity description Partners (Lead in bold)

A2.1.1 NPL will extract from their proficiency testing database data (across more than 4 rounds of testing) of participants using P-AMS when participating in SO2 proficiency testing based on the NPL stack simulator facility. HLNUG will also supply appropriate P-AMS test data that they possess.

NPL, HLNUG

A2.1.2 NPL and HLNUG will analyse the extracted data from A2.1.1 in terms of changing performance since scheme inception and compare this to changing emission monitoring requirements as laid out in relevant European directives (i.e. the Waste Incineration and Large Combustion Plant Directives, both of which preceded the Industrial Emissions Directive). Although testing will have been carried out using matrices with differing chemical and physical properties, such as gases containing interfering components, a comparison will be made between the NPL proficiency testing data (mainly P-AMS based) and HLNUG proficiency testing data (mainly SRM based) in order to draw some conclusions regarding overall industry capability.

NPL, HLNUG

A2.1.3 Uniper and NPL will carry out statistical analyses to characterise the impact of unconditioned and conditioned sampling system on the uncertainties of EN 14181 QAL2 calibrations of permanently installed AMSs. The analyses will include considerations such as a critique on the validity of applying a calibration function when the deviation of the calibration curve is within the uncertainty associated with the SRM or P-AMS and the consequential deviation in annualised mass emissions.

Uniper, NPL

A2.1.4 NPL will write a report summarising the findings from the activities of Task 2.1 in terms of the performance of unconditioned and conditioned sampling systems derived from a history of proficiency testing data (A2.1.2) and the influence of such uncertainty sources (A2.1.3) on EN 14181 QAL2 calibrations of permanently installed AMSs. HLNUG and Uniper will assist NPL in writing the report.

NPL, HLNUG,

Uniper

C2.b Task 2.2: Laboratory and Field Testing of Conditioned Sampling Systems and Modelling of SO2 Losses

The aim of this task is, as mentioned above, to carry out a combination of laboratory and field trials comparing unconditioned and conditioned sampling and to develop a model of SO2 losses to facilitate future drying instrumentation design.

Activity number

Activity description Partners (Lead in bold)

A2.2.1 VTT will plan two field trials at two applicable plants (plants using different processes but both using a fuel that could contain sulphur) in Finland. Planning includes contacting plant operators, coordinating with Ramboll and NAB (both who will be carrying out these tests) and designing the experiments.

VTT, Ramboll,

NAB

A2.2.2 VTT, Ramboll, and NAB will carry out the first field trial in Finland. This trial will last for one week, including measurement set-up, three days measurements and dismantling of the set-up. In these tests, VTT, Ramboll and NAB will perform intra-laboratory validations according to CEN/TS14793 for alternative methods (AM) compared to SRM, wet-chemical method EN14791. It is planned that the alternative methods that are used are FTIR, UV-fluorescence and NDIR. The aim of this trial is to study if these alternative methods/instruments can give results that are equivalent to the SRM and could be used instead of EN 14791.

VTT, Ramboll,

NAB

A2.2.3 All samples from EN 14791 measurements acquired in A2.2.2 will be sent to a sub-contracted accredited laboratory in Finland for sulphate analysis. Allowing any variation in the data between the AM and sulphate analysis in the SRM to be identified.

VTT

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A2.2.4 VTT, Ramboll and NAB will analyse the data from the activity A2.2.2 to produce a data set of SO2 concentration measurements. This data set is analysed and if the results are equivalent to SRM, it is used as a validation protocol to the Finnish authorities to show that these AMs can be used in Finland instead of EN 14791. The data from A1.2.6 will also be used as appropriate.

VTT, Ramboll,

NAB

A2.2.5 VTT, Ramboll and NAB will carry out a second field trial in Finland. During this trial, also lasting one week as in A2.2.2, different conditioning units for instrumental SO2 systems will be tested. SO2 will be measured with instrumental methods, such as FTIR, NDIR and/or UV-fluorescence. It is planned that the conditioning methods that will be applied are based on permeation (with NDIR), condensation (chillers) (with NDIR) and dilution technique (with UV-fluorescence). During this trial, VTT will measure simultaneously with two FTIR analysers ten measurements in one day, using at least two different sampling probe materials, such as borosilicate glass, stainless steel to acquire field data on possible material effects.

VTT, Ramboll,

NAB

A2.2.6 VTT will write a paper on the work on sampling performance from A2.2.1 to A2.2.5. This will be submitted to an appropriate peer review journal (e.g. Accreditation and Quality Assurance) in A3.1.4.

VTT

A2.2.7 CMI will create a mathematical model of SO2 losses in dryers based on the cooling and condensation of water. Equations governing the physical processes in the dryers (water condensation and SO2 diffusion to the condensed water) will be documented and solved for simplified cases such as condensation film formation along a cooled infinite plane or spherical droplet formation inside a cooled gas.

CMI

A2.2.8 Using the facility constructed in A1.2.1, NPL will carry out a series of 10 independent measurements of chiller and permeation based sampling techniques used for leading P-AMSs.

NPL

A2.2.9 NPL will analyse the combined data sets from A2.2.8 and A1.2.4 to determine the laboratory sampling performance of conditioned (P-AMSs, A2.2.8) and unconditioned sampling (SRM, A1.2.4). This will provide empirical evidence eliminating or supporting some of the proposed loss mechanisms.

NPL

A2.2.10 NPL will write a paper on the laboratory performance of SRM and P-AMS sampling in the context of performance at decreased emission levels and capability for current and future enforcement of increasingly stringent emission levels. This will be submitted to an appropriate peer review journal (e.g. JA&WMA) in A3.1.4.

NPL

A2.2.11 CMI will use a computational fluid dynamics (CFD) software to model a flow and temperature distribution experienced inside a selected dryer (from one used in A2.2.8). The results of A2.2.8 will be combined with the results of the CFD modelling in order to obtain estimations of the SO2 losses in the selected dryer. The estimations will be compared with laboratory data supplied by NPL from A2.2.9.

CMI, NPL

A2.2.12 CMI will write a report summarising the results of A2.2.7 and A2.2.11, to be published on the project website.

CMI

A2.2.13 Once the report has completed CMI will send the coordinator D4 “Summary report on the mathematical model for prediction of SO2 loses in conditioned sampling”. The coordinator will then submit this to EURAMET as D4.

NPL, CMI

A2.2.14 VTT and NPL will carry out an analysis of all laboratory (A1.2.4 and A2.2.9) and field (A2.2.2 and A2.2.5) data in order to construct a comprehensive appraisal of SRM (unconditioned) and P-AMS (conditioned) sampling characteristics and uncertainty estimates.

VTT, NPL

A2.2.15 NPL and VTT will write a summary report based on A2.2.14 discussing the capabilities of unconditioned vs conditioned sampling and the implications for the SRM and P-AMS for enforcing emission limits.

NPL, VTT

A2.2.16 NPL and VTT will send the coordinator D3 “Summary report on the capabilities of unconditioned vs conditioned sampling and the implications for the SRM and P-AMS for enforcing emission limits”. The coordinator will then submit this report to EURAMET as D3.

NPL, VTT

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C3 WP3: Creating impact

The aim of this WP is to disseminate the results to stakeholders, end users and CEN / TC 264 / WG16, Reference measurement methods for NOx, SO2, O2, CO and water vapour measurements and to facilitate uptake of the project’s outputs.

C3.a Task 3.1 Knowledge transfer

The aim of this task is to ensure maximum exposure (and therefore impact) of the technical work by communication of outputs to stack testing organisations, plant operators, instrument manufacturers, regulators and those involved with standardisation via a broad variety of mechanisms.

With specific regard to the existing SRM for SO2 (EN 14791) as described in the introductory test to WP1 this standard is not due for review until 2020. However, there is mechanism to bring this forward in that if technical flaws are found an Amendment can be tabled to CEN/ TC 264 who will vote on whether to carry out an immediate correction. Hence, should any technical flaws be found in the course of this project such an Amendment will be submitted to CEN/ TC 264 by the consortium.

Activity number

Activity description Partners (Lead in bold)

A3.1.1 The consortium will create a Stakeholder Committee of at least 16 representatives drawn from regulators, stack testing organisations, plant operators, instrument manufacturers and experts from relevant CEN standardisation committees. As the trade association representing members from all these areas, STA will lead, with support from all partners, the creation of the Stakeholder Committee. Also, members of the Stakeholder Committee will be invited to contribute to the survey of the community being led by STA in A1.1.1.

STA, all

partners

A3.1.2 An e-mail alert mailing list will be created by NPL comprising of members of the Stakeholder Committee and also other stakeholders, registering via the project website (A3.1.3) with an interest in the work under the project. Throughout the duration of the project, e-mail alerts will be sent by NPL each time a project output is ready for public dissemination via the project website (A3.1.3) (e.g. conference presentation slides, papers, etc.). This will ensure that key stakeholders are fully aware of project outputs and will receive them as soon as they are available facilitating uptake.

NPL, all

partners

A3.1.3 A project website will be created (hosted at NPL) with both a public part and a restricted part for project partners only. The public part of the website will be regularly updated with recent project highlights, project outputs (the same outputs that will have been sent to Stakeholders by the e-mail alert in A3.1.2), conferences attended, standardisation activities and any other relevant project news. The restricted part of the website will provide an area for partners to exchange information and other relevant project files as part on ongoing technical work including meeting minutes and actions.

NPL, all

partners

A3.1.4 The partners will submit a minimum of 2 manuscripts (written in A2.2.6, A2.2.10) to peer review journals (ensuring open access) appropriate for the scientific area (e.g. Journal of the Air and Waste Management Association, Environmental Science: Process & Impacts, ACQUAL). The authors will clearly acknowledge the financial support through EMPIR as required by EURAMET.

NPL, VTT

A3.1.5 NPL will create a new uncertainty pro-forma spreadsheet for calculating sampling contributions to uncertainty budgets for P-AMS based emissions measurements of SO2

for both compliance and EN 14181 QAL2 regulatory monitoring applications. STA have agreed to provide this key tool on their website and promote it to all members of STA (the tool will also be made available via the project website).

NPL, STA, EA

A3.1.6 5 conference papers or posters will be submitted by the project partners. The partners will target conferences appropriate to the emissions monitoring community (e.g. Air Quality & Emissions (AQE), International Conference on Air Quality & Emissions (CEM), Air & Waste Management Association (A&WMA), and Finnish National Congress). The authors will clearly acknowledge the financial support through EMPIR as required by EURAMET.

CMI, all

A3.1.7 VTT will author a manuscript highlighting key project findings and submit this to the trade journal, Finnish Air Pollution Prevention Society, FAPPS

VTT

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A3.1.8 NPL will present key project findings to British Standards Institute committee EH/2-1 Air Quality - Emissions. This is the UK mirror group to CEN / TC 264.

NPL

A3.1.9 VTT will present key project findings to the Finnish Standards Association mirror group to CEN / TC 264.

VTT

A3.1.10 HLNUG will present key project findings to German Standards Institute committee 134-04-03-10 Air Quality. The German mirror group to CEN / TC 264.

HLNUG

C3.b Task 3.2 Training

Activity number

Activity description Partners (Lead in bold)

A3.2.1 NPL and all partners will organise an end of project workshop towards the end of the project where all partners will present the key outputs from the work. The target number of delegates will be from 15 to 30 and invites will be sent to a broad cross-section of the parties involved in emissions monitoring.

NPL, all

partners

A3.2.2 To compliment activity A3.1.5, NPL will author an on-line training document to provide guidance to the members of STA for the correct use of the uncertainty pro-forma spreadsheet tool described in A3.1.5. This will be available for download along with the pro-forma spreadsheet.

NPL, STA

A3.2.3 VTT will organise a one day workshop in Finland. The workshop will present the results achieved by the project but will allow time for discussion of the results with all participants. Finnish accredited stack testing organisations, accreditation body (FINAS), regulators, analyser manufacturers, plant owners will be invited to this workshop. Also, the invitation will be extended to the Baltic area and invites sent to relevant organisations in Estonia, Lithuania and Latvia. The workshop will target attracting around 50 delegates.

VTT, Ramboll,

NAB

C3.c Task 3.3 Uptake and exploitation

The aim of this task is largely two-fold; to exploit the work at CEN via TC 264 / WG16 and a newly created working group (WGXX) concerning standardisation of proficiency testing based on stack simulation facilities, and to increase regulatory acceptance in terms of petitioning the Finnish national regulator to permit the use of P-AMS based monitoring of SO2.

Activity number

Activity description Partners (Lead in bold)

A3.3.1 At the project kick-off meeting an exploitation plan will be formulated by the project partners. This will be reviewed and updated at each project meeting (Task 4.2).

NPL, all

partners

A3.3.2 Presentation (oral or written as appropriate) to CEN / TC 264 concerning unconditioned sampling project findings (i.e. findings most relevant to EN 14791). Presentation to be made to either a meeting of WG16 (Reference measurement methods for NOx, SO2, O2, CO and water vapour measurements) or at an equally applicable CEN meeting. Presentation to be led by NPL.

NPL, all

partners

A3.3.3 Presentation (oral or written as appropriate) to CEN / TC 264 concerning conditioned sampling project findings (i.e. findings most relevant to SO2 TS). Presentation to be made to either a meeting of WG16 (Reference measurement methods for NOx, SO2, O2, CO and water vapour measurements) or at an equally applicable CEN meeting. Presentation to be led by VTT.

VTT, all partners

A3.3.4 NPL on behalf of all partners to request a letter from CEN / TC 264 acknowledging contributions under A3.3.2 and A3.3.3 and submit the returned letter to EURAMET as D5.

NPL

A3.3.5 Attendance at new CEN / TC 264 Working Group tasked with standardising proficiency testing schemes based on stack simulation facilities.

Contribute project findings to meetings facilitating the drafting process.

The meetings will be attended by a combination of HLNUG, NPL and VTT who will present the findings.

HLNUG, NPL,

VTT

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A3.3.6 Petition the Finnish national regulatory authority using the field data analysed in accordance with CEN / TS 14793 for acceptance of P-AMS for monitoring applications as an Alternative Method to the SRM.

VTT, Ramboll,

NAB

All IP and potential licencing/exploitation will be handled in accordance with the Grant Agreement and the Consortium Agreement.

C4 WP4: Management and coordination

C4.a Task 4.1: Project management

Activity number

Activity description Partners (Lead in bold)

A4.1.1 The project will be managed overall by the coordinator from NPL. NPL will appoint from its Project Management Office a dedicated Project Manager (PM) to ensure the smooth running to all administrative elements of the project. Contact details of the PM will be immediately circulated to all partners.

NPL

A4.1.2 The PM appointed in A4.1.1, will put together a Project Management Board (PMB) comprising of the Coordinator, PM and WP leaders. The project management board will resolve any issues passed up to the project management board by those involved with the project.

NPL, VTT, CMI

A4.1.3 The WP leaders will report on the on-going progress to the PM by e-mail and teleconferences.

NPL, VTT, CMI

A4.1.4 The PM with support from the partners, will manage the project’s risks to ensure timely and effective delivery of the scientific and technical objectives and deliverables.

NPL, all

partners

A4.1.5 The consortium will ensure that any ethical issues identified (see Section D3) are addressed.

NPL, all

partners

C4.b Task 4.2: Project meetings

Activity number

Activity description Partners (Lead in bold)

A4.2.1 The kick-off meeting involving all partners will be held shortly after the start of the project, at NPL.

NPL, all

partners

A4.2.2 There will be two further full project meetings, one at month 18 (December 2017) and another at month 36 (June 2019) which as the final project meeting will include a session to assess the immediate impact of the project. The PMB formed in A4.1.2, will meet before each of these full project meetings. The location of the meetings will rotate among the partners. Where possible, meetings may be held as satellite meetings to important conferences or committee meetings.

NPL, all

partners

A4.2.3 In addition, WP leaders will hold telecons with their respective WP contributors at least at months 9 (March 2017) and 27 (September 2018). Individual WP leaders will be responsible for organising such telecons as part of leading their WP. The meetings will review progress and will be used to ensure partners are clear as to their role for the next period.

NPL, all project

partners

C4.c Task 4.3: Project reporting

Activity number

Activity description Partners (Lead in bold)

A4.3.1 One month after the signature of the grant agreement a publishable summary will be produced and submitted to EURAMET. This will also be published on the public area of the project website. The publishable summary will be updated to reflect project progress on a 9 monthly basis

NPL, all

partners

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A4.3.2 Following Articles 17 and 20 of the grant agreement, information will be submitted to EURAMET, in accordance with the procedures issued by them to enable EURAMET to comply with its obligations to report on the programme to the European Commission.

Progress reports will be submitted at months 9 (March 2017), 27 (September 2018 + 45 days), 18 (December 2017), 36 (June 2019 + 60 days).

Impact/Output reports will be submitted at the same times.

All WP leaders will provide input to these reports (obtaining input from WP participants as necessary) for compilation by the PM prior to approval by the coordinator and submission to EURAMET.

NPL, all

partners

A4.3.3 Periodic Reports (including financial reports and questionnaires) will be delivered at months 18 (December 2017) and 36 (June 2019 + 60 days) in accordance with Article 20 of the grant agreement.

All partners will provide input to these reports and the PM/Coordinator will provide these to EURAMET.

NPL, all

partners

A4.3.4 Final Reports will be delivered at month 36 (June 2019 + 60 days) in accordance with Article 20 of the grant agreement.

All partners will provide input to these reports and the PM/Coordinator will provide these to EURAMET.

NPL, all

partners

Formal reporting will be in line with EURAMET’s requirements and will be submitted in accordance with the Reporting Guidelines.

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C5 Gantt chart

Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun

M1 M2 M3 M4 M5 M6 M7 M8 M9 M10 M11 M12 M13 M14 M15 M16 M17 M18 M19 M20 M21 M22 M23 M24 M25 M26 M27 M28 M29 M30 M31 M32 M33 M34 M35 M36

WP1

Task 1.1

A1.1.1

A1.1.2

A1.1.3

A1.1.4

A1.1.5

A1.1.6

A1.1.7

Task 1.2

A1.2.1

A1.2.2

A1.2.3

A1.2.4

A1.2.5

A1.2.6

Month

Activity

Number

2016 2017 2018 2019

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Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun

M1 M2 M3 M4 M5 M6 M7 M8 M9 M10 M11 M12 M13 M14 M15 M16 M17 M18 M19 M20 M21 M22 M23 M24 M25 M26 M27 M28 M29 M30 M31 M32 M33 M34 M35 M36

WP2

Task 2.1

A2.1.1

A2.1.2

A2.1.3

A2.1.4

Task 2.2

A2.2.1

A2.2.2

A2.2.3

A2.2.4

A2.2.5

A2.2.6

A2.2.7

A2.2.8

A2.2.9

A2.2.10

A2.2.11

A2.2.12

A2.2.13

A2.2.14

A2.2.15

A2.2.16

2016 2017 2018 2019Activity

Number

Month

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Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun

M1 M2 M3 M4 M5 M6 M7 M8 M9 M10 M11 M12 M13 M14 M15 M16 M17 M18 M19 M20 M21 M22 M23 M24 M25 M26 M27 M28 M29 M30 M31 M32 M33 M34 M35 M36

WP3

Task 3.1

A3.1.1

A3.1.2

A3.1.3

A3.1.4

A3.1.5

A3.1.6

A3.1.7

A3.1.8

A3.1.9

A3.1.10

Task 3.2

A3.2.1

A3.2.2

A3.2.3

Task 3.3

A3.3.1

A3.3.2

A3.3.3

A3.3.4

A3.3.5

A3.3.6

2016 2017 2018 2019Activity

Number

Month

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Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun

M1 M2 M3 M4 M5 M6 M7 M8 M9 M10 M11 M12 M13 M14 M15 M16 M17 M18 M19 M20 M21 M22 M23 M24 M25 M26 M27 M28 M29 M30 M31 M32 M33 M34 M35 M36

WP4

Task 4.1

A4.1.1

A4.1.2

A4.1.3

A4.1.4

A4.1.5

Task 4.2

A4.2.1

A4.2.2

A4.2.3

Task 4.3

A4.3.1

A4.3.2

A4.3.3

A4.3.4

2019Activity

Number

2016 2017 2018

Month

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Section D: Risk and risk mitigation

D1 Scientific/technical risks

Risk (description) Likelihood and impact of occurrence

Mitigation

i.e. what the consortium will do to decrease the likelihood of the risk occurring

Contingency

i.e. what the consortium will do if despite the mitigation the risk still occurs

Task 1.1:

Lack of stakeholder engagement

Likelihood without mitigation: Low

Impact: Limited value of industry survey in A1.1.1 and attendance at WP3 workshops.

Likelihood after mitigation: very Low

Mitigation is already in place in terms of the Source Testing Association being an External Partner therefore providing an ideal conduit for engaging stakeholders and ensuring good community awareness of the project.

Partners to all play a role in targeting key stakeholders at related meetings. i.e. the partners will encounter many key stakeholders in meetings and conferences on related subjects providing venues for 1-2-1 conversations gathering industry opinion and raising the projects profile.

Task 1.1 & Task 2.1:

Incompatibility of HLNUG and NPL historical proficiency testing data (e.g. due to differing test parameters) compromising ability to make unconditioned vs conditioned sampling comparisons

Likelihood without mitigation: Low

Impact: The comparison of unconditioned to conditioned sampling will be compromised. The result will be that conclusions on the two sampling approaches from the project will rely much more on the laboratory and field testing led by NPL and VTT, respectively.

Likelihood after mitigation: very Low

Mitigation is not possible as the PT data has already been collected. However, the contingency (see right) will enable project deliverables to still be met should this risk materialise. Although, from initial NPL / HLNUG discussions it is believed this is unlikely.

NPL and HLNUG will carry out internal comparisons of SRM to P-AMS sampling. This will be possible as whilst NPL possess mainly P-AMS data they also possess some limited SRM data. Similarly, HLNUG do not possess only SRM sampling PT data.

Task 1.2 and Task 2.2:

Difficulties constructing the temporary laboratory facility for delivering reference gas mixtures for SRM and P-AMS sampling testing

Likelihood without mitigation: Medium

Impact: Lack of laboratory data to combine with field data to provide an overall picture of SRM vs P-AMS sampling. Potentially limiting results returned to CEN / TC 264 / WG16.

Likelihood after mitigation: Low

The facility will be constructed using off the shelf components already known to exist. Without the need for bespoke components the risk of not completing the facility is very much reduced.

Additional field work “spiking” SO2 from gas cylinders into sampling systems whilst sampling stack gas. Amount of spiked SO2 recovered will show sample losses and characterise performance.

Task 2.2:

Failure to organise industrial site for field trials

Likelihood without mitigation: Medium

Impact: Field trials cannot be carried out and as a consequence there is no field data available on the sampling for SRM or P-AMS.

Likelihood after mitigation: Low

VTT has organised all the intercomparison tests in Finland during 30 years and thus, VTT has close relationships with the many plant operators making failure to secure a suitable site unlikely.

Smaller scale testing at VTT´s own engine facility.

Task 2.2:

Operational malfunction of the analysers used in the field trials

Likelihood without mitigation: Medium

Impact: No data available on the sampling for P-AMS.

Likelihood after mitigation: Low

There are several analyser manufacturers involved in the project as potential collaborators. Therefore, if in the field trials some analyser’s malfunction sourcing repair / replacement will be facilitated.

Renting of the equipment from other suppliers.

Task 2.2:

Hardware capacity is too low to perform the computational modelling of flow with condensing water in a real sampling system

Likelihood without mitigation: Medium

Impact: Only a simplified case of the sampling system can be modelled.

Likelihood after mitigation: Low

Parts of the hardware can be purchased to improve its performance.

Numerical models without water condensation can be used with additional work to estimate the condensation process in the real sampling system by analytical methods.

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D2 Management risks

Risk (description) Likelihood and impact of occurrence

Mitigation

i.e. what the consortium will do to decrease the likelihood of the risk occurring

Contingency

i.e. what the consortium will do if despite the mitigation the risk still occurs

Key personnel are lost to the project

Likelihood without mitigation: Medium

Impact: Delays to specific tasks and loss of links with CEN.

Likelihood after mitigation: Low

The coordinator is not due to retire during the course of the project.

None of the WP leaders are due to retire during the course of the project.

Many of the staff employed by the partners sit as national experts on CEN / TC 264 working groups including WG16. Therefore, one member of staff leaving the project will not affect these links.

If the coordinator leaves the project there are several individuals who poses sufficient experience to assume the role of coordinator. Appointment of a new coordinator will be agreed with EURAMET.

NPL, VTT and CMI all have other staff with sufficient experience to be able to replace the respective WP leader. The individual institution will be responsible for appointing a replacement should it become necessary and will keep the coordinator fully informed.

Complexity of managing the consortium

Likelihood without mitigation: Medium

Impact: If there is confusion between partners this could compromise the quality of project delivery.

Likelihood after mitigation: Low

The partners have cooperated many times in the past so there is already in place a good working relationship and a good comprehension of the range of expertise and capabilities.

The coordinator & PM will ensure effective communication across the project communicating when partners deliverables and reports, etc., are due ensuring timely project delivery.

There is sufficient overlap of skills between partners that in the unlikely event that a partners is unable to carry out an activity this work can be reassigned to another partner or re-scoped in agreement with EURAMET.

Delays in WP delivery Likelihood without mitigation: Medium.

Impact: The project does not achieve all of its objectives.

Likelihood after mitigation: Low

All WP leaders are responsible for the timely delivery of activities within their WP. WP leaders will monitor the work within their WP identifying issues early and finding solutions where possible. Constant communication during the project will also help to avoid any delays. WP leaders will communicate all issues to the project coordinator and PM.

If there are severe risks for delays, the tasks might be transferred to other partners (after negotiation).

Activity interdependency Likelihood without mitigation: Medium.

Impact: Due to dependency more than one activity is delayed increasing adverse impact on the project.

Likelihood after mitigation: Low

WP leaders will facilitate this on a local level and will arrange telecons as necessary at the WP level to ensure timely delivery. Interdependencies will be carefully considered in the planning of work.

Contingency has been allowed in terms of overlap of linked activities. Hence, minor delays will have no impact on delivery and be absorbed into the allowed contingency.

Intellectual Property Rights ownership issues

Likelihood without mitigation: Low.

Impact: The project does not achieve all of its objectives.

Likelihood after mitigation: Low

This project is not expected to produce IP so this should not be an issue.

In the unlikely event of an issue independent arbitrators will be used to resolve any partner disagreements in ownership.

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Collaborator fails to provide access to industrial process plant for field trials (linked to 4th scientific risk in table above)

Likelihood without mitigation: Medium.

Impact: Field trials cannot be carried out and as a consequence there is no data available on the sampling for P-AMS.

Likelihood after mitigation: Low.

In addition to the mitigation already detailed in the 4th row of the scientific risks table there is further mitigation in the form of political pressure. This is that national regulators tend to look unfavourably on site operators unwilling to cooperate in projects such as this.

(Same contingency as listed in 4th row of scientific risks table).

D3 Ethics

The EMPIR Ethics Review 2015 has given JRP 15NRM01 Sulf-Norm “Ethics clearance”.

However, potential ethics issues are raised under the following 2 areas:

Third countries

Data protection

Third countries

The consortium will ensure that any partners or collaborators from Third Countries fully adhere to H2020 ethics standards, no matter where the research or activities are carried out and that research or activities performed outside the EU are compatible with European Union, national and international legislation and can be legally conducted in one of the EU Member States. The consortium will also, in the case of dual use applications, clarify whether any export licence is required for the transfer of knowledge or material.

Data protection

The consortium will ensure that all participants in training activities and meetings give a valid informed consent for the processing of personal data.

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Section E: References

[1] http://www.eea.europa.eu/media/newsreleases/industrial-air-pollution-cost-europe/

[2] http://ec.europa.eu/environment/integration/research/newsalert/pdf/375na4_en.pdf

[3] Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control). OJ EU L334: 17-119.

[4] Towards an Improved Policy on Industrial Emissions. Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the Regions. Commission of the European Communities, COM (2007), 843 final.

[5] Directive 2000/76/EC of the European Parliament and of the Council of 4 December 2000 on the Incineration of Waste. OJ C L332: 91-111.

[6] Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the Limitation of Emissions of Certain Pollutants into the air from Large Combustion Plants. OJ C L309: 1-21.

[7] Regulation (EC) No 166/2006 of the European Parliament and of the Council of 18th January 2006 Concerning the Establishment of a European Pollutant Release and Transfer Register and Amending Council Directives 91/689/EEC and 96/61/EC. O.J.E.U., 2006, L33:1-17.

[8] Convention on Long-range Transboundary Air Pollution. United Nations Economic Commission for Europe, Geneva, 1979.

[9] Future Work Items / Activities of CEN/TC 264. CEN/TC 264 N2204, 30th March 2014.

[10] Decisions 24th Meeting of CEN/TC 264, Verneuil-en-Halatte, France. CEN/TC 264 N2213, 22nd May 2014.

[11] Work Programme 2015: European Standardisation and Related Activities. CEN and CENELEC, July, 2014.

[12] Stationary Source Emissions – Determination of Mass Concentration of Sulphur Dioxide – Reference Method. Comité Européen de Normalisation, EN 14791: 2005.

[13] Stationary Source Emissions - Quality Assurance of Automated Measuring Systems. Comité Européen de Normalisation, EN 14181: 2014.

[14] Air Quality – Certification of Automated Measuring Systems. Comité Européen de Normalisation, EN 15267-3: 2007.

[15] http://www.who.int/features/factfiles/asthma/en/

[16] http://www.eea.europa.eu/highlights/europe-still-playing-catch-up

[17] http://www.consilium.europa.eu/en/press/press-releases/2015/06/30-medium-combustion-plants/


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