SPRI Combustion Guidance 2013

Scottish Pollutant Release Inventory Reporting
Combustion Guidance Note

December 2013
SPRI Combustion Guidance 2013
Page 1 of 35
Published December 2013
CONTENTS
Introduction
1.1
1.2
1.2.1
1.2.2
1.3
1.4
1.5
Scope of the guidance note

Release estimation techniques (RETs)
Uncertainty
Limits of detection
Access to further information
Disclosing information you provide
Feedback
2
2
4
4
4
4
4
Emissions to air
2.1
2.2
2.2.1
2.2.2
2.3
2.3.1
2.3.2
2.3.3
2.3.4
2.3.5
2.4
Relevant pollutants
Emission sources
Point source emissions
Fugitive emissions
Quantification of emissions
Sampling data
Using continuous emission monitoring systems (CEMS) data
Emission factors
Fuel analysis data
Fugitive emissions
Substances reported as
5
6
6
6
6
6
7
9
19
22
22
Emissions to water and waste water
24
3.1
3.2
3.3
3.4
3.5
Relevant pollutants
Emission sources
If no emission factors or other RETs are available
24
24
24
26
27
Off-site waste transfers
28
4.1
4.2
Relevant wastes
Transboundary shipments of hazardous waste
28
28
References and further information
29
Appendix A Normalisation of emission concentrations

Appendix B Conversion factors
Appendix C Glossary

31
33
34
Page 1 of 35
Introduction
This Guidance Note provides information to assist you in preparing submissions to the Scottish
Pollutant Release Inventory (SPRI). It has been developed through a process of consultation
between industry stakeholders and ourselves. It is part of a range of guidance and tools produced
to assist in the completion of the annual SPRI return. Information on the range of guidance notes
is available on the SPRI website1.
By providing a series of guidance notes, we seek to ease the burden on industry and to raise the
quality of SPRI data. In addition, the increasing use of SPRI data in policy-making and for
comparisons on a sector and national basis has led to a need for increased consistency in SPRI
data and an improved understanding of uncertainty.
1.1
Scope of the guidance note
This Note covers activities that are regulated as Combustion Activities under the Pollution
Prevention and Control (Scotland) Regulations 2000 (as amended) (PPC). Included within the
scope are Part A prescribed/listed activities regulated under Section 1.1 of the PPC Regulations2.
Following the guidance in this note, in conjunction with the General SPRI Guidance Note 20133,
will ensure that you meet the reporting requirements of the E-PRTR Regulation4. The General Note
includes a more prescriptive indication of methods of measurement and calculation which should
be applied to produce a SPRI data return. Data on transboundary shipments of hazardous and
non-hazardous waste taking place during the reporting year must also be reported to meet the EPRTR requirements.
Note that you are not required to include any emissions due to historic activities (for example, from
contaminated land) in your SPRI return, unless the original contamination is related to an ongoing
activity.
Emissions reported relate to operations of the activity (direct emissions from point and fugitive
sources) and from unauthorised or unplanned events termed accidental emissions (e.g. resulting
from equipment failure).
For accidental emissions you should not include any emissions resulting from routine maintenance,
such as the release associated with recharging cooling fluids, as these releases will be included
within the total mass reporting within the SPRI return
1.2
Release estimation techniques (RETs)
This Note provides information on RETs for the SPRI substances relevant to this industry sector.
Emphasis has been placed on providing information on the most common emissions from the
sector. However, the absence of an RET for a substance in this Note does not imply that an
emission should not be reported to the SPRI. The obligation remains to report on all relevant
emissions.
In general, there are four types of RETs that may be used to evaluate emissions:
http://www.sepa.org.uk/spri
http://www.legislation.gov.uk/ssi/2000/323/contents/made
http://bit.ly/uuRWwH
4
http://prtr.ec.europa.eu/.
2
3

Page 2 of 35
Sampling or direct monitoring;

Emission factors;
Fuel analysis or other engineering calculations; and
Mass balance.
Depending on the particular site, pollutant or process, each of the above techniques may be the
most appropriate to use. You should have an understanding of the factors that lead to the
selection of the most appropriate RET and be able to justify why the technique has been selected.
You should always select the RET based on the application for which it has been designed.
However, there are cases where mandatory RETs exist, such as when reporting emissions under
European Union (EU) Directives or in accordance with authorisation or permit conditions.
Examples of this are the reporting requirements under the Large Combustion Plant Directive
(LCPD)5 and the European Union Emissions Trading System (EU ETS) for greenhouse gases
(GHGs)6. For consistency, you should also consider extending the use of such methods to
additional parts of the installation that are not subject to the mandatory requirement, but that have
SPRI reporting obligations. At a minimum the SPRI data should match other reporting obligations,
where there are common reportable substances, such as carbon dioxide emissions.
In the absence of a mandatory methodology, you should use methods that have been agreed with
SEPA for your industrial sector, where available. An example of this is the UK Electricity Supply
Industry (ESI) methodology7 that is developed for all pulverised coal, large-scale oil and gas-fired
Combined Heat and Power (CHP) power generation plant. A summary is contained in relevant
sections of this Note for use on similar types of plant.
Mandatory or industry methodologies should be used where available and site specific data in the
form of monitored emission concentrations or mass balance techniques should be used where
appropriate. Measured emission concentrations should be ideally based on data obtained using
appropriately certified equipment, and/or accredited services. Continuous monitoring data should
normally be used in preference to periodically sampled data. Sections 2.3.1 and 2.3.2 contain
guidance on the use of sampling data for determination of emissions to air.
Where emission factors are used, preference should be given to the use of site-specific emission
factors over those developed from other representative plant. However, in order to develop a sitespecific emission factor, it is necessary to relate the level of emissions to an activity within the
process. This is normally obtained from sampling data, or can be obtained from manufacturers
information or by calculation. In the absence of such information, UK or international emission
factors can be used. UK factors are presented in this Note and have been termed generic factors.
The RETs presented in this Note relate principally to representative operating conditions.
However, it is important to recognise that emissions resulting from significant operating deviations
(e.g. failure of abatement plant) and/or accidental events (e.g. spills) also need to be estimated. In
the case of air emissions from spillage events, it may be necessary to make an estimate of the
amount of substances released as vapour. For all spills, the additional emission is the net
emission, i.e. the quantity of the SPRI reportable substance spilled, less the quantity recovered or
consumed during clean-up operations. Further information on RETs is available from the SPRI
document entitled SPRI Operator Guidance on Release Estimation Techniques (RET)8.
http://www.dhttp://www.defra.gov.uk/environment/quality/industrial/eu-international/lcpd/
http://ec.europa.eu/clima/policies/ets/index_en.htm.
See section 5 References and further information.
8
http://bit.ly/u2MaLa.
6

Page 3 of 35
1.2.1 Uncertainty
The level of uncertainty of a determination is important in judging whether a change in reported
emissions is important or not. For example, if the level of reported emissions from one year to the
next increases by 10%, this may not be a real increase if the level of uncertainty in the
measurement is 20%. In this case, two different values are reported but the actual emissions
could be the same.
The guidance given in this Note is aimed at reducing the variability and uncertainty in emission
determination.
1.2.2 Limits of detection

If the best available information indicates that a substance is not released from your process, report n/a for
that substance. Where a substance may be released but at a release concentration that is below the limit of
detection, you also need to report n/a unless an alternative release estimation technique, such as mass
balance, produces an applicable result. By limit of detection we mean the lowest concentration which can be
measured by the analytical method prescribed in the Permit, or such other method as we approve.
We recognise that there may be circumstances where some analyses in a series do not detect a substance
but others do. Provided that no more than 5% of the readings show a positive value, and the values obtained
are not more that 20% above the accepted limit of detection, you can treat them as if they were also reported
as below the limit of detection. In any other case, use the values obtained and make the assumption that
where the substance is reported as not detected it is present at 50% of the LOD. In these cases, you need to
multiply each concentration (that is, those measured at above the LOD as measured and those measured at
below the LOD as of the LOD) by the total flow during the period that the measurement relates to in order
to determine the mass emission.
In some cases we may have agreed a different methodology with you for a particular substance or process.
If so, use this in place of the procedure above.
If as a result of this methodology a positive result is obtained that is below the reporting threshold
(BRT), it should be reported as Below Reporting Threshold (BRT) rather than n/a.
1.3
Access to further information
This Note does not provide detailed information on suggested measurement and monitoring
techniques as this is dealt with extensively in other guidance documents that we publish.
References to monitoring guidance and other sources of reference information are included in
Section 5 of this document.
1.4
Disclosing information you provide
The General SPRI Guidance Note provides information relating to commercial confidentiality.
1.5
Feedback
In order to improve the quality of our guidance, we would like to receive feedback from you on your
experiences in using this Note. Such feedback will be taken into account in the preparation of
other guidance notes in this series, and in the updating of this document.
Feedback should be submitted to the SPRI team by email:
Email: SPRIAdministration@sepa.org.uk

Page 4 of 35
Emissions to air
2.1
Relevant pollutants
The combustion of fossil fuels will almost always lead to releases to air of CO2, CO, NOx and
Particulates. Other pollutants will be released dependent on the fuel and combustion technology
used, particularly SO2. Smaller quantities of pollutants such as trace metals, hydrogen halides, unburnt hydrocarbons, non-methane volatile organic compounds (NMVOCs) and dioxins may also be
emitted, but they may have a significant influence on the environment due to their toxicity or their
persistence.
Pyrolysis and gasification can be used to pre-treat fuels in order to remove impurities or to produce
fuel that can be combusted more readily. The fuels can be either pre-cleaned before combustion
or directly combusted. The pollutants emitted from the process are therefore critically dependent
on the fuel used and the nature of the process.
The following table illustrates the likely pollutants emitted from different types of fuel. The table
should be taken as a guide only, and you should verify that there are no other pollutants emitted
from your process.
Table 1
Guide of main pollutants emitted by combustion activities to air
Fuel type
Solid
Inputs
Coal
Biomass+
Potential air emissions

NOx, CO, CO2, SOx, particulate matter
(including PM10), fugitive dust, trace metals,
PCBs and PAHs, hydrogen halides,
methane, NMVOCs, dioxins, N2O
NOx, CO, CO2, SOx (low), particulate matter
(including PM10), CH4, NMVOCs, trace
metals (from sewage sludge)
Liquid
Fuel oil

(including PM10), PCBs and PAHs, hydrogen
chloride, trace metals, and dioxins
Gaseous
Natural gas
NOx, CO, CO2, CH4
Secondary fuels
Solid, liquid or gaseous

(including PM10), PCBs and PAHs, hydrogen
halides, trace metals, NMVOCs, H2S,
ammonia and dioxins
The percentage proportion of the total CO2 attributable to biomass (non-fossil fuel) can be
recorded within Section C of the SPRI reporting form, within the Carbon Dioxide substance. This
is the percentage of the total CO2 emissions attributable to biomass fuels. Where you record
BRT you can still enter a percentage figure within the Biomass Percentage box. If you
calculate you are above the reporting threshold enter the total CO2 figure which should include
both fossil fuel emissions as well as biomass-derived emissions.
Subsidiary or substitute fuels may contain other pollutants that will require reporting.

Page 5 of 35
2.2
Emission sources
2.2.1 Point source emissions

These emissions are exhausted via a stack or vent, i.e. a single point source into the atmosphere.
Abatement equipment, e.g. an electrostatic precipitator (ESP) or fabric filter (bag house) can be
incorporated into the exhaust system prior to discharge to atmosphere. Point source emissions will
be the most significant emission source for combustion activities.
2.2.2 Fugitive emissions

Fugitive emissions are those that are not released from a point source such as a stack. Examples
of fugitive emissions include dust from coal and ash stockpiles and entrainment of pollutants during
material handling. Leaks from valves and flanges are also examples of fugitive emissions. With
appropriate management and control, these emission sources are generally minor for the
combustion sector. Only fugitive emissions that leave the site need to be reported to the SPRI.
Whilst contained spills would therefore not need to be reported, you should report vapour
emissions that may have dispersed.
2.3
2.3.1 Sampling data

In order to use sampling data to estimate emissions, information is required on both the flowrate
and pollutant concentration. In order to accurately determine annual emissions, sampling for SPRI
reporting should be performed under conditions representative of annual operations and ideally in
accordance with methods or standards that we have approved.
Care should be taken with relying on the results of one spot sample in order to report annual
emissions, unless you are certain that the process conditions are representative of annual average
operations. Where a process has a number of steady state conditions, it may be necessary to take
samples under each operating condition and average the result according to the length of time the
process operates at each condition. Similarly, where process conditions at the time of the spot
sampling are uncertain, it may be necessary to take several samples and to average the results in
order to provide the final annual emission estimate. Good engineering judgement should be used
in order to select the most appropriate sampling time and data to use. You should be able to justify
the sampling programme selected.
Sampling as part of a permit condition may require that the monitoring be undertaken at maximum
load (i.e. higher than annual operating conditions) and this should be taken into account in the
annual emission estimates. When in doubt, the proposed sampling protocols should be confirmed
by us.
In order to estimate annual emissions from sampling data, the first step is to multiply the measured
emission concentrations by the volumetric flowrates of the emission source at the time of the test.
Assuming that representative sampling has been undertaken, these emission rates are then
aggregated together for the annual operating time.
Care should be taken to ensure that the emission concentration and flowrate are compatible, e.g.
normalised emission concentrations should be multiplied by normalised volumetric flowrates or
actual, measured emission concentrations multiplied by actual, measured volumetric flowrates.
Normalised emission rates are quoted in terms of a standard oxygen concentration, and are

Page 6 of 35
usually dry gas, at a temperature of 273K and a pressure of 101.3 kPa. It is always good practice
to confirm the basis of measured data. Formulae for conversion between normalised and actual
emission concentrations are contained in Appendix A of this Note.
Sampled emission concentrations are also often reported in parts per million (ppm). In order to
estimate annual emissions, these need to be converted to mg/m3 at the emission temperature at
which the volumetric flowrate is measured. Formulae for converting ppm to mg/m 3 are contained
in Appendix B.
The following section shows how to calculate emissions based on stack sampling data expressed
in mg/m3. An example involving PM10 emissions is included, although the same general
methodology is applicable for the majority of the substances listed in the SPRI.
E
C x Q x 0.0036 x [Op Hours]
Where:
E
C
Q
0.0036
Op hours
(1)
= emission rate of pollutant (kg/yr)

= pollutant concentration (mg/m3)
= volumetric flowrate of the emission (m3/s)
= the conversion factor from mg/s to kg/hr
= the operating hours of the activity per year
Where the pollutant concentration is consistent over the averaging period (i.e. one year), equation
1 can be written as:
E
C x M x V x 10-6
Where:
(2)
E
C
M
V

= average pollutant concentration (mg/m3)
= mass of fuel burnt in one year (te dry fuel)
= standard volume of flue gas per tonne of fuel (m3/te dry fuel)
Example 1
The following example is for PM10 emissions from combustion activities using equation 1.
Operating hours
PM10 emission
concentration
Emission volumetric
flowrate
E
=
=
=
=
=
24 hours/day, 280 days per year

50 mg/m3 (normalised to 273K, dry, 3% oxygen)
10 m3/s (normalised to 273K, dry, 3% oxygen)
C x Q x 0.0036 x 24 x 280
50 x 10 x 0.0036 x 24 x 280
12,096 kg/yr
The use of continuous emission monitoring systems (CEMS) is considered below, which in
essence, follows the same principles as using spot sampling data.
2.3.2 Using continuous emission monitoring systems (CEMS) data

The revised LCPD contains requirements for the installation of CEMS for the measurement of SO 2,
NOx and PM emissions., for certain combustion plants Knowledge of the corresponding volumetric
flowrate is required in order to determine mass emissions.

Page 7 of 35
In general, you should use CEMS data that are from appropriately calibrated instrumentation
operating within stated tolerances. Although CEMS can report real-time emissions over a variety
of time periods automatically, it may be necessary to manually determine annual emissions from
such data, especially for periods where data may be out of tolerance. In any case, where annual
emissions are calculated within the software of a CEMS, it is good practice to manually check the
data in order to ensure that the automatic calculations are accurate.
For the Electricity Supply Industry, it may not be possible to obtain valid CEMS data during start-up
and shut-down. In these circumstances, for the purposes of reporting to the SPRI, for example, an
alternative approach using emission factors, can be used by agreement.
The Waste Incineration (WID) and LCP Directives require subtraction of confidence intervals (as
specified in the appropriate Directive) from CEM average values, to provide "validated" averages
that are compared against the given ELVs for compliance purposes. This is acceptable for
relatively short-term average periods, but not long-term periods (such as a whole year and SPRI
returns) when positive and negative errors (random errors) would be increasingly expected to
cancel each other out. Therefore, confidence intervals must not be subtracted from the average
values generated from the raw emissions data, prior to calculation of annual mass emissions
(unless part of an over-riding written agreement with SEPA).
Prior to using CEMS to determine emissions, it is preferable to agree the methodology for
collecting and averaging the data with us.
The basic equation for determining emissions is equation 1, adjusted for the appropriate time
period of the measurement. It must be applied for each time period for which emission
measurements are available in the year, following the guidance given in Section 2.3.1. Normally,
the measurement time periods are the same, such that it is possible to simply multiply the average
emission rate by the operating time per year to obtain the annual emission. However, it may be
that the measurement time periods vary and then equation 3 should be used.
E
1n (Ei x t)
Where:
E
Ei
t
n
(3)
= emission rate of pollutant over time period (t)
= time period for emission measurement
= number of time periods in the year
Example 2
This example shows how SO2 emissions can be calculated using equation 3 based on the
average CEMS data for 6 days of a week. In the case of the example, it is assumed that the
process operates for 24 hours per day, 48 weeks per year and that the CEMS data is
representative of annual operations.
E1
E2
E3
E
=
=
=
=
=
13.2 kg/hr
12.6 kg/hr
11.2 kg/hr
E4
E5
E6
=
=
=
12.2 kg/hr
14.0 kg/hr
13.4 kg/hr
[(13.2 x 24) + (12.6 x 24) + (11.2 x 24) + (12.2 x 24)+ (14 x 24) + (13.4 x 24)] x
48 (t)
88,243 kg/yr

Page 8 of 35
2.3.3 Emission factors

(a)
General
Emission factors can be used to estimate emissions to the environment. In this Note, they
relate the quantity of substances emitted from a source to some common activity
associated with those emissions. General emission factors have been developed from a
variety of sources, but this guidance draws upon UK information in particular.
Provided that unit operations remain consistent, representative monitoring data can be
used to generate site-specific emission factors. The emission factor will be the ratio of the
measured or calculated pollutant emission to the process activity (e.g. fuel flowrate). Sitespecific emission factors should be periodically verified to ensure their continued validity,
especially where fuel quality varies throughout the year. Where different fuels are used, the
emission when using each fuel separately should be determined, and the results added
together.
Where an emission factor or other RET is not available for a particular substance, then you
may review published information or use the emission factors listed in this Note. However,
care needs to be taken in selecting appropriate emission factors to ensure that the
conditions under which the emission factor has been determined are representative of the
sites operations.
Emission factors are usually expressed as the weight of a substance emitted multiplied by
the unit mass, volume, distance, or duration of the activity emitting the substance. In some
cases, and particularly in the case of SO2, the emission factor is based on fuel analysis
data (see Section 2.3.4).
Emission factors are used to estimate an activitys emissions by the general equation:
[A x Op hours] x EF
Where:
E
A
Op hours
EF
(4)

= activity rate of process (te/hr or m3/hr)
= operating hours per year of activity (hr/yr)
= controlled emission factor of pollutant per activity (kg/te or
kg/m3)
Within equation 4 it is important to note that EF is the emission factor for the pollutant released to
atmosphere, i.e. after the emission has been abated.
Depending on the availability of information, equation 4 can be rewritten as:
E
M x EF
Where:

E
M
EF
(5)
= activity rate in terms of mass of fuel burnt in the year (te/yr)
= controlled emission factor of pollutant per activity (kg/te dry fuel)
Page 9 of 35
The following example shows how to estimate annual emissions using equation 4.
Example 3
Estimating carbon monoxide (CO) emissions from light fuel oil combustion serves as an example
of the simplest use of emission factors. Consider an industrial boiler that burns 4,000 litres of oil
per hour and operates for 300 days per year. The CO emission factor given is assumed to be
0.6 kg of CO per 1000 litres of oil burned.
A
Op hours
EF
=
=
=
4,000 litres per hour (4 m3/hour)

24 hours per day, 300 days per year
0.6 kg/m3
=
=
4 x 24 x 300 x 0.6
17,280 kg/yr
Emission factors developed from measurements for a specific location can sometimes be
used to estimate emissions at other sites provided that the processes are comparable in
size and operation. As previously mentioned, it is advisable to have an emission factor
reviewed and approved by SEPA prior to its use for SPRI submissions.
In the case of new or modified processes, initial emission factors can be obtained from
manufacturers data with sampling undertaken during commissioning to confirm the
assumed values.
(b)
Carbon dioxide factors

The European Commission has established guidelines for the monitoring and reporting of
Green House Gasses pursuant to European Directive 2003/87/EC establishing the EU
ETS9. The European guidance sets out the approved methodology for estimating CO2
emissions based on emissions from regular operations and abnormal events, including
start-up and shut-down and emergency situations over the reporting period.
Under the EU ETS guidelines, the Commission has put monitoring and reporting into a
European level regulation, to bring harmonisation across Europe. The Monitoring and
Reporting Regulation (MRR) is defined within the Commission Regulation (EU) No.
601/2012 of 21 June 2012 on the monitoring and reporting of greenhouse gas emissions
pursuant to Directive 2003/87/EC of the European Parliament and of the Council.
Information and guidance of the change in reporting can
http://ec.europa.eu/clima/policies/ets/monitoring/documentation_en.htm
(c)
be
found:
Solid fuel combustion factors

(i)
Electricity supply industry (ESI)
The emission factors contained in this Section (and in d(i) and e(i)) represent currently
agreed factors for electricity generating stations. They have been developed from
measurements on large electricity generating stations (greater than 300 MW th) and are
http://www.sepa.org.uk/climate_change/solutions/eu_emissions_trading_system/monitoring_and_reporting.aspx

Page 10 of 35
regularly updated.
methodology.
Further detail on these emission factors is contained in the ESI
Also included in Table 2 are estimates of the amount of as received coal that would need
to be burnt in a year in order to exceed the reporting thresholds. A value for the tonnes of
coal that will need to be burnt for SO3 has not been provided, as it will be reported with SO2
(which is either normally estimated from CEMS or fuel analyses in accordance with Section
2.3.4). ESI plant burning less than the indicated tonnage of coal should therefore report
emissions as BRT for that particular pollutant provided that there are no other sources of
the pollutant on site.
Emissions of NOx from ESI coal-fired power plants that do not use CEMS for annual mass
emissions can be calculated from the fuel burn and NOx factors which have been agreed
with us on a station-specific basis.
Particulate matter concentrations are normally measured by CEMS for ESI plant. The
annual mass emission should be calculated from the instantaneous measured
concentration multiplied by the instantaneous volumetric emission, as in equation 1. Where
load and abatement performance is constant, the average concentration and flowrate can
be used (equation 2). For ESI plant it is generally assumed that each tonne of coal
generates 9,000 m3 of flue gas normalised at 6% oxygen concentration.
The SPRI return requires the total, PM10 and PM2.5 fractions of the particulate matter to be
reported. For ESI coal-fired plant, the PM10 and PM2.5 fractions are assumed to be 80%
and 40% respectively of the total particulate matter emitted. You can also use these factors
when burning peat or biomass.
Emissions of hydrogen chloride, chlorine and inorganic compounds as HCl and fluorine
and inorganic compounds as HF are normally estimated from fuel analysis, as shown in
Section 2.3.4.

Page 11 of 35
Table 2
UK ESI PI emission factors for large combustion plant
Pollutant Species
Emission factor (kg/tonne

as received coal burnt) for
pulverised coal plant with
or without FGD
Dioxins and furans (expressed as I1.5 x 10-11
++
TEQ)
Dioxins and furans (expressed as
1.6 x 10-11
WHOTEQ)++
PCB (expressed as WHOTEQ)
1.8 x 10-10
PCB (expressed as total mass)
9.9 x 10-8
Benzo(a)pyrene (BaP)
9.0 x 10-7
Anthracene
2.7 x 10-7
Benzo(b)fluoranthene
5.4 x 10-7
Benzo(g,h,i)perylene
5.4 x 10-7
Benzo(k)fluoranthene
5.4 x 10-7
Chrysene
3.6 x 10-7
Fluoranthene
4.5 x 10-7
Indeno(1,2,3-cd)pyrene
5.4 x 10-7
Naphthalene
4.9 x 10-5
Methane
Non-methane
compounds
volatile
organic
Carbon monoxide
SO3 (reported as part of sulphur oxides
SO2 and SO3 as SO2)
[te coal burnt for

above reporting
threshold]
[666,667]
[625,000]
[55,556]
[1,010,101]
[1,111,111]
[BRT]*
[1,851,852]
[1,851,852]
[1,851,852]
[BRT]*
[2,222,222]
[1,851,852]
[2,040,816]
1.4 x 10-2
[714,286]
2.7 x 10-2
[370,370]
1.1
6.3 x 10-2
[90,909]
-
Nitrous oxide
2.6 x 10-2
[384,615]
* - These emissions should always be reported as below the reporting threshold given the
required fuel burn.
++ - Where possible I-TEQ should be reported in preference to WHO-TEQ (although reporting of
both is acceptable).
Generic factors
In the absence of other information, generic emission factors based on currently achievable
emission rates from various combustion plants can be used. The generic emission factors in this
Section (and in d(ii) and e(ii)) have been taken from existing UK regulatory guidance for
combustion appliances10, 11, 12, 13 supplemented with Local Authority Guidance14, 15.
10
HMSO. Process Guidance Note IPC S3 1.01 Combustion processes Supplementary Guidance Note November 1995.
HMSO Process Guidance Note S2 1.01 Combustion processes: large boilers and furnaces 50MW(th) and over November 1995.
HMSO. Process Guidance Note S2 1.03 Combustion processes: gas turbines September 1995.
13
HMSO. Process Guidance Note IPR 1/2 Combustion processes: gas turbines September 1994.
14
Local Authority Unit. Assessment for second revision of PG1/4, Process Guidance Note for Part B. Gas turbines 20-50 MW rated
thermal input.
11
12
15
Local Authority Unit. Assessment for second revision of PG1/4, Process Guidance Note for Part B. Gas turbines 20-50 MW rated
thermal input.

Page 12 of 35
The existing UK regulatory guidance contains achievable emission data post-abatement in terms of
mg/MJ of net thermal input together with the equivalent normalised emission concentrations
(mg/m3). Therefore, if you know the normalised emission concentration of your combustion
appliance, you can calculate the equivalent emission factor in terms of mg/MJ and use equation 7
below. The relevant mg/MJ and mg/m3 values from the guidance are listed in Table 3, Table 5 and
Table 7 for each fuel category. The generic emission factors (EFi) for coal-firing are presented in
Table 3 below and are expressed in terms of the net heat input into the combustion appliance. In
order to calculate the annual emission for the SPRI return, a variant of equation 4 should be used:
E
Ae x EF x 10-6
Where:
E
Ae
EF
(7)
= emission of pollutant(kg/yr)
= annual energy consumption(MJ/yr)
= energy emission factor of pollutant (mg/MJ)
The emission factors also enable an estimate to be made of the size of combustion plant that
would need to be operated in order for the emission to be above the reporting threshold values.
These estimates are also included in Table 3 in terms of the average MWth net thermal input of the
plant, assuming that the combustion appliance operates for 100% of the year. If the combustion
plant operates for less than 100% of the year, the calculated MW th threshold can simply be divided
by the percentage operating time to provide the appropriate MW th threshold. For single
combustion appliances that are rated less than the indicated MW th threshold, a BRT return can be
made. However, if you have more than one combustion appliance on site, your aggregate
emission may be above the threshold value.
Table 3
Solid fuel-firing generic emission factors (net basis)
Technology
Emission
Particulate
NOx
factor
matter
mg/MJ mg/m3 mg/MJ
Stoker boiler, in-furnace
desulphurisation*
CFBC, in-bed
desulphurisation*
PFBC, in-bed
desulphurisation and
SNCR*
PF boiler, dry lime injection,

low-NOx burners**
PF boiler, wet limestone

scrubbing, low-NOx burners

EF
Threshold
BRT (W th)
EF
35
Threshold
for BRT
(MW th)
EF
35
Threshold
for BRT
(MW th)
EF
35
Threshold
for BRT
(MW th)
EF
35
25
105
CO
mg/m3
300
30
25
70
21
200
225
60
87
50
150
10
30
315
650
14
15
150
63
151
25
mg/m3
63
45
25
mg/M
J
50
35
100
91
250
35
100
Page 13 of 35
Technology
Emission
factor
and re-burn***
PF boiler, wet limestone

scrubbing, low-NOx burners
and SCR***
Boiler, 20-50MWth, stoker

firing****
Boiler, 20-50MWth, other

firing****
Particulate
matter
mg/MJ mg/m3
NOx
Threshold
for BRT
(MW th)
EF
63
36
Threshold
for BRT
(MW th)
EF
63
Threshold
for BRT
(MW th)
EF
Threshold
for BRT
(MW th)
108
108
15
mg/MJ
70
CO
mg/m3
mg/M
J
91
mg/m3
200
35
100
45
300
160
91
450
20
300
225
14
50
150
63
650
50
150
63
Note:
*- Use reference document 12.
** - Use reference document 13.
*** - Use reference document 11.
**** - Use reference document 15,
For coal-fired plants incorporating Selective Catalytic Reduction (SCR), an emission factor of 4
mg/MJ (10 mg/m3) for ammonia can be used.
Plant employing Selective Non-catalytic Reduction (SNCR) could also release ammonia and
nitrous oxide. In the absence of other information, emission factors for SNCR for ammonia and
nitrous oxide releases can be assumed to be 2 mg/MJ (5 mg/m3) and 21 mg/MJ (60 mg/m3)
respectively.
For unabated emissions of coal, peat or biomass powered plant the PM10 fraction can be
assumed to be 40% of the total particulate matter emitted, rising to 80% for plant with ESPs or bag
filters and dry FGD and 95% for plant with ESPs or bag filters and wet FGD.
(d)
Emission factors for liquid fuel combustion

(i)
Electricity Supply Industry (ESI)
In a similar manner to Section 2.3.3 c(i), the UK ESI emission factors are listed in Table 4
for heavy fuel oil-fired plant. Further detail on these emission factors is contained in the
ESI methodology.
Also included in Table 4 are estimates of the amount of oil that would need to be burnt in
order to exceed the reporting thresholds given the listed emission factors. A value for the
tonnes of oil that will need to be burnt for SO3 has not been provided, as it will be reported
with SO2. ESI plant burning less than the indicated tonnage of oil should therefore report

Page 14 of 35
emissions as BRT for that particular pollutant provided that there are no other sources of
the pollutant on site.
Table 4
Pollutant Species
Emission factor (kg/tonne [te oil burnt for above
oil burnt) for heavy oilthe reporting
fired plant
threshold]
-11
Dioxins and furans (expressed as I2.1 x 10
[497,512]
TEQ)++
2.1 x 10-11
[497,512]
++
WHOTEQ)
PCB (expressed as WHOTEQ)
2.4 x 10-10
[41,667]
-7
PCB (expressed as total mass)
1.3 x 10
[769,231]
-6
1.2 x 10
[833,333]
-7
Anthracene
3.6 x 10
[BRT]***
7.2 x 10-7
[1,388,889]
-7
7.2 x 10
[1,388,889]
-7
7.2 x 10
[1,388,889]
-7
Chrysene
4.8 x 10
[BRT]***
Fluoranthene
6.0 x 10-7
[1,666,667]
-7
7.2 x 10
[1,388,889]
-5
Naphthalene
6.5 x 10
[1,538,462]
-2
Methane
1.8 x 10
[555,556]
-2
Non-methane
volatile
organic
3.6 x 10
[277,778]
compounds
Carbon monoxide
1.5
[6,667]
-2
SO3 (reported as part of sulphur oxides
4.2 x 10 *
[-]
- SO2 and SO3 as SO2)
1.08**
[-]
-2
Nitrous oxide
3.5 x 10
[285,714]
Note:
* - for plant with Mg(OH)2 flue gas conditioning.
** - for plant without Mg(OH)2 flue gas conditioning.
*** - These emissions should always be reported as below the reporting threshold given the
required fuel burn.
++ - Where possible I-TEQ should be reported in preference to WHO-TEQ (although reporting of
both is acceptable).
Emissions of NOx from ESI oil-fired power plants that do not use CEMS for determining annual
mass emission can be calculated from the fuel burn and NOx factors that have been agreed with us
on a station-specific basis.
Particulate matter concentrations are normally measured by CEMS for ESI plant. The annual
mass emission should be calculated from the instantaneous measured concentration multiplied by
the instantaneous volumetric emission, as in equation 1. Where load is constant, the average
concentration and flowrate can be used (equation 2). For ESI plant it is generally assumed that
each tonne of oil generates 12,000m3 of flue gas normalised at 3% oxygen concentration.

Page 15 of 35
The SPRI return requires the total, PM10 and PM2.5 fractions of the particulate matter to be
reported. For ESI oil-fired plant, the PM10 and PM2.5.5 fractions are assumed to be 71% and 52%
respectively of the total particulate matter emitted.
(ii)
Generic factors
In a similar manner to Section 2.3.3 c(ii), and based on the same referenced information
sources, emission factors based on achievable emission rates from various liquid-fired
combustion plant can be used in equation 7. Relevant emission factors for liquid-fired plant
are given in Table 5 (in terms of net heat input), and the same methodology should be used
as that outlined in Section 2.3.3 c(ii).
Table 5
Liquid fuel-firing generic emission factors (net basis)
Technology
Gas turbine (after

1994)*
Gas turbine (pre1994)*
Boilers, 20-50MW,
L/M/H fuel oilfiring**
Boilers, 20-50MW,
distillate firing**
Compression ignition
engine, SCR***
Emission
factor
EF
Threshold
for BRT
(MW th)
EF
Threshold
for BRT
(MW th)
EF
Threshold
for BRT
(MW th)
EF
Threshold
for BRT
(MW th)
EF
Threshold
for BRT
(MW th)
Particulate
matter
mg/MJ mg/m3
0
0
-
NOx
30
140
100
38
450
55
12
42
150
75
200
42
150
58
50
8
84
25
100
40
63
165
125
125
75
150
25
mg/m3
60
mg/MJ
50
23
150
28
mg/m3
125
mg/MJ
105
42
CO
125
150
25
Note:
*- Use reference document 14.
** - Use reference document 15.
***- Use reference document 13.
For liquid fuel-fired plants incorporating SCR, an emission factor of 3 mg/MJ (10 mg/m 3) for
ammonia can be used.
For unabated emissions, the PM10 fraction can be assumed to be 45% of the total particulate
matter emitted, rising to 80% for plant with ESPs or bag filters and dry FGD and 90% for plant with
ESPs or bag filters and wet FGD.

Page 16 of 35
(e)
Emission factors for natural gas combustion

(i)
Electricity Supply Industry (ESI)
In a similar manner to Section 2.3.3 c(i), the UK ESI emission factors are listed in Table 6
for natural gas-fired plant. Further detail on these emission factors is contained in the ESI
methodology.
Also included in Table 6 are the approximate GJ of energy that would be required to
exceed the reporting thresholds given the listed emission factors and burning only natural
gas.
Table 6
Pollutant Species
Emission factor
[GJ of energy giving rise to
(g/GJ gas burnt) for
numerical reported value]
gas firing (based on
GCV)
Dioxins and furans (expressed as I0
[-]
TEQ)
0
[-]
WHO-TEQ)
PCB (expressed as WHO-TEQ)
0
[-]
0
[-]
Anthracene
0
[-]
0
[-]
0
[-]
0
[-]
Chrysene
0
[-]
Fluoranthene
0
[-]
0
[-]
Naphthalene
0
[-]
Methane
3.7
[2,702,700]
Non-methane volatile organic
0.9
[11,111,000]
compounds
Carbon monoxide
13
[7,692,300]
SO3 (reported as part of sulphur
0
[-]
oxides - SO2 and SO3 as SO2)
Nitrous oxide
0.5
[20,000,000]
NOx emissions from CCGT and gas-fired plant are generally calculated from continuous monitors.
For the combustion of natural gas, the ESI PI methodology advises a revised emission factor of
0.80 g/GJ (GCV) or 0.89 g/GJ (NCV) for particulate matter from gas turbine plant.
For gas turbines running on distillate fuel, for example during start-up, the emission factors given in
Table 5 can be used, and 100% of the particulate matter emission assumed to be PM10 and 50%
PM2.5. Note that from 2009, the ESI proposes that they will assume that 100% of particulate matter
is PM2.5, as a conservative estimate.
(ii)
Generic factors
In a similar manner to Section 2.3.3 c(ii), and based on the same referenced information
sources, emission factors based on achievable emission rates from various natural gas-

Page 17 of 35
fired combustion plant can be used in equation 7. Relevant emission factors for natural
gas-fired plant are given in Table 7 (in terms of net heat input), and the same methodology
should be used as that outlined in Section 2.3.3 c(ii). Note that the emission factors are
based on net calorific values (NCV).
Table 7
Natural gas fuel-firing generic emission factors (net basis)
Technology
Emission
factor
Particulate
matter
mg/MJ
Gas turbine, after 1994*
EFi (mg/MJ)
Threshold
for
BRT
(MW th)
Gas turbine, pre-1994*
EFi (mg/MJ)
EFi (mg/MJ)
Dual fuel compression

ignition engine,
SCR***
EFi (mg/MJ)
Dual fuel compression

ignition engine, lean
burn***
EFi (mg/MJ)
Spark ignition engine,

SCR***
EFi (mg/MJ)
Spark ignition engine,

lean burn, exhaust gas
recirculation (EGR)***
EFi (mg/MJ)
Note:
*
**
***
mg/MJ
105
15
20
Threshold
for
BRT
(MW th)
100
30
100
106
100
125
375
125
100
125
125
150
25
150
25
150
25
37
450
9
150
85
84
25
60
37
21
38
140
85
21
Threshold
for
BRT
(MW th)
50
81
20
mg/m
63
125
39
317
Threshold
for
BRT
(MW th)
mg/MJ
30
15
60
63
CO
mg/m
50
Threshold
for
BRT
(MW th)
Threshold
for
BRT
(MW th)
Threshold
for
BRT
(MW th)
Boilers, 20-50MW, Flue
gas recirculation (FGR)**
mg/m
NOx
125
150
25
Use reference document 14.

For both compression ignition engines and spark ignition engines, a factor of 170 mg/MJ (200
mg/m3) can be used for NMVOCs. For natural gas-fired plants incorporating SCR, an emission
factor of 8 mg/MJ (10 mg/m3) for ammonia can be used.
Apart from mercury, trace metallic elements in natural gas are assumed to be zero. For mercury,
an emission factor of 1 x 10-4 mg/m3 of gas burnt can be used to calculate mercury vapour
emissions. In this case, greater than 1 x 1010 m3 of gas would need to be burnt in a year to exceed
the reporting threshold.

Page 18 of 35
The PM10 and PM2.5 fractions can be assumed to be 100% of the total particulate matter emitted
when burning natural gas.
2.3.4 Fuel analysis data

(a)
General
The use of fuel analysis data to determine emissions is similar to the use of emission
factors.
The basic equation used in fuel analysis emission calculations is:
Qf x [Op hours] x [PCf/100] x (MWp / EWf)
Where:
(8)
E
Qf
PCf
Op hours
= emission of pollutant (kg/yr)

= fuel use (kg/hr)
= pollutant concentration in the fuel (%)
= operating hours per year (hr/yr)
MW p
EW f
= molecular weight of pollutant as emitted after combustion

= elemental weight of pollutant as present in fuel
Equation 8 is the method usually used for calculating SO2 emissions where it is normally
assumed that all of the sulphur in the fuel is converted to SO2. However, when using the
equation for coal-fired plant, it is assumed that 5% of the sulphur is retained in the ash.
Where the pollutant concentration in the fuel is consistent over the averaging period (i.e.
one year), equation 8 can be written as:
E
M x [PCf/100] x (MWp / EWf)
Where:

E
M
PCf
MW p
EW f
(9)
= emission rate of pollutant in (kg/yr)

= mass of fuel burnt in one year (kg/yr)
= pollutant concentration in the fuel (%)
= molecular weight of pollutant as emitted after combustion
= elemental weight of pollutant as present in fuel
Page 19 of 35
Example 4
This example shows how SO2 emissions can be calculated from oil combustion, based
on fuel analysis results and fuel flow information. It is assumed that the facility operates using oil
for 150 hours per year and that abatement of SO2 does not occur.
Qf
PCf
MWp
EWf
Op hours
=
=
=
=
=
2000 kg/hr
1.17%
64
32
150 hr/yr
=
=
=
Qf x PCf x (MWp / EWf) x [Op hours]

[(2000) x (1.17 / 100) x (64/32) x 150] kg/yr
7.0 x 103 kg/year
Equation 8 can also be used for volatile elements such as fluorine and chlorine as well as
trace metallic pollutants, although some of these species are retained in the plant, either in
the ash or in abatement equipment (see below).
When using equations 8 or 9, you should be aware that the amount of pollutants present in
the fuel can vary significantly. For UK ESI plant, the trace element concentration in the coal
is calculated as a yearly weighted mean average for each plant, based on the delivered
tonnage of coal. Where coals have not been analysed for trace element content, then you
should use an average value for coals from a similar geographic region.
(b)
Solid fuel analysis

For elements that are effectively captured in either bottom ash or fly ash, equation 8 can
result in the overestimation of emissions. In addition, emission quantities of volatile and
semi-volatile components will greatly depend on the emission temperature and abatement
collection efficiency as volatile and semi-volatile substances can condense on fine
particulate matter. Increasing the emission temperature may significantly increase the
pollutant release rate of volatile components. Any changes to the process conditions that
may affect pollutant partitioning or capture should be taken into account in emission
calculations by the determination of site-specific retention and enrichment factors (see
below).
Mass emissions of trace metallic elements from coal combustion can be calculated
indirectly from the amount of particulate matter emitted, corrected by factors representing
the concentration of the trace element in the coal and how much of the element is
chemically present in the ash, using the following equations. The total emission is the sum
of the emission from the non-volatile and volatile phases:
Non-volatile phase:
Env
PCcoal x (100 / AA) x F x R x PM

(10)
Page 20 of 35
Volatile phase:
Ev
PCcoal x (1 F) x CB
Where:
Env
Ev
PCcoal
AA
F
R
PM
CB
(11)
= non-volatile pollutant emission (kg/yr)

= volatile pollutant emission (kg/yr)
= trace element weight fraction in the coal
= average ash mass percentage in coal (%)
= retention factor in ash (-)
= enrichment factor (-)
= particulate matter emission (kg/yr)
= coal burned (kg/yr)
Common enrichment and retention factors that are used across UK coal-fired ESI plant are
tabulated in Table 8. These factors are appropriate for exhaust gas temperatures of less
than approximately 130oC. For higher exhaust gas temperatures the factors may differ,
especially for the more volatile elements, and you should therefore use site-specific factors.
The use of Flue Gas Desulphurisation (FGD) will lead to the retention of sulphur from the
emission, but it will also lead to the retention of soluble acid halides such as HCl and HF.
In the absence of site specific data for FGD, retention factors for HCl and HF should be
taken as 98% and 72% respectively. The additional factors given in Table 8 for FGD are
for wet limestone/gypsum systems.
Table 8
2009 UK ESI PI coal combustion factors
Pollutant Element
Arsenic
Selenium
Lead
Antimony
Nickel
Chromium
Copper
Manganese
Vanadium
Zinc
Cadmium
Mercury
Retention factor
(F)
1
0.8
1
1
1
1
1
1
1
1
1
0.5
Enrichment factor
(R)
3.4
9.0
2.9
3.6
1.9
1.7
2.0
1.7
1.4
4
4.5
4.0
FGD retention
factor (vapour)
0.65
0.5
In order to use equations 10 and 11, it is necessary to know the composition of the coal in
terms of the percentage of trace metallic elements present. As coal composition can vary
significantly depending on the source of the fuel, you should obtain information on the trace
elements from the supplier, or have specific coal analysis carried out.
Fuel composition should also be taken into account in determining pollutant emissions from
subsidiary or substitute fuels. In the absence of other data, for fuels such as biomass that
have a low ash content, the enrichment and retention factors given above can be used.

Page 21 of 35
(c)
Liquid fuel analysis

Equation 11 can be used to calculate trace metallic emissions from oil-fired plant. As a
generality within the ESI methodology it is assumed that for large, heavy fuel oil plant with
particulate or grit arrestors a retention factor of 0.75 can be used for trace elements.
Appropriate retention factors should be determined for other abatement plant. In the
absence of abatement, the retention factor would be zero.
As with coal, information on the composition of the trace elements in the fuel should be
obtained from the supplier or be measured.
Emissions of halogens from oil-fired plant can be assumed to be zero.
(d)
Natural gas analysis

As indicated in Section 2.3.3 e(ii), apart from mercury, natural gas supplies in the UK are
currently assumed to have zero trace metal content. Emissions of halogens from natural
gas-fired plant are also assumed to be zero.
Where no specific gas analysis is available and in order to calculate emissions from gas
venting, natural gas should be assumed to comprise 1% CO2, 1% nitrogen, 92% CH4 and
6% NMVOCs.
2.3.5 Fugitive emissions

For solid fuel plant, particulate matter emissions can occur by dust blown from coal stocks and ash
storage areas. However, these can be assumed to be low in comparison to stack emissions
unless specific events have occurred which are known to have released significant quantities of
material off-site.
Techniques for estimating fugitive emissions from the surface of stockpiles are limited. Options
include measuring ambient dust levels upwind and downwind of the source of interest and/or
applying predictive mathematical models.
CH4 and other hydrocarbon emissions from coal stocks and oil tank filling can be assumed to be
small in relation to emissions through the stacks. For natural gas-fired plant, where gas is vented
to atmosphere for operational and maintenance purposes, the mass emissions of CO2, CH4 and
NMVOCs should be calculated from the gas composition.
2.4
Certain substances on the SPRI return are required to be reported as the main constituent, e.g.
Nitrogen oxides, NO and NO2 as NO2.
When a conversion needs to be made, the emission
concentration or emission rate should be multiplied by the molecular weight of the reported as
substance, and divided by the molecular weight of the emitted substance. This is illustrated in the
following example.

Page 22 of 35
Example 5
Assume a discharge concentration of NO is 50 mg/m3. Using the molecular weights of NO and
NO2, the equivalent discharge concentration of NO2 can be determined.
MW of NO
MW of NO2
=
=
30
46
Concentration of NO as
NO2
50 x 46 / 30
76.7 mg/m3
The mass of NO2 released can then be determined in accordance with equation 1.
Further guidance on reporting emissions, including dioxin and other organic substance congeners
is given in the General SPRI guidance document.

Page 23 of 35
Emissions to water and waste water
Emissions of substances to water can be either direct to controlled waters or indirect, following
transfer to off-site effluent treatment plant.
If your wastewater is treated by an Independently-operated Wastewater Treatment Plant
(IOWWTP) covered by Section 5 of the Pollution Prevention and Control (Scotland) Regulations,
then this waste stream should be recorded as a transfer in tonnes/year within Section D Waste
Transfers. Any transfers of liquid waste from the SPRI-reporting site by road tanker or other liquid
container should also be reported within Section D Waste Transfers.
Guidance on what constitutes an emission or a transfer is contained in the General SPRI Guidance
document3.
3.1
Relevant pollutants
A variety of substances need to be considered when reporting emissions to water or transfers in

wastewater to sewer. The main ones are illustrated in Table 9. The table should be taken as a
guide only, and you should verify that there are no other pollutants emitted from the process. The
significance of each parameter depends on the specific plant configuration and the process
applied, which also determines the type and amount of pollutant present in the wastewater prior to
treatment.
Table 9
Guide on main reportable substances likely to be emitted to water
Substance
Substance
Arsenic
Zinc
Cadmium
Iron
Chromium (Cr III and Cr VI)
Ammonia
Copper
Nitrogen (total as N)
Lead
Phosphorus (total as P)
Mercury
Chlorides
Nickel
Fluorides
3.2
Emission sources
Emissions to water generally arise from the following sources:

Cooling water system;
Demineralised water treatment plant;
Boiler blow down;
FGD wastewater treatment plant;
Ash transport wastewater;
Surface water run-off from storage areas (e.g. fuel, ash, FGD material);
Cleaning water.
Notwithstanding the above, you should consider all emission sources to water and characterise the
flows and emission concentrations from each source.
3.3
There is less choice in the techniques to use for the determination of emissions to water than for
emissions to air. The most appropriate method is to use direct measurement. However, you may

Page 24 of 35
use other RETs, particularly mass balances or site-specific emission factors where these are
appropriate. Mass balances can often be used when emissions to water are very complex and
difficult to quantify with other approaches. However, a mass balance calculation is still likely to
require direct measurement of emissions from some of the water pathways in order to verify the
calculations. Site-specific emission factors are determined from the ratio of the measured or
calculated pollutant emission to the water discharge flow rate.
Within this Note, advice is given on the use of direct measurement techniques as these are likely to
be applicable to the majority of Operators.
Using the direct measurement technique requires information on both the flow rate and pollutant
concentration. Measurement of flows and pollutant concentrations should be undertaken at the
same time during representative operating conditions. Particular care should be taken when
relying on the results of one spot sample in order to report annual emissions unless you can be
certain that the process conditions are representative. Where a process has a number of
operating conditions, it may be necessary to take samples at each condition and average the result
according to the length of time the process operates at each condition. Similarly, where process
conditions at the time of the spot sampling are uncertain, then it may be necessary to take several
samples and the results averaged in order to provide the final annual emission estimate.
The frequency of sampling will depend on the variability of the data. Initially, it may be necessary
to take several samples and average the results to yield an annual result. If, however, the results
indicate that a concentration and flow are reasonably constant, then the frequency of sampling
may be reduced to a practical minimum of once per year. You should be able to justify the
sampling regime selected and this should be supported by a history of previous measurements.
The background load of a reportable substance in water may be taken into account. For example,
if water is collected at the site of the installation from a neighbouring river, lake or sea for use as
process or cooling water which is afterwards released from the site of the facility into the same
river, lake or sea, the release caused by the background load of that substance can be
subtracted from the total release of the installation. The measurements of pollutants in collected
inlet water and in released outlet water must be carried out in a way that ensures that they are
representative of the conditions occurring over the reporting period. If the additional load results
from the use of extracted groundwater or drinking-water, it should not be subtracted since it
increases the load of the pollutant in the river, lake or sea.
It may also be necessary to take account of the fact that evaporation of water from the process will
lead to an increase in the pollutant concentration. This can be done by using the following
equation:
PC
(OC [IC x VF])
Where:
PC
OC
IC
VF
(12)
= the pollutant emission concentration due to the process (mg/l)

= the measured pollutant concentration in the discharge (mg/l)
= the measured pollutant concentration in the feed water (mg/l)
= the ratio of volume of water extracted to volume of water discharged
In order to estimate the mass emission to water, the appropriate pollutant concentration is then
multiplied by the flow rate for that particular discharge point. These representative discharge rates
are then aggregated together based on the time for which the water is discharged at that rate.
For emission points fitted with continuous monitors, calculations of mass emissions from a
particular discharge point can be made automatically. However, for cooling water it may also be

Page 25 of 35
necessary to adjust the measured data to take account of input pollutant concentrations as
described above, and it is good practice to manually check automatic calculations to ensure that
they are accurate.
Example 6 below shows how to estimate annual mass flow of a substance from cooling water
discharges taking into account water evaporation in the plant.
Example 6
Suppose the chromium discharge concentration [OCcr] and annual volume flows from three
separate discharge points are found to be:
[OCcr]1
[OCcr]2
[OCcr]3
=
=
=
2.2 x 10-3 mg/m3

1.2 x 10-3 mg/m3
4.5 x 10-3 mg/m3
V1
V2
V3
=
=
=
4.2 x 106 m3
36 x 106 m3
21 x 106 m3
Chromium inlet concentration [ICcr]

=
0.12 x 10-3 mg/m3
Volume of water extracted during testing =
15,000 m3
period
Volume of water discharged during testing =
14,300 m3
period
The volume factor
=
15,000/14,300 = 1.05
From equation 12 above, the following average process concentrations are therefore:
[PC] 1
{2.2 x 10-3 [0.12 x 10-3 x 1.05]} = 2.07 x 10-3 mg/m3
[PC]2
{1.2 x 10-3 [0.12 x 10-3 x 1.05]} = 1.07 x 10-3 mg/m3
[PC]3
{4.5 x 10-3 [0.12 x 10-3 x 1.05]} = 4.37 x 10-3 mg/m3
Total annual chromium mass emission = {[PC]1 x V1} + {[PC]2 x V2} + {[PC]3 x V3}
= {2.07 x 10-3 x 4.2 x 106} + {1.07 x 10-3 x 36 x 106} + {4.37 x 10-3 x 21 x 106} mg
= 139g which is below the reporting threshold
3.4
Certain substances on the SPRI return are required to be reported as the main constituent, e.g.
Chlorides total as Cl. For instances when a conversion needs to be made, the emission
concentration should be multiplied by the molecular weight of the main constituent and divided by
the total molecular weight of the substance. This is illustrated in the following example.
Further guidance on reporting emissions of specific compounds is given in the General SPRI
Guidance document.

Page 26 of 35
Example 7
Let the measured concentration of sodium chloride be 50 mg/l and the total volume released is
1,000 m3.
Relative Atomic Mass of
sodium
Relative Atomic Mass of
chlorine
Molecular Weight of sodium
chloride
23
35
58
Concentration of sodium chloride as

chloride
50 x 35 / 58
30.2 mg/l = 30.2 g/m3
The mass of chloride released is (30.2 x 10-3) x 1000 = 30.2 kg which is below the reporting
threshold.
3.5
If no emission factors or other RETs are available
If an emission factor or other release estimation technique is not available then you should contact
SEPA.
3.6
Units
In completing the SPRI return, care should be taken with the units of the substances reported. A
checklist of unit prefixes is included in Appendix B to aid in this process.

Page 27 of 35
Off-site waste transfers
In this section you are asked to report waste or tankered liquid waste removed from the site. All
sites are likely to produce some waste and should address this issue.
You are required to report waste transfers from your site where the reporting thresholds of 2
tonnes/yr for hazardous waste and/or 2,000 tonnes/yr for non-hazardous waste are exceeded.
Any transfer of waste off-site to a third party is covered by the Duty of Care provisions of the
Environmental Protection Act 1990. This includes the requirement to describe the waste and
record the quantity. You should therefore use data generated in compliance with Duty of Care
requirements to complete the SPRI return.
If tankered waste is to be further processed, such as, dewatering of oily waste by a specialist
waste contractor, it should be recorded within this Section. However, where tankered waste is
destined to be treated at an Urban Waste Water Treatment Plant (UWWTP) outwith your site it
should be recorded with Section C Waste Water
4.1
Relevant wastes
Typical wastes and by-products generated in this sector are:

Bottom ash and/or boiler slag;
Fly-ash;
Fluidised bed ash;
Flue gas desulphurisation residues and by-products;
Special wastes (e.g. solvents);
Metallic wastes;
Chemical wastes;
Waste oils;
General waste.
4.2
Transboundary shipments of hazardous waste
For transboundary movements of hazardous waste (outwith the United Kingdom), the name and
address of the recoverer or the disposer of the waste and the actual recovery or disposal site have
to be reported

Page 28 of 35
References and further information

1.
Scottish Pollutant Release Inventory website.

http://www.sepa.org.uk/air/process_industry_regulation/pollutant_release_invento
ry.aspx
2.
The Pollution Prevention and Control (Scotland) Regulations 2000 (as amended)
SSI 2000 No. 323.
http://www.legislation.gov.uk/ssi/2000/323/contents/made
3.
SPRI General Guidance Note.

ry/operator_guidance.aspx
4.
European Pollutant Release and Transfer Register (E-PRTR) website.

http://prtr.ec.europa.eu/
5.
Directive 2001/80/EC of the European Parliament and of the Council of 23

October 2001. Limitation of emissions of certain pollutants into the air from large
combustion plants.
http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2001:309:0001:0001:EN:PDF
EU ETS Directive
http://ec.europa.eu/clima/policies/ets/index_en.htm
6.
7.
Joint Environment Programme. Electricity Supply Industrys Pollution Inventory

Methodology, 2009 (Revised February 2012, next revision due Spring 2012).
Available from: The Library, Power Technology, Ratcliffe on Soar Power Station,
Ratcliffe on Soar, Nottingham NG11 OEE.
8.
SPRI Guidance Note on Release Estimation Techniques (RET).

ry/operator_guidance.aspx
9.
EU ETS Monitoring and Reporting Guidelines.

http://www.sepa.org.uk/climate_change/solutions/eu_emissions_trading_system/
monitoring_and_reporting.aspx
10.
EU ETS Country Specific Factors.

http://www.decc.gov.uk/en/content/cms/what_we_do/change_energy/tackling_cli
ma/emissions/eu_ets/euets_phase_ii/monitoring/monitoring.aspx
11.
HMSO. Process Guidance IPC S3 1.01 Combustion processes Supplementary

Guidance Note, November 1995 ISBN 0-11-310183.
12.
HMSO. Process Guidance Note S2 1.01 Combustion processes: large boilers

and furnaces 50MW(th) and over, November 1995 ISBN 0-11-753206-1.
13.
HMSO. Process Guidance Note S2 1.03 Combustion processes: gas turbines,

September 1995 ISBN 0-11-753166-9.
14.
HMSO. Process Guidance Note IPR 1/2 Combustion processes: gas turbines,
September 1994 ISBN 0-11-752954-0.

Page 29 of 35
15.
16.

Local Authority Unit. Assessment for second revision of PG1/3, Process

Guidance Note for Part B. Boilers and furnaces with a net rated thermal input of
20 50 MWth.
http://www.defra.gov.uk/publications/files/env-permitting-general-guidance-b.pdf
Local Authority Unit. Assessment for second revision of PG1/4, Process
Guidance Note for Part B. Gas turbines 20 50 MWth rated thermal input.
http://archive.defra.gov.uk/environment/quality/pollution/ppc/localauth/pubs/guida
nce/notes/pgnotes/documents/PG1_04.pdf
Page 30 of 35
Appendix A Normalisation of emission concentrations

In many cases, pollutant emission concentrations to air are reported as normalised concentrations,
the actual measured emission concentration having been adjusted to a normalised temperature
(273K), oxygen, pressure and/or water vapour concentration. In calculating mass emissions to air,
it is important that either the actual release concentration is multiplied by the actual volumetric flow
rate, or the normalised concentration is multiplied by the normalised volumetric flow rate. In many
cases, emission concentrations and volumetric flow rate are quoted in different ways, and you
should ensure that the measurements are multiplied together on a consistent basis.
The following equations can be used to correct measured concentrations and flow rate for
temperature, oxygen, pressure and water vapour content. It should be noted that the equations for
correcting concentrations and volumetric flow rate are simple inversions of each other.
Concentrations
To correct for moisture concentration to dry (0% oxygen)
Cd = Cm x (100/(100 -%H20))
Where
Cd is the dry concentration

Cm is the measured concentration
%H20 is the measured water vapour percentage
To correct the % oxygen to dry basis (if required may already be measured dry)
O2(dry) = O2m x (100/(100 -%H20))
Where
O2(dry) is the dry oxygen percentage

O2m is the measured oxygen percentage
To correct to normalised oxygen concentration

Ccorr = Cd x (20.9 - O2norm)/(20.9 - O2(dry))
Where
Ccorr is the corrected concentration for oxygen concentration

O2norm is the stated normalised oxygen percentage
To correct for temperature

CnormT = Ccorr x ((273 + Tm)/273)
Where
CnormT is the normalised concentration for temperature

Tm is the measured temperature in degrees centigrade
To correct for pressure

Cnorm = CnormT x (101.3/Pm)
Where
Cnorm is the normalised concentration

Pm is the measured pressure in kPa

Page 31 of 35
Volumetric flow rates

To correct for moisture concentration to dry (0% oxygen)
Qd = Qm x ((100 -%H20))/100)
Where
Qd is the dry volumetric flowrate

Qm is the measured volumetric flowrate
%H20 is the measured water vapour percentage
To correct the % oxygen to dry basis (if required may already be measured dry)
O2(dry) = O2m x (100/(100 -%H20))
Where
O2(dry) is the dry oxygen percentage

O2m is the measured oxygen percentage
To correct to normalised oxygen concentration

Qcorr = Qd x (20.9 - O2(dry))/(20.9 - O2norm)
Where
Qcorr is the corrected volumetric flowrate for oxygen concentration

O2norm is the stated normalised oxygen percentage
To correct for temperature

QnormT = Qcorr x (273/(273+ Tm))
Where
QnormT is the normalised volumetric flowrate for temperature

Tm is the measured temperature in degrees centigrade
To correct for pressure

Cnorm = CnormT x (Pm /101.3)
Where
Cnorm is the normalised volumetric flowrate

Pm is the measured pressure in kPa

Page 32 of 35
Appendix B Conversion factors

ppm to mg/m3 air
The conversion between ppm and mg/m3 is dependent on both the molecular weight of the
substance and the temperature at which the conversion is made. The assumption is that the
pollutant behaves as an ideal gas and as such, 1 mole of the substance occupies 22.4 litres at
standard temperature (273K) and pressure (101.3 kPa). This is consistent with normalised
concentrations, and it is therefore not normally necessary to take account of the temperature or
pressure difference in the conversion. However, when converting ppm to mg/m 3 at actual
discharge conditions, it is important to take account of the necessary factors.
To convert from ppm to mg/m3, the following formula should be used:
mg/m3 = ppm x (MW/22.4) x (273/T) x (P/101.3)
Where
MW is the molecular weight of the substance (in grams)

T is the temperature at which the conversion is to be made (degrees Kelvin)
P is the pressure at which the conversion is to be made (kPa)
To convert from mg/m3 to ppm, the following formulae should be used:

ppm = mg/m3 x (22.4/MW) x (T/273) x (101.3/P)
ppm to mg/l Water
The conversion between ppm and mg/l for water is straightforward in that it is normally assumed
that water has a density of 1000 kg/m3. On this basis, 1 ppm = 1 mg/l = 1 g/m3 = 1 mg/kg.
Metric prefixes
The following prefixes are given for the metric system as an easy reference guide.
Factor by which unit is
multiplied
24
10
21
10
18
10
15
10
12
10
9
10
6
10
3
10
2
10
10
-1
10
-2
10
-3
10
-6
10
-9
10
-12
10
-15
10
Prefix
Symbol
yotta
zetta
exa
peta
tera
giga
mega
kilo
hecto
deca
deci
centi
milli
micro
nano
pico
femto
Y
Z
E
P
T
G
M
k
h
da
d
c
m
n
p
f
10-18
10-21
10-24
atto
zepto
yocto
a
z
y

Page 33 of 35
Appendix C Glossary
BaP
BAT
BRT
CEMS
CCGT
CH4
CHP
CF
CO
CO2
COD
Cr
D&R
EU ETS
EF
EGR
ELV
E-PRTR
ESI
ESP
ETP
EWC
FGD
FGR
GCV
GHG
HCl
HF
HFO
H2S
IOWWTP
IPC
IPPC
I-TEQ
JEP
LCPD
LOD
Mg(OH)2
MCERTS
NCV
NOx
N2O
NMVOCs
PAHs
PCBs
PCDDs
PCDFs
PF
PFBC
PM
PM10
PM2.5
Benzo(a)pyrene
Best Available Techniques
Below Reporting Threshold
Continuous Emission Monitoring System
Combined Cycle Gas Turbine
Methane
Combined Heat and Power
Conversion Factor
Carbon Monoxide
Carbon Dioxide
Chemical Oxygen Demand
Chromium
Disposal and Recovery
European Union Emissions Trading System
Emission Factor
Exhaust Gas Recirculation
Emission Limit Value
European Pollutant Release and Transfer Register
Electricity Supply Industry
Electrostatic Precipitator
Effluent Treatment Plant
European Waste Catalogue
Flue Gas Desulphurisation
Flue Gas Recirculation
Gross Calorific Value
Greenhouse Gas
Hydrogen Chloride
Hydrogen Fluoride
Heavy Fuel Oil
Hydrogen Sulphide
Independently-operated Wastewater Treatment Plant
Integrated Pollution Control
Integrated Pollution Prevention and Control
International Toxicity Equivalents of Dioxins
Joint Environment Programme
Large Combustion Plant Directive
Limit of Detection
Magnesium Hydroxide
(Environment Agencys) Monitoring Certification Scheme
Net Calorific Value
Oxides of nitrogen (mixture of NO and NO2)
Nitrous Oxide
Non-methane Volatile Organic Compounds
Polycyclic Aromatic Hydrocarbons
Polychlorinated Biphenyls
Polychlorinated Dibenzodioxins
Polychlorinated Dibenzofurans
Pulverised Fuel
Pulverised Fuel Bed Combustion
Particulate Matter
Particulate Matter (< 10 m aerodynamic diameter)
Particulate Matter (< 2.5 m aerodynamic diameter)
Page 34 of 35
PPC
ppm
RET
SCR
SNCR
SOx
SO2
SO3
SPRI
TOC
TPM
UNECE
UWWTD
USEPA
VOCs
WHO
WHO-TEQ
WID

Pollution Prevention and Control (Scotland) Regulations 2000

(as amended)
Parts per million
Release Estimation Technique
Selective Catalytic Reduction
Selective Non-catalytic Reduction
Oxides of Sulphur (mixture of SO2 and SO3)
Sulphur Dioxide
Sulphur Trioxide
Scottish Pollutant Release Inventory
Total Organic Carbon
Total Particulate Matter
United Nations Economic Commission for Europe
Urban Wastewater Treatment Directive
United States Environmental Protection Agency
Volatile Organic Compounds
World Health Organisation
WHO Toxicity of Dioxins
Waste Incineration Directive
Page 35 of 35

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