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Technical Guidance Note

(Monitoring) M1
Sampling requirements for stack-emission monitoring

Environment Agency
Version 4
July 2006
Record of amendments

Version Date Amendment


number
2 July 2002 Added details on the use of temporary platforms to section 4.1.1.
3 Oct 2005 Added details on conducting a swirl test (Section 2.1.3).
3 Oct 2005 Added details on criteria for selection of gas sampling location (Section
2.2.3).
3 Oct 2005 All references to BS 3405:1983 and BS 6069:Section 4.3:1992 deleted.
3 Oct 2005 Amendments to positional requirements for CEMs (Section 3.2).
3 Oct 2005 Section 4.1.1 amended to reflect requirements of HSE Work at Height
Regulations 2005.
3 Oct 2005 Revised access port requirements (Figure 4.5).
4 July 2006 Added definition of a sampling section and amended other definitions in
Box 1.2.
4 July 2006 Amended section 2.1 to include the measurement of velocity.
4 July 2006 Amended guidance on selection of a suitable sampling location for
sampling gas concentrations (section 2.2.2).
4 July 2006 Amended guidance on determining if stack gases are homogenous
(section 2.2.3).
4 July 2006 Explained principle for sampling inhomogeneous gases and added
reference to prEN15259.
4 July 2006 Amended guidance on locating CEMs (section 3.1).
July 2006 Restructured section 4.1 on sampling facilities.
4 July 2006 Amended statement referring to weather protection on platforms (section
4.1.1).
4 July 2006 Added clarification on probe length (Figures 4.1, 4.2, 4.3 and 4.4)
4 July 2006 Added guidance on assessing the affect of platforms on the structural
integrity of stacks (section 4.1.7).
4 July 2006 Restructured Section 4.2 on risk management
4 July 2006 Added details of standards and guidance documents related to the
inspection of the structural integrity of stacks (Annex 2).

Status of this document

This TGN may be subject to review and amendment following publication. The most
recent version of this note is available on our website at:

www.mcerts.net

Feedback
If you have any comments on this document please contact Rupert Standring at
Rupert.Standring@environment-agency.gov.uk
Foreword

Purpose
This Technical Guidance Note (TGN) on sampling requirements for monitoring stack-
emissions to air is one of a series providing guidance to our staff, monitoring
contractors, industry and other parties interested in stack-emission monitoring. It is
also a key reference document in support of our Monitoring Certification Scheme
(MCERTS) and Operator Monitoring Assessment (OMA).

It provides guidance on:

the selection of the sampling position, sampling plane and sampling points;
access, facilities and services required;
safety considerations.

Throughout the document, references to sampling from stacks should be interpreted as


also meaning sampling from vents, ducts and flues, unless otherwise stated.

The section on safety draws attention to the importance of health and safety in stack-
emission monitoring, provides guidance on the hazards and risks associated with
stack-emission monitoring and highlights the relevant health and safety legislation.

How to use M1
The TGN is divided into four chapters. Chapter 1 describes the main monitoring
approaches, the fundamental principles of sampling and the importance of a
monitoring strategy. Chapters 2 and 3 give guidance on the sampling requirements
for periodic stack-emissions measurements and continuous emissions monitoring
systems, respectively. Chapter 4 provides guidance on sampling facilities and safety
requirements for stack-emission monitoring.
Contents

1. Monitoring approaches
1.1 Monitoring strategy 1
1.2 The different approaches to monitoring stack-emissions 2
1.3 The importance of representative sampling 2
1.3.1 Fundamental principle 2
1.3.2 Representative sampling of particulates and gases 2
1.4 Choice of sampling method, sampling technique and equipment 4

2. Sampling requirements: periodic measurements


2.1 Periodic sampling of particulates 4
2.1.1 Special characteristics 4
2.1.2 Positional requirements for sampling particulates 5
2.1.3 Criteria for locating the sampling plane 6
2.1.4 Surveying the proposed sampling plane 8
2.1.5 Preliminary velocity survey 8
2.1.6 Unacceptable characteristics 8
2.1.7 Number of sampling points 9
2.1.8 Position of sampling points along the sample lines 9
2.1.8.1 Position of sampling points for circular stacks 10
2.1.8.2 Position of sampling points for rectangular and square stacks 11
2.2 Periodic sampling of gases 13
2.2.1 Special characteristics of sampling gases 13
2.2.2 Location requirements for monitoring gases 14
2.2.3 Criteria for locating a sampling plane for gas concentrations 15

3. Sampling requirements: Continuous emissions monitoring systems


3.1 CEMs measuring concentrations 16
3.2 CEMs measuring gas volumetric flow rates 16

4. Sampling facilities and safety requirements for stack-emission monitoring


4.1 Sampling facilities 17
4.1.1 Safe working platform and means of access to the sampling position 17
4.1.2 Space for the equipment and personnel 18
4.1.3 Means of entry into the stack (sampling access ports) 19
4.1.4 Sampling facilities for periodic monitoring of gases 25
4.1.5 Sampling facilities for CEMs 25
4.1.6 Essential services 25
4.1.7 Installing and upgrading sampling platforms at existing stacks 25

4.2 The risk-management approach to site work 26


4.2.1 Safety has the highest priority 26
4.2.2 Prominent hazards encountered when stack-emission monitoring 27
4.2.3 The risk assessment process 27
4.2.4 Responsibilities 28
4.2.5 When to carry out a risk assessment 29
4.2.6 Getting the operator involved 29
4.2.7 Reporting of accidents and near misses 30
4.2.8 Further guidance 30

Annex 1 Sample point requirements as specified in ISO 9096:2003 31


Annex 2 Health and safety legislation, guidance and standards 32

References 33
Sampling requirements for stack-emission monitoring

1. Monitoring guidance
We publish Technical Guidance Notes (TGNs) to provide advice and support in
relevant subject areas. This TGN covers sampling and safety requirements for stack-
emission monitoring. It is one of a series of TGNs in the M series providing
guidance on regulatory monitoring.

Our MCERTS scheme (see Box 1.1) includes both continuous emission monitoring
systems (CEMs) and manual stack-emission monitoring. MCERTS for manual stack-
emission monitoring provides for the assessment of the management, quality and
reliability of organisations, and the competence of individuals carrying out stack-
emission monitoring against published performance standards for organisations1 and
personnel2. This TGN is a key reference document that underpins MCERTS for
manual stack-emission monitoring and provides guidance on suitable sampling
locations for CEMs.

Box 1.1 MCERTS


MCERTS is our Monitoring Certification Scheme for instruments, monitoring and
analytical services. The scheme is built on proven international standards and provides
industry with a framework for choosing monitoring systems and services that meet our
performance specifications. MCERTS reflects the growing requirements for regulatory
monitoring to meet European and international standards. It brings together relevant
standards into a scheme that can be easily accessed by manufacturers, operators, regulators
and laboratories. Further information on MCERTS is available at www.mcerts.net

1.1 Monitoring strategy

Emission monitoring carried out at a stack must be fit-for-purpose. To meet this


criterion, considerable thought must go into developing an appropriate monitoring
strategy for the particular application.

This monitoring strategy should be documented in a site-specific protocol (SSP),


which is generated by the monitoring organisation before monitoring work begins.
The SSP describes how the method will be employed in a given, specific situation and
should be undertaken for each site where monitoring is to take place. The MCERTS
performance standard for organisations sets out the requirements for the SSP.

TGN M1, Version 4, July 2006 Page 1 of 33


1.2 The different approaches to monitoring stack-emissions

Stack-emissions monitoring can be classified into two types:


a) Periodic measurements a measurement campaign is carried out at
periodic intervals, for example, once every three months. The sample
is usually, but not always, withdrawn from the stack (extractive
sampling). An instrumental or automated technique may be used,
where the sampling and analysis of the substance is fed to an on-line
analyser. Alternatively, a technique may be used where a sample is
extracted on site and analysed later in a laboratory. Samples may be
obtained over several hours, or may be so-called spot or grab
samples collected over a period of seconds to several minutes.
b) Continuous emissions monitoring systems (CEMs) automated
measurements carried out continuously, with few if any gaps in the
data produced. Measurement may be carried out in situ in the stack (for
example, cross-duct monitoring), or extractive sampling may be used
with an instrument permanently located at or near the stack. CEMs are
also referred to as Automated Monitoring Systems (AMS), particularly
in a European context.

1.3 The importance of representative sampling

1.3.1 Fundamental principle

The fundamental principle behind any sampling activity is that a small amount of
collected material should be representative of all the material being monitored. The
number and location of samples that are needed to make up a representative sample
depends on how homogeneous the material is. If it is very homogeneous, only a few
samples may be required. If the material is heterogeneous, many more samples will
be required.

1.3.2 Representative sampling of particulates and gases

This fundamental principle applies as much to sampling stack gases as it does to any
other type of sampling. Although the gas in a stack might be thought of as being
more uniform than, for example, a stockpile of coal, gases in stacks can become non-
homogeneous. This may be due to differences in chemical composition, or differences
in temperature and velocity, which may lead to stratification and swirling. Where the
gas is also carrying particulates along the duct, there is likely to be even less
homogeneity. Here, special measures must be taken to ensure samples are
representative.

For gases carrying particulates, the sampling approach has to address two effects.
Firstly, inertial effects introduced by gravity and the duct geometry lead to the
particles being unevenly distributed in the duct. Samples must be obtained from
multiple sample points (see to Box 1.2 for definitions of terms) across the sampling
plane to give an overall average of the particulate emission. Rules have been
developed specifying where these sampling points should be located (these are

TGN M1, Version 4, July 2006 Page 2 of 33


described in Section 2.1.8). In the case of a cross-duct CEM monitoring particulates,
the average particulate concentration is obtained as an integrated measurement across
the duct. Secondly, for extractive methods, the sample must be collected isokinetically
(see Box 1.3).

Box 1.2 Definitions of important terms in stack emission monitoring

Stack, duct or flue a structure through which gases pass. Typically stacks are intended to
be of sufficient height to adequately disperse emissions in the atmosphere. The terms duct
and flue are synonymous.

Sampling section - region of the stack or duct that includes the sampling plane and the inlet
and outlet sections.

Sampling plane the plane normal to the centreline of the stack or duct at the sampling
location.

Sampling location or site the working area around the sampling plane on a stack or duct.

Sampling lines imaginary lines in the sampling plane along which sampling points are
located, bounded by the inner wall of the stack or duct.

Sampling ports or access ports points in the wall of the stack or duct through which
access to the emission gas can be gained.

Sampling point the specific position on the sample plane from where the sample is
extracted.

Isokinetic sampling is achieved when the gas enters the sampling nozzle at the same
velocity and direction as the gas travelling in the stack or duct.

Box 1.3 The importance of isokinetic sampling for particulates

Due to the wide range of particle sizes normally present in process emission streams, it is
necessary to sample isokinetically to ensure that a representative sample of the particulate
emission is obtained.

If the sampling velocity is less than the isokinetic rate, at first sight it would appear, that
the emission will be underestimated. However, because the sampling rate is too low,
there is a divergence in flow around the sampling inlet. Small particles are able to follow
the flow and a percentage of them will not be sampled. Larger particles, on the other
hand, are not able to follow the flow because of their greater inertia and more of these
particles will enter the sampler. Thus a sub-isokinetic sampling rate will lead to a bias in
the sampled particle size distribution towards the larger particles. This could lead to an
overestimate of the particulate concentration depending on the original size distribution.

Sampling at a rate in excess of the isokinetic rate will lead to a bias in the sampled
particle size distribution towards the smaller particles. This could lead to an
underestimate of the emission concentration depending on the original size distribution.

TGN M1, Version 4, July 2006 Page 3 of 33


Where the measurement is of concentrations of gaseous species alone, a sampling
location where the gases are well mixed should be chosen. If gases are well mixed it
is possible to demonstrate that sampling can be carried out from a single sampling
point in the sampling plane. However, if the mass emission rate is to be calculated, the
gas volumetric flowrate will need to be measured; this will require velocity
measurements to be made at several points across the sampling plane.

Some pollutants; for example, metals and dioxins, are present in both particulate and
vapour phases. Other pollutants for example, hydrogen chloride, may be present in an
aerosol phase and vapour phase. Aerosols are normally treated as particulates. In all
such cases isokinetic multi-point sampling is required, as described in Section 2.1.

1.4 Choice of sampling method, sampling technique and equipment

There is a wide choice of monitoring approaches, analytical techniques, published


methods and equipment that can be used to carry out stack-emissions measurements.
It is important that each of these is chosen to be suitable for the application in
question. TGN M2 Monitoring of stack emissions to air3 gives detailed guidance on
deciding which approach, technique and method should be chosen.

The sampling approach, technique, method and equipment that are chosen can have
different effects on the requirements for access, facilities and services. Though the
precise requirements can vary, the following will always be required:

a safe means of access to the sampling position;


a means of entry for sampling equipment into the stack;
adequate space for the equipment and personnel;
provision of essential services, such as electricity.

Further details on such requirements are given in Chapter 4.

2. Sampling requirements: periodic measurements

2.1 Periodic sampling of particulates

2.1.1 Special characteristics

Periodic sampling of particulates requires extractive isokinetic sampling methods.


The principle of isokinetic sampling is that a sharp-edged nozzle is positioned in the
stack facing into the moving gas stream and a sample of the gas is extracted through
it, at the same velocity as the gas in the stack, for a measured period of time (see Box
1.3). To allow for non-uniformity of particulate distribution, samples are taken at a
pre-selected number of points across the sample plane. The particulates collected in
the sampler are later weighed, and the concentration of particulate matter in the stack
is calculated using the volume of gas sampled. The mass flow rate of particulate
matter in the stack can be calculated from the concentration and the velocity of gas in
the stack.

TGN M1, Version 4, July 2006 Page 4 of 33


Some of the older measurement standards are prescriptive (either explicitly or
implicitly) about the equipment that can be used for sampling particulates. The trend
now, however, is towards standards that lay down minimum performance and design
criteria for the equipment. Any piece of sampling equipment can be used if it meets
these criteria and is fit for purpose. This last caveat is important as each system may
have particular advantages and drawbacks. These need to be considered when
choosing the most suitable sampling equipment for the measurement in question.

The main differences between particulate sampling equipment, in so far as they affect
the access, facilities and services required, is the configuration of the sample probe
and particle-separator device. Sampled particulate is collected on a filter held in a
filter holder; the latter may be arranged on the probe so that it is in the stack (in-stack
filtration) or out of the stack (out-of-stack filtration).

2.1.2 Positional requirements for sampling particulates

There are a number of standard methods for monitoring particulates. The Comit
Europen de Normalisation (CEN) standard BS EN 13284-1:20024 details the
positional requirements for particulates and is referred to on positional requirements
by a number of other CEN standards. It should be noted that BS EN 13284-1:2002
along with another particulate standard BS ISO 9096:20035 covers the measurement
of particulates in the range from 0 to 1000 mg m-3.

This chapter provides a single set of requirements for sampling positions for
isokinetic sampling of particulates and multi-phase pollutants. This chapter also
provides the single set of requirements for sampling positions for measuring stack gas
velocity. These requirements are taken from BS EN 13284-1:2002.

TGN M1, Version 4, July 2006 Page 5 of 33


2.1.3 Criteria for locating the sampling plane

The general approach for periodic sampling of particulates and aerosols can be
summarised as:

Identify a potentially suitable sampling


location (covered in this section)

Access the stack and check that the gas-flow


criteria are met by carrying out an exploratory
survey (see Sections 2.1.4 and 2.1.5)

Decide the number and position of the


sampling points (see Sections 2.1.7 and 2.1.8),
and install ports and access to the sampling
location (see Section 4.1).

Carry out preliminary velocity traverse


(Section 2.1.5) to confirm satisfactory and
proceed with sampling.

Sampling must be carried out at a suitable location on the stack. Bends, branches,
obstructions, fans and leaks can all cause undesirable variations in the velocity
profiles, which may make the location unsuitable for sampling.

For new installations, the sampling plane should be located according to the
requirements contained in Table 2.1. By adhering to these requirements, there is a
very good chance that the flow-stability criteria defined in Table 2.2 will be met. The
flow-stability criteria of a gas encompass velocity and direction. Flow criteria is used
in this TGN as a term to cover all these parameters. It should be emphasised that it is
the flow criteria that are important, not the adherence to the positional requirements
per se. Therefore on plants where the sampling plane location does not meet the
recommendations in Table 2.1, it is possible to locate the sampling plane at another
location as long as the flow criteria are met.

TGN M1, Version 4, July 2006 Page 6 of 33


Table 2.1 Recommended location for meeting sample location requirements for
periodic sampling of particulates

General location of The sampling plane should be situated in a length of straight duct (preferably
sampling plane vertical) with constant shape and constant cross-sectional area. Where possible,
the sampling plane should be as far downstream and upstream from any
disturbance, which could produce a change in direction of flow (e.g. bend, fan or
a partially closed damper).
Location of sampling The sample plane criteria are usually met in sections of duct with five hydraulic
plane in straight diameters (see Box 2.1 for definition) of straight duct upstream of the sampling
section plane and two hydraulic diameters downstream. If the sampling plane is to be
located near the top of the stack outlet then the distance from the top should be
five hydraulic diameters (making a straight length of 10 hydraulic diameters).

Box 2.1 Definition of hydraulic diameter


It is not possible simply to use the term diameter in positional criteria, because not all stacks are of
circular cross-section. To allow all shape ducts to be included, the term hydraulic diameter is used,
defined as:
(4 x area of sampling plane) / length of sample plane perimeter

Table 2.2 Flow-stability criteria for periodic sampling of particulates

*
Angle of gas flow 15 from stack longitudinal axis

Flow direction No local negative flow

Minimum velocity Dependant on the method used (for Pitot tubes a differential
pressure larger than 5 Pa)
Gas velocities variations Ratio of highest to lowest local gas velocities less than 3:1

Compliance with the flow criteria should be checked by a preliminary velocity survey
(Section 2.1.5). If the flow criteria in Table 2.2 are not met, the sampling location is
not in compliance and a more suitable sampling location should be selected.
However, problems with meeting the criteria sometimes occur with older installations
where it is not always practicable to move the sampling plane to a better location
because of safety considerations, cost, or the design of the stack. When this occurs it
may be possible to improve representative sampling by increasing the number of
sampling points above those specified in Tables 2.3 and 2.4.

*
The angle of gas flow is determined by carrying out a swirl test. Guidance on carrying out a swirl test
is contained in Annex B of BS EN 13284-1: 2002.

TGN M1, Version 4, July 2006 Page 7 of 33


2.1.4 Surveying the proposed sampling plane

An exploratory survey of the proposed sample plane should be undertaken. This


should include a stack-gas velocity survey, as described in Section 2.1.5. For metal or
other thin-walled ducts or chimneys, 13mm diameter pilot holes, drilled through the
flue wall on the centres of the proposed sample access holes, may enable a small bore
Pitot-static tube and thermocouple probe of suitable length to be used for this purpose.
The use of such temporary access holes distinguishes the exploratory velocity traverse
from the preliminary velocity survey. The latter must be performed through
permanent access ports meeting the requirements in Section 2.1.5.

It is important that this approach is followed, so that the sample plane location is
shown to be suitable before installing comprehensive and expensive sampling access
and facilities on a stack.

2.1.5 Preliminary velocity survey

A preliminary velocity traverse should be carried out before sampling is carried out at
a location for the first time. To establish that a sampling location is suitable,
measurements of gas velocity should be carried out at equally spaced points along
each proposed sampling line (often referred to as a grid measurement). Sampling
points should be located either more than 3% of the sampling line length or more than
5cm whichever is the greater value from the duct wall. Measurements at these
sampling points must demonstrate that the gas stream at the sampling plane meets the
requirements contained in Table 2.2. If the results do not conform to the flow-stability
criteria, another sample location should be found.

2.1.6 Unacceptable characteristics

Some older installations may not meet the flow-stability criteria, but sampling may
nevertheless still be required. Deviations from the standard can have significant
effects on measurement uncertainty.

Information on assessing the effects of deviations on accuracy is given in the Source


Testing Association (STA) Quality Guidance Note QGN001 r16.

TGN M1, Version 4, July 2006 Page 8 of 33


2.1.7 Number of sampling points

The number of sampling points required is determined by the size of the stack. The
minimum number of sampling points and sample lines are shown in Tables 2.3 and
2.4, for circular and rectangular stacks respectively. The sample point requirements
contained in ISO 9096:2003 are detailed in Annex 1.

Table 2.3 Minimum number of sampling points for circular stacks

Range of sampling Range of duct Minimum number of Minimum number of


plane areas diameters sampling lines sampling points per
m2 m (diameters) plane
<0.1 <0.35 - 1a
0.1 to 1.0 0.35 to 1.1 2 4
1.1 to 2.0 1.1 to 1.6 2 8
>2.0 >1.6 2 At least 12 and 4 per m2 b
a using only one sample point may give rise to errors that give an uncertainty above 10%.
b for large ducts, 20 sampling points is generally sufficient

Table 2.4 Minimum number of sampling points for rectangular stacks

Range of sampling plane areas Minimum number of side Minimum number of sampling
m2 divisions a points per plane
<0.1 - 1b
0.1 to 1.0 2 4
1.1 to 2.0 3 9
>2.0 3 At least 12 and 4 per m2 c
Note a: Other side divisions may be necessary, for example if the longest stack side length is more than twice the
length of the shortest side (see Figure 2.4). Sample lines for square and rectangular stacks are explained in Section
2.1.8.2.
Note b: Using only one sampling point may give rise to errors that give an uncertainty above 10%
Note c: For large ducts, 20 sampling points is generally sufficient.

2.1.8 Position of sampling points along the sample lines

The sampling plane is divided into equal areas and sampling is carried out from points
in the centres of these areas. This is shown in Figure 2.1 for circular stacks and in
Figures 2.2, 2.3 and 2.4 for square and rectangular ducts.

Sampling points should be located either more than 3% of the sampling line length or
more than 5cm whichever is the greater value from the duct wall.

TGN M1, Version 4, July 2006 Page 9 of 33


2.1.8.1 Position of sampling points for circular stacks

The sampling plane is divided into equal areas, the central one being circular (see
Figure 2.1). The sampling points are located along two or more sampling lines
(diameters) at the centres of these equal areas.

Figure 2.1 Sampling in circular stacks (positions shown are for stacks >2 m in
diameter)

1
2
3 Xi

The precise positions of the sampling points will depend on:

the number of sampling lines chosen;


the number of sampling points that need to be used (see Table 2.3).
A commonly encountered situation is a circular stack with two sample lines. In this
case, a simple expression can be used to calculate the distance of each sampling point
from the duct wall.
xi = Kid

where: xi is the distance (m) from the stack wall to an individual sampling point;
Ki is a calibration factor (a percentage of the diameter);
d is the duct diameter (m) at the sampling plane;
i is the sample point identification position on the sample line.

Values for the factor K are given in Table 2.5 for different numbers of sampling
points (nd) required along each of two sampling lines.

TGN M1, Version 4, July 2006 Page 10 of 33


Table 2.5 Position of sampling points as a percentage distance across a circular
stack

Sample point Values of K (as a % of diameter) for different numbers of points (nd)
position (i) on the (central point included)
sampling line nd = 3 nd = 5 nd = 7 nd = 9
1 11.3 5.9 4.0 3.0
2 50.0 21.1 13.3 9.8
3 88.7 50.0 26.0 17.8
4 - 78.9 50.0 29.0
5 - 94.1 74.0 50.0
6 - - 86.7 71.0
7 - - 96.0 82.2
8 - - - 90.2
9 - - - 97.0

Table 2.5 does not apply to circular stacks where more than nine sampling points are
needed or more than two sample lines are used. In such cases, the following general
formula should be used to calculate the distance of each sampling point in from the
duct wall.
xi = 0.5d [1-{((2nr-2.i+1)nd+1)/(2nr.ndia+1)}]

where: i is sample point identification number* along the sampling line;


d is the inside diameter of the stack, i.e. the length of the sampling line (m);
nr is the number of sampling points on a sampling radius (i.e. 0.5d); and
ndia is the number of sampling diameters (sampling lines).

There is also an alternative method, known as the tangential method, for determining
the position of sampling points in circular stacks. This rule allows the approach
common in the United States (that is, no sampling point at the centre of the stack).
Details of the tangential method can be found in BS EN 13284-1:2002.

2.1.8.2 Position of sampling points for rectangular and square stacks

The sampling plane should be divided up into the required number of equal areas by
lines parallel to the stack walls (see Table 2.4). The distance between each of these
parallel lines is known as a side division. Sampling points are located at the centres
of the equal areas, also known as partial areas. Figure 2.2 shows the relationship
between the sample points in the centres of equal areas, the side divisions and the
sample lines. Refer to Section 2.1 for details on where to install access ports to reach
these sampling points.

*
The first point in from the access port is identified as position 1.

TGN M1, Version 4, July 2006 Page 11 of 33


Figure 2.2 Equal areas, side divisions, sampling lines for square/rectangular
stacks
3 side divisions along
shortest side 9 equal areas

3 side
divisions 9 sampling
along points
longest
side

Cross-section
of stack

3 sampling
lines

The most common case, shown in Figure 2.3, is for square and near-square stacks
(where the ratio of the longer sides l1 to the shorter sides l2 of the stack is no more
than 2:1). The longer and shorter sides of the stack are both divided into an equal
number of parts to meet the requirements of Table 2.4 for minimum numbers of
sample lines and sampling points. The number of partial areas, each having a
sampling point at its centre, is thus the square of the number of side divisions. These
areas have the same shape as the stack.

Figure 2.3 Sampling positions in square/near-square stacks where sides l1 to l2 is


2:1
l2 l1
2n1

l1
n1

l1

Cross-section
of stack

l2 l2
2n2 n2

TGN M1, Version 4, July 2006 Page 12 of 33


For stacks with a more extreme rectangular aspect ratio (ratio of longer sides l1 to the
shorter sides l2 is more than 2:1) a different approach is used, to avoid having long,
thin partial areas. The procedure is to give stack side l1 more side divisions than l2, so
that the partial areas have a length to breadth ratio of no more than 2:1. This is
illustrated in Figure 2.4.

Figure 2.4 Sampling positions in rectangular stack where sides l1 to l2 is >2:1

l1
l2 2n1

l1
n1 Cross-section
of stack

l1

l2 l2
2n2 n2

The requirements of Table 2.4 for minimum numbers of sample lines and sampling
points must be met. The number of sampling points is calculated as follows: if the
stack sampling plane sides l1 and l2 are divided into n1 and n2 parts respectively, then a
total of n1.n2 sampling points is obtained.

The distance between the stack wall and the first sample point will be l1/2n1 if
sampling was carried out from ports on side l2, or l2/2n2 if sampling was carried out
from ports on side l1.

2.2 Periodic sampling of gases

2.2.1 Special characteristics of sampling gases

For monitoring gases, the range of sampling equipment and apparatus is very wide.
However, they can be grouped conveniently into automated techniques and manual
techniques (see Box 2.2). The main steps in measuring gaseous pollutants are as
follows:

TGN M1, Version 4, July 2006 Page 13 of 33


Stage 1 Stage 3
Automated/ instrumental techniques The sampled substance
Representative sample
of source gas extracted is analysed by an
through probe, filtered appropriate analytical
and conditioned technique
Stage 2
Gaseous substances
adsorbed on, or
absorbed in, an
appropriate collection
medium

Manual techniques

When gases are measured using automated/instrumental techniques, such as gas


analysers, Stage 2 is omitted, and the sample goes directly to the analysis stage (Stage
3). In contrast, when gases are measured using manual techniques, Stage 3 is usually
carried out away from the site at an analytical laboratory.

Box 2.2 Automated and manual techniques


For automated techniques, the sampling and quantification stages are conventionally considered
to take place almost simultaneously, within an analyser. With manual techniques, the sample is
taken then the quantification and analysis takes place as a discrete, later stage.

Sampling-train configurations will vary according to the substance and the process
conditions, for example whether the gas stream is hot or cool, wet or dry, and whether
sampling is to be performed in an intrinsically safe area. For instance, a cool gas
stream will require Stage 1 of the sample train to have a heated sample line; very wet
gas streams may require drop-out pots. The sample train configuration may affect the
requirements for access and facilities. For example, Stages 1 and 2 may take place
immediately after the sample probe, with the apparatus located on the stack access
platform. Alternatively, an inert (and usually heated) sample line may be used to bring
the sample gas from the probe to Stages 2 and 3 at the base of the stack or in a mobile
laboratory.

It is also necessary to consider the phase of the target species. For example, if water
droplets are present which may absorb hydrogen chloride, isokinetic sampling may be
required.

2.2.2 Location requirements for monitoring gases

The location requirements for measuring gas concentrations are less exacting than for
particulates, as variations in velocity profiles tend not to affect the homogeneity of the
gas concentration. This means that the proximity to bends, branches, obstructions and
fans is less important. However, sampling after the ingress of dilution air must be
avoided. The criteria for measuring gas concentrations alone are described in Section
2.2.3.

TGN M1, Version 4, July 2006 Page 14 of 33


However, sometimes it is necessary to report mass emissions rates, such as g s-1, to
demonstrate environmental compliance, or for pollution inventory reporting or
emissions trading purposes Calculation of mass emissions rate requires the
measurement of gas volumetric flow-rate through the duct. This requires velocity
measurements to be taken at different points across the sampling plane. Measurements
to determine stack-gas velocity and volumetric flow rate should be made in
accordance with ISO 10780:19947 or BS EN13284-1. A suitable sampling location
should therefore conform to the particulate monitoring flow-stability requirements
described in Table 2.2.

2.2.3 Criteria for locating a sampling plane for gas concentrations

Ideally, sampling should be carried out from a sampling position where the gases are
homogeneous and there is positive gas flow.

For the proposed sampling location, it is necessary to determine any spatial or


temporal fluctuations in the gas concentration(s) by carrying out a preliminary survey
of the gas concentration using the grid measurement approach described in Section
2.1.5.

ISO/DIS 10396 states that a traversing gas sampling probe should be used to measure
the concentration(s) at a minimum of twelve points located at sampling locations
specified in ISO 9096:2003. The concentration is measured for a minimum of two
minutes at each traverse point using an automated analytical method. While the
traverse is carried out temporal variations in the flue gas are accounted for by a
second set of measurements taken at a fixed point in the stack.

The pollutant is considered to be homogenous (i.e. not stratified) if the concentration


at each individual traverse point differs by no more than 10% from the arithmetic
average concentration for all of the traverse points.

If the gas is shown to be homogenous it is only necessary to sample at one point


within the stack to determine the average concentration. The sample point used should
be positioned one-third to halfway in the stack.

If the gas is not homogenous (i.e. stratified) either a different sample location should
be found or a grid measurement approach used. CEN standard (prEN 15259 due to be
published in 2007) provides a procedure for representative sampling of
inhomogeneous gases using a grid measurement approach. In summary, the grid
measurement approach for sampling gases follows the same principles as particulate
sampling. However, unlike sampling for particulates when using an instrumental
technique the concentration is determined directly at each sampling point in the plane.
Also, the rate at which the gas is sampled at each sampling point is not adjusted
according to the stack gas velocity. Instead the sample mass flow per partial area is
determined by ensuring the sampling time spent at each sampling point is proportional
to the velocity at each point.

ISO 10396:1993 is currently being revised. It contains more stringent requirements for sample plane
selection than the 1993 version. Once published these more stringent requirements will apply.

TGN M1, Version 4, July 2006 Page 15 of 33


3 Sampling requirements: continuous emissions monitoring systems

3.1 CEMs measuring concentration

In many applications the calibration of the CEM is established by comparison with


simultaneous measurements obtained using a standard reference method. Wherever
possible, the CEMs and manual monitoring locations should be in close proximity.
Further information is contained in BS EN 14181:20048 and TGN M209.

Therefore for CEMs measuring particulates, the location of the CEM should be in
close proximity to the manual particulate monitoring location, which is determined by
the requirements of BS EN13284-1: 2002 (see Section 2.1.3, Table 2.2).

For CEMs that measure gases, the location of the CEM should be in close proximity
to the manual gas monitoring location, which is determined by the requirements of
ISO10396 (see Section 2.2.3).

3.2 CEMs measuring gas volumetric flow rates

The positional requirements for CEMs measuring gas volumetric flow rate are
specified in BS ISO 1416411, and these are summarised in Table 3.1. The flow-
stability criteria are given in Table 3.2.

Table 3.1 Positional recommendations for continuous gas-flow monitoring

General location of sampling plane Representative of total volume-flow in the duct


Length of straight section At least ten hydraulic diameters long.
Note: this is more stringent than BS EN 13284-1:2002.
Location of sampling plane in straight At least five hydraulic diameters upstream and at least five
section and in relation to bends fans hydraulic diameters downstream from any flow disturbance.
and the like

Table 3.2 Flow-stability criteria for continuous gas-flow monitoring


Angle of gas flow 10 from duct axis

Flow direction No local negative gas flow

Minimum velocity As specified by CEMs manufacturer

Gas velocity variations Must be 10% at any sample point

TGN M1, Version 4, July 2006 Page 16 of 33


4. Sampling facilities and safety requirements for stack-emission
monitoring
4.1. Sampling facilities

4.1.1 Safe working platform and means of access to the sampling position

Industrial processes are regulated by authorisations or permits issued under Integrated


Pollution Control (IPC) or Pollution and Prevention Control (PPC) Regulations.
These place requirements on an operator to provide a safe and permanent means of
access to enable monitoring to be carried out at specified release points. However, in
exceptional circumstances, for example, at an old installation where limited access
prevents the installation of a permanent platform, temporary structures (such as,
scaffolding) may be used, provided it is fully justified by the operator.

All platforms, whether permanent or temporary, should meet the minimum weight
criteria required for sampling. This is defined as 400kg point load in BS EN 13284-
1:2002 and for permanent platforms is achievable. However, temporary, scaffold
platforms cannot be constructed to this specification and must, instead, be constructed
to a specific minimum scafftag category of heavy duty or meet the requirements
stated in the monitoring standard, whichever is the greater. Temporary platforms must
also be tied to, or supported by, a permanent structure. Sampling from mobile access
platforms, cherry pickers or ladders is unacceptable. Sampling from roofs or
the tops of arrestment equipment, vessels and ducts is unacceptable unless they have
been assessed as being suitable by meeting the requirements for platforms described
in this TGN and the Work at Height (WAH) Regulations 2005**.

The platform and access must meet all current legislative requirements regarding
dimensions and construction, be maintained to a safe standard and undergo regular
inspection by a competent person. For scaffolding, a properly completed and dated
Scafftag is one means of demonstrating and recording this inspection. For
permanently installed platforms, the structural integrity of the platform and any
supports and attachments shall be assessed periodically by the process operator. The
inspection shall also include the effects of weathering, corrosion and damage. The
frequency and comprehensiveness of inspection shall be commensurate with the risk
of failure and serious injury. For example, a steel platform at height and in a corrosive
atmosphere may require more frequent and thorough inspections than a low platform
in a normal atmosphere. Records of inspections should be available for the
monitoring team to check before they ascend to the work area.

The WAH Regulations place specific stipulations that require the employer to carry
out inspections of work equipment and pre-use checks of places of work. Working

A permanent platform should be used where possible. If a temporary platform is required then the
process operator and sampling team must liase to ensure that the scaffold erected is of a sufficient
standard to support the minimum weight requirement. The sampling team leader should confirm this
before undertaking the work. Special or masonry independent tied scaffold would normally be
sufficient.
**
Annex 2 contains details of health and safety legislation, guidance and standards relevant to stack
emission monitoring.

TGN M1, Version 4, July 2006 Page 17 of 33


platforms and associated guard-rails, barriers, toe-boards, ladders etc, should be
inspected at the following frequencies:

after assembly/installation but before use;


at suitable intervals where there has been exposure to conditions causing
deterioration; and
at each time an exceptional circumstance has occurred which is liable to
jeopardise its safety.

The WAH regulations also require a prior to use check to be carried out. This should
be done each day the platform is used. It is the responsibility of the operator to do
this, although it should also be carried out as part of the stack emission monitoring
risk assessment.

The platform shall be provided with handrails and kick-boards that meet the
requirements of the Workplace (Health, Safety and Welfare) Regulations 1992,
(Regulation 13) for permanent platforms and the Health and Safety in Construction
Regulations (HS(G)150) for temporary platforms (see Annex 2).

Where the selected sample plane is located in a horizontal section of a large


rectangular duct, and where some of the sample points are positioned above a
convenient and safe working height (nominally 1.75m maximum for sample probe
handling), it will be necessary to provide a dual-level sampling platform of adequate
design so that sampling staff can carry out the full range of sampling requirements in
a safe and satisfactory manner.

It is not advisable to select a sampling plane in a horizontal section of a circular duct


as this presents practical difficulties in obtaining access to all the sample points.

Removable chains or self-closing gates shall be used at the platform to prevent


workers falling through access hatches or ladders.

Protection from adverse weather may be desirable for an exposed sampling position.
However, it should be recognised that any protective cladding installed at high levels
will affect wind loading on the stack and will be vulnerable to damage during high
winds. It may be preferable to ensure that sampling at elevated positions is only
carried out in periods of relatively calm weather as the installation of an enclosure at
the sampling platform does not remove the hazard of transporting equipment and
personnel to the platform under unfavourable conditions.

The platform shall not accumulate free-standing water and, if necessary, drainage is to
be provided.

BS EN 13284-1:2002 contains requirements related to the working platform. There


are also a number of CEN standards covering platforms and access (Annex 2).

4.1.2 Space for the equipment and personnel

The space/size requirements for platforms are shown in Figures 4.1 to 4.4. The
platform surface area should not be less than 5m2. The minimum width at any point

TGN M1, Version 4, July 2006 Page 18 of 33


shall be 2m. The minimum length in front of the access port shall be 2m or the length
of the probe (which includes nozzles, suction/support tubes and associated filter
holders) plus 1m (whichever is the greater). The platform should be wide enough to
prevent sampling equipment extending beyond the platform.

4.1.3 Means of entry into the stack (sampling access ports)

The access ports shall be big enough for the insertion and removal of the equipment
used and to allow the sampling points to be reached. BS EN 13284-1:2002
recommends that access ports have a minimum diameter of 125mm (illustrated in
Figure 4.5) or a surface area of 100mm x 250mm, except on stacks smaller than 0.7m
diameter. For small stacks (less than 0.7m diameter) a smaller socket (for example
50mm may be necessary, but there must be close liaison with the sampling team to
ensure the required sampling equipment can be accommodated.

The port socket shall not project into the gas stream (see Figure 4.5). Typical
arrangements of access fitments are shown in Figures 4.6 and 4.7. The operator must
maintain the ports in good condition and free them up prior to work being undertaken.

Many stacks in the UK have been fitted with a 4-inch nominal British Standard pipe (BSP) socket.

The aim is to simplify the insertion of an in-line 47mm filter holder, which is approximately 150mm
long.

TGN M1, Version 4, July 2006 Page 19 of 33


Figure 4.1 Typical area required behind probe for handling

Sampling line

Minimum of 2m or probe length* + 1m

Duct Platform area

Sampling line

Plan view
*the probe length includes nozzles, suction/support tubes and associated filter housing

Figure 4.2 Plan view of platform working area and orientation recommendations
for small vertical circular stacks (<3.6m diameter)

Stack

Sampling platform
subject to minimum of 5m2

Sockets

Minimum of 2m or probe length* + 1m


Probe length is approximately stack diameter

*Probe length includes nozzles, suction tubes/supports and filter holders

Figure not to scale

TGN M1, Version 4, July 2006 Page 20 of 33


Figure 4.3 Plan and side view of platform working area and orientation
recommendations for large vertical circular stacks (3.6m diameter)

Sampling should be carried out from


four sample holes on these large stacks

Figure not to scale

Platform
Minimum width of platform at
any point is 2m Stack

'L'
L (Length) = Probe length (including nozzles, suction tubes/supports and filter housing) +1m
Probe length is approximately stack diameter / 2.

MONORAIL SUPPORTS PROVISION FOR


LIFTING EQUIPMENT

TGN M1, Version 4, July 2006 Page 21 of 33


Figure 4.4 Plan view of recommended platform working area for square or
rectangular ducts (up to l1 = 3.6 m)

Minimum platform area (a x


b) shall be 5m2
Duct Sampling
w platform b

l1 a

Depth of platform (a) = Probe length* +1m

Duct side length, l1 (m) 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0
Duct side width, w (m) 0.6 8.0 1.0 1.2 1.4 1.6 1.8 2.0
Width of platform, b (m) 2.0 2.0 2.0 2.0 2.0 2.0 2.1 2.2

Duct side length, l1 (m) 2.2 2.4 2.6 2.8 3.0 3.2 3.4 3.6
Duct side width, w (m) 2.2 2.4 2.6 2.8 3.0 3.2 3.4 3.6
Width of platform, b (m) 2.3 2.4 2.5 2.6 2.7 2.8 2.9 3.0

*The probe length includes nozzles, suction/support tubes and associated filter housing

Figure 4.5 Standard 125mm access port

2
STACK WALL

129.30

1. Flange BS10 125mm (5)

2. Pipe stub 125mm schedule 40

3. Pipe stub length should be a minimum of 75mm from the stack wall (recommended is 100mm)

4. Recommendation that 1000mm of Unistrut P1000 is fitted vertically on the centre line of the
sample port for positioning of the monorail

TGN M1, Version 4, July 2006 Page 22 of 33


Figure 4.6 Typical arrangement of access fittings on large circular stacks (3.6m
diameter)

Parallel-sided socket

Centre line
90

Plan view

Parallel-sided socket

Side elevation

Parallel-sided socket

Note - for small circular stacks, two ports at 90 will usually suffice.

TGN M1, Version 4, July 2006 Page 23 of 33


Figure 4.7 Typical arrangement of access fittings on large square/rectangular
stacks

Sampling centre line

Plan view

Sampling centre line

Parallel-sided
socket

Sampling centre line

Side elevation

Note - for small stacks, ports on one side will usually suffice.

TGN M1, Version 4, July 2006 Page 24 of 33


4.1.4 Sampling facilities for periodic monitoring of gases

Access and facilities requirements for gases alone are usually less demanding than for
particulates. In practice, meeting the requirements for particulates in Section 4.1 will
also satisfy the requirements for gases. When gas concentrations only are to be
monitored, smaller access ports than those specified for particulates may be
permissible following consultation and agreement with the sampling team.

4.1.5 Sampling facilities for CEMs

When designing a platform for CEMs access and facilities are required to enable:

calibration by periodic monitoring using a standard method;


routine maintenance and operational functional checks, such as span and zero
checks to be carried out.

As CEMs require calibration by periodic monitoring the access and facilities should
as a minimum comply with the requirements given in Section 4.1.1 and 4.1.2, for
particulates and gases respectively.

4.1.6 Essential services

The sampling position should have artificial lighting or have facilities for temporary
lighting. The sampling position should be well ventilated. Single phase 110 V
electrical power of a suitable current shall be provided by a suitable number of
outdoor waterproof sockets at the platform. Water, drainage and compressed air shall
be supplied at the request of the sampling team. When undertaking sampling of gases
using instrumental techniques, many monitoring organisations use mobile emissions
monitoring laboratories, which may require a 32amp or even a 63amp power supply.
When this type of sampling is undertaken operators need to provide parking facilities
for these vehicles within close proximity to the sampling location.

Lifting equipment is required for the raising and lowering of apparatus where access
to the sampling platform is by vertical, or steeply inclined, ladders or stairs. In all
such cases, the lifting equipment (for example, hoists) and attachments (for example,
eyes) must be installed, inspected and maintained by a competent person.

A sampling monorail may be attached above the sampling ports to enable certain
designs of sampling train to be suspended.

4.1.7 Installing and upgrading sampling platforms at existing stacks

It is sometimes necessary to retrofit new platforms or upgrade platforms on existing


stacks. It must be borne in mind that the original design of the stack may not have
taken such changes into account. The installation or extension of fixed ladders and
gantries to an existing stack will bring about a significant increase to the total load
(especially wind load) on the structure. This effect may be particularly significant on
stacks with small diameters, as they must support structures that meet the minimum
size requirement specified in this TGN.

TGN M1, Version 4, July 2006 Page 25 of 33


When retrofitting fixed ladders and platforms to a stack an appropriately qualified
engineer* should be engaged to carry out a design check of all components, including
foundations, to ensure that it is capable of bearing the increased load. To carry out this
assessment full design details of both the existing structure and the proposed sampling
platforms and access ladders must be available. It is also likely that the engineer will
require the stack to be inspected by a competent specialist contractor to ensure that
deterioration has not occurred to the overall stability of the structure. If necessary, it
may be possible to carry out minor strengthening works to an existing structure to
accommodate additional load, although there is a limit to the effectiveness of this
approach.

If the changes to the platform are supported by the existing structure then the
requirement for inspection of the platforms prior to use may well need to be extended
to the stack itself.

Annex 2 provides details of guidance and standards relevant to construction,


maintenance and inspection of stacks.

4.2 The risk-management approach to site work

4.2.1 Safety has the highest priority

Safety must be considered at the earliest point in the monitoring strategy, and must be
revisited whenever a decision is made on sampling positions, access and
requirements. Any change to the sampling positions, access and requirements is
subject to the overriding requirement for the work to be carried out safely for
example, a modification to the sampling position that would theoretically provide a
technical improvement must not proceed if it introduces an unacceptable safety risk.

There are many hazards associated with stack monitoring. The basic principles of
health and safety must be applied. In particular, a risk assessment must be carried out
before starting work - this is a legal requirement. The risk assessment should be
documented. Risk assessments should also be performed during the site review
process. Further guidance is available in the MCERTS Performance standard for
organisations.

The risk assessment will assess the level of risk from each of the various hazards
present. If the risk is unacceptable, control measures must be used to reduce the risk
to an acceptable level before starting work. It is recommended that, as a minimum,
the routine hazards described in Section 4.2.6 of this TGN should be included in the
risk assessment. However, there may be other hazards - every site is different. The
reader is advised to consult the Source Testing Associations (STA) booklet Risk
Assessment Guide: Industrial-emission Monitoring (see Annex 2).

The focus of this section is on periodic monitoring, as this approach requires a


considerable amount of manual work on-site. However, the principles apply equally
*
Details of qualified engineers and specialist inspection contractors can be obtained from trade
associations such as The Association of Technical Lightning and Access Specialists (www.atlas-
1.org.uk).

TGN M1, Version 4, July 2006 Page 26 of 33


when using CEMs and should be followed whenever manual work on CEMs is
carried out, for example, during installation, maintenance and calibration.

4.2.2 Prominent hazards encountered when stack-emission monitoring

The most prominent hazards are shown in Figure 4.8. It must be reiterated that this is
not an exhaustive list and there may be other hazards. Every site is different.

Figure 4.8 Most prominent hazards associated with stack monitoring

Temperature Fire and


extremes emergency
Site traffic

Wind, rain,
lightning, snow Mechanical
and ice operations
Weather, General site
environment hazards
Sunburn and welfare Chemical
operations
Lone working
RISK TO
Tiredness
HEALTH &
SAFETY
Lifting

Chemical
hazards in lab Physical Falling
hazards at stack
Burns
Exposure to Chemical
substances used in hazards at stack
Electricity
analysis and
cleaning
Compressed gases
Exposure to Exposure to
substances used in substances from
monitoring tests flue gases

4.2.3 The risk-assessment process

The fundamental stages of the risk-assessment process can be summarised as:

Step 1 Step 2 Step 3


Identify the Assess the RISKS Apply CONTROL
HAZARDS MEASURES

TGN M1, Version 4, July 2006 Page 27 of 33


As the risk assessment forms the foundation of safe working on stacks, it is very
important to understand the distinction between hazard and risk. These terms are
defined in Box 4.1.

Box 4.1 The distinction between hazard and risk


Hazard - a substance or physical situation with inherent potential to cause harm
Risk - an estimation of the likelihood of that potential being realised, within a
specified period or in specified circumstances, and the consequence

Using an extreme example to illustrate this difference between hazard and risk,
working on stacks is associated with the hazard of slips on icy platforms. The risk of
slipping is high on a cold winters day, but is very low in summer.

The first step of the risk assessment is therefore to identify the hazards that will be
faced. Then, a judgement must be made on what the risk will be (that is, the
likelihood of an accident) in the light of all the relevant factors. If the risk is not
acceptable, then control measures must be put in place to reduce the risk. The
criterion for the risk being acceptable is that the risk shall be as low as is reasonably
practicable, commonly known by the abbreviation ALARP. Only then should work
commence. Control measures can be applied according to the following hierarchy:

engineering - for example, a self-closing gate to reduce the risk of falls from the
platform;
procedural - for example, permit-to-work systems;
personal protective equipment (PPE) - for example, safety goggles to reduce the
risk of eye injury when opening access ports.

Engineering control measures should be considered first, as these measures may either
remove the hazard entirely or reduce the risk permanently. PPE measures should be
used to reduce the risk further only when other measures fail to reduce the risk to as
low as reasonably practicable. PPE should not be the control measure of first choice.

4.2.4 Responsibilities

The Management of Health and Safety at Work Regulations 1999 has many
requirements. Specifically, it places a duty of care on employers to:

ensure the competency of employees through training and experience to allow


them to work in a safe manner;
adequately assess the health and safety risks of employees and any other persons
not in his employment who may be affected by the works;
identify and implement appropriate risk-control measures to ensure the safety of
employees and other persons;
review risks and control measures regularly to ensure continued validity.

TGN M1, Version 4, July 2006 Page 28 of 33


For operators carrying out stack-emissions monitoring using their own staff, the
responsibility for the risk assessment and safe systems of work is straightforward.
Where operators contract-out the monitoring, both the operator and monitoring
contractor have the responsibility as site occupier and employer to follow safe
systems of work.

The operator also has a responsibility to employ competent monitoring organisations


and the monitoring organisation has a responsibility to ensure employees are
competent to carry out the work safely.

Where work is being carried out by a monitoring organisation directly for us, the
monitoring organisation, the operator and the regulator all have responsibilities in this
regard. In practice, the monitoring team is usually best placed to carry out a
comprehensive risk assessment of the work they carry out on site. Since they are also
usually subject to the greatest risk, the site team should always carry out their own
risk assessment, regardless of whether the operator has done so.

4.2.5 When to carry out a risk assessment

Where a monitoring organisation has not previously carried out sampling from a
particular stack, a site review will be necessary to:

carry out a risk assessment;


assess the suitability of the sampling position;
deal with practical issues to ensure subsequent monitoring proceeds smoothly (for
example, suitability of equipment, length of probes required).

It is very important to understand that all safety improvements and control measures
must be in place before the monitoring team starts work. For this reason, a risk
assessment should be carried out as part of a site review, as this gives the site operator
time to implement any control measures found to be necessary.

As well as carrying out a risk assessment at the site review stage, the monitoring team
must carry out a risk assessment before they start sampling work. The findings of the
risk assessment should be reviewed and agreed by the members of the monitoring
team. It is important that this risk assessment is carried out at the start of every
monitoring campaign at a site, even if the team has been there before. This is good
practice because it focuses the teams attention on safety as the first issue to address
on-site. It also reduces the possibility of the staff becoming complacent after several
visits because they feel they know all the issues.

4.2.6 Getting the operator involved

When the monitoring team arrives on-site, its first task must be to conduct the risk-
assessment. If the team has not worked on the site before, the operators
representative should accompany them as they make the assessment for reasons of
safety and to provide knowledge of specialised site-specific issues (for example,
process conditions, escape routes). It is not always necessary for the team to be
accompanied during the risk assessment when they return for repeat visits.

TGN M1, Version 4, July 2006 Page 29 of 33


However, whether it is the teams first visit to the site or a repeat visit, the operators
representative should be briefed on the findings of the completed risk assessment.
This will give the operator the opportunity to raise any additional issues of concern,
and comment on the findings of the assessment and the control measures the
monitoring team has decided will be necessary. If the operator has any relevant
comments, these should be considered. They can be incorporated into the assessment
and its findings if they reduce the risk further.

Some of the control measures required may need to be put in place by the operator.
The operators confirmation that these have been completed should be obtained
before monitoring work is started.

When the site work is finished, any relevant comments should be noted on the risk
assessment based on any lessons learnt. This will be useful for the next visit.

4.2.7 Reporting accidents and near misses

There is a statutory requirement to report certain accidents under the Reporting of


Injuries Diseases and Dangerous Occurrences Regulations (RIDDOR) 1995. Any
incidents coming under these criteria must be reported to the Health and Safety
Executive. However, there are additional benefits to be gained from informing
relevant organisations such as the STA and us about such events as well as other, non-
reportable, accidents or near misses. Though some of the occurrences may be minor,
knowledge about them aids the development of procedures and guidance to avoid
future accidents.

The STA produces guidance on safe working procedures for stack monitoring. This is
regularly revised and updated, taking into account legislative changes and lessons
learned from incidents and near misses. The STA also has a fast- track system for
disseminating urgent safety information to members. To enable the STA to give
maximum value to its members, it asks monitoring teams and operators to submit
details of incidents and near-misses. These submissions are treated in the strictest
confidence and can, if desired, be made anonymously.

4.2.8 Further guidance

Annex 2 shows some of the major items of legislation and guidance relevant to the
hazards depicted in Figure 4.8. The STA has produced a health and safety booklet,
which describes each of the most prominent hazards and the factors that affect the risk
of an accident from them. This guidance, together with other relevant guidance,
should be consulted as part of the risk assessment process. However, safety
management is a fast-evolving subject and new guidance, and new and revised
legislation appears frequently. All parties involved in stack-emission monitoring
should ensure they take account of the most recent developments.

TGN M1, Version 4, July 2006 Page 30 of 33


Annex 1 Sample point requirements as specified in ISO 9096:2003

Table 1 Minimum number of sampling points for circular stacks


Range of duct Minimum Minimum number of Minimum number of
diameters number of sampling points per sampling points per
(m) sampling lines line, plane,
(diameters) Incl. Excl. Incl. Excl.
centre centre centre centre
point point point point
<0.35 - 1a - 1a -
0.35 to 0.70 2 3 2 5 4
0.70 to 1.00 2 5 4 9 8
1.00 to 2.00 2 7 6 13 12
>2.00 2 9 8 17 16
a. Using only one sampling point can give rise to errors greater than those specified in ISO 9096:2003

Table 2 Minimum number of sampling points for rectangular stacks


Range of Minimum number of side Minimum number of sampling points
sampling plane divisions a per plane
areas (m2)
<0.09 - 1b
0.09 to 0.38 2 4
0.38 to 1.50 3 9
>1.50 4 16
Note a: Other side divisions may be necessary, for example, if the longest stack side length is more than twice
the length of the shortest side (see Figure 2.4). Sample lines for square and rectangular stacks are explained in
Section 2.1.8.2
Note b: Using only one sampling point can give rise to errors greater than those specified in ISO 9096:2003

TGN M1, Version 4, July 2006 Page 31 of 33


Annex 2 Legislation, guidance and standards relevant to stack-
emission monitoring health and safety

Legislation
Electricity at Work Regulations 1989
Personal Protective Equipment at Work Regulations 1992
Workplace (Health, Safety and Welfare) Regulations 1992
The Carriage of Dangerous Goods (Classification, Packaging and Labelling) and Use of
Transportable Pressure Receptacles Regulations, 2004
The Lifting Operations and Lifting Equipment Regulations 1998 (LOLER)
Control of Substances Hazardous to Health Regulations 1999 (COSHH)
Management of Health and Safety at Work Regulations 1999
Noise at Work Regulations 1989
Construction Health and Welfare Regulations 1996
Manual Handling Operations Regulations 1998
Confined Spaces Regulations 1999
Work at Height Regulations 2005. Statutory Instrument No. 735. ISBN 0 11 0725638.
HMSO.
Guidance and standards
HS(G)150, Health and Safety in Construction: guidance on small lifting equipment
HS(G)107, Maintaining portable and transportable electrical equipment
HSE guidance leaflet INDG308 5/00 C1200, The Safe Use of Gas Cylinders
HSE information leaflet IND(G)147(L), Keep Your Top On Health Risks from
Working in the Sun
HSE Guidance, 5 Steps to Risk Assessment
HSE Guidance, A Guide to Risk Assessment Requirements
HSC Safe work in confined spaces
BS4211 Specification for ladders for access to chimneys, other high structures, silos and
bins
STA Health Safety Guidance Note HSGN0008, Risk Assessment Guide: Industrial-
emission Monitoring
EN ISO 14122-1: 2001, Safety of machinery Permanent means of access to machines
and industrial plants Part 1: Choice of a fixed means of access between two levels.
EN ISO 14122-2: 2001, Safety of machinery Permanent means of access to machines
and industrial plants Part 2: Working platforms and gangways.
EN ISO 14122-3: 2001, Safety of machinery Permanent means of access to machines
and industrial plants Part 3: Stairways, stepladders and guard-rails.
EN ISO 14122-4: 1996, Safety of machinery Permanent means of access to machines
and industrial plants Part 4: Fixed ladders.
CICIND Model Code for Concrete Chimneys
CICIND Model Code for Steel Chimneys
CICIND Chimney Maintenance Guide
BS 4076 : 1989 Specification for Steel Chimneys
GS53 HSE Guidance Note for the Inspection of Single Flue Industrial Steel Chimneys
ATLAS Guide to the Inspection of Single Flue Industrial Steel Chimneys
ATLAS Guide to the Inspection of Reinforced Concrete Chimneys and Cooling Towers

TGN M1, Version 4, July 2006 Page 32 of 33


References
1. MCERTS, Manual stack-emission monitoring: performance standard for
organisations, Version 4, September 2003. Environment Agency.

2. MCERTS, Manual-stack emission monitoring: personnel competency standard,


Version 3, July 2005, Environment Agency.

3. Technical Guidance Note M2 Monitoring of Stack Emissions to Air, Version 3.1, June
2005 Environment Agency.

4. BS EN 13824-1:2002 Stationary source emissions Determination of low range


mass concentration of dust Part 1 Manual gravimetric method..

5. BS ISO 9096:2003 Stationary source emissions Manual determination of mass


concentration of particulate matter.

6. Quality Guidance Note QGN001 r1, Guidance on Assessing Measurement


Uncertainty in Stack Monitoring, Source Testing Association, September 2004.

7. ISO 10780:1994, Stationary source emissions Measurement of velocity and volume


flowrate of gas streams in ducts.

8. BS EN 14181:2004. Stationary source emissions Quality assurance of automated


measuring systems.

9. Technical Guidance Note M20 - Quality assurance of continuos emissions


monitoring systems - application of BS EN 14181 and BS EN 13284-1. Environment
Agency.

10. BS ISO 14164: 1999, Stationary source emissions Determination of the volume
flowrate of gas streams in ducts Automated method.

TGN M1, Version 4, July 2006 Page 33 of 33