When emission measurement is usually addressed
Emission measurement for stationary air pollution sources is addressed mainly when it follows from the law, implementing decree, operating permit, or a requirement of the competent authority.
This typically concerns boiler plants, paint shops, combustion sources, dryers, technological exhausts, filtration equipment, melting and heating equipment, chemical technologies, plastics processing, wood-processing operations, or other industrial sources with air emissions.
However, not every situation automatically means that measurement must be carried out immediately. It may be more appropriate first to review the operating permit, technical parameters of the source, source classification under the Air Protection Act, and conditions set by the authority.
When one-off emission measurement is needed
One-off emission measurement is usually needed in the following cases:
- after first putting a stationary source into operation,
- after a change of fuel, raw material, or thermally treated waste stated in the operating permit,
- after intervention in the construction or equipment of the source that may affect emissions,
- at regular intervals set by legislation or the operating permit,
- on the basis of a requirement from the Czech Environmental Inspectorate (CEI), regional authority, or other competent body,
- when verifying compliance with emission limits,
- when documenting operating conditions after installation of new technology or filtration equipment.
For some sources, measurement is a one-off obligation after putting into operation or after a technology change. For other sources measurement is repeated regularly, for example at annual or multi-year intervals depending on source type and legal or operating permit requirements.
One-off emission measurement and periodic emission measurement
In practice two terms are often used: one-off measurement and periodic measurement. These are not two completely different types of technical activity, but rather a difference in reason and repetition of measurement.
| Type of measurement | When it is addressed | Typical purpose |
|---|---|---|
| First one-off measurement | After putting the source into operation or after a significant technology change | Verification that the new or changed source meets emission limits and operating conditions |
| Periodic measurement | At regular intervals set by regulation or operating permit | Regular demonstration of compliance with emission limits |
| Control measurement | During inspection, complaint, suspicion of non-compliance, or at request of the air protection authority | Verification of actual state of operation and emissions |
| Technical or indicative verification | Before technology adjustment, after tuning, or for internal control | Auxiliary supporting document for the operator; may not replace authorised measurement |
The operator should therefore address not only the question "measure or not measure", but mainly the question for what purpose the output is to serve. Authorised measurement for fulfilling a legal obligation has a different regime from technical verification for the operator's internal needs.
When another supporting document may be sufficient instead of measurement
In some situations the first step need not be emission measurement itself. It may be more appropriate first to prepare or review another expert supporting document.
This may typically involve:
- review of the operating permit,
- expert assessment of whether the source is subject to a measurement obligation,
- expert opinion under the Air Protection Act,
- dispersion study,
- emission balance,
- volatile organic compound balance,
- operating rules,
- update of operating records,
- technical assessment of the measuring location,
- evaluation of the authority requirement.
| Situation | What is usually advisable to check |
|---|---|
| New source or technology change | Operating permit, source classification, need for expert opinion, dispersion study, and subsequent measurement |
| Older operating permit | Whether it matches the current state of technology and present legal requirements |
| Change of fuel or raw material | Whether the change triggers a measurement obligation or change of operating permit |
| Unclear authority requirement | What specific output the authority requires and for which proceeding it is to serve |
| Backup energy source | Whether conditions are met for another method of determining pollution level |
| Missing measuring location | Whether measurement can be carried out representatively and safely, or how to adjust the measuring location |
Measurement itself makes sense when it is clear what is to be measured, on which source, under what operating regime, at which exhaust, and for what purpose. If these data are unclear, it is advisable first to carry out expert assessment of supporting materials.
Role of the Czech Environmental Inspectorate
The Czech Environmental Inspectorate may verify compliance with emission limits and operating conditions during inspection activities. At the same time, inspection activity does not replace the operator's obligations.
The operator must themselves monitor whether they have a valid operating permit, whether they meet set emission limits, whether they carry out measurement within required deadlines, and whether they have the relevant reports and operating records available.
From a practical perspective it is important that the operator does not wait until an inspection. If it is uncertain whether measurement is mandatory, it is advisable to verify the situation in advance according to the operating permit, source classification, and current state of technology.
Notification of the measurement date
For measurement that is to serve as statutory one-off emission measurement, timely notification of the measurement date is important. If the date is not properly notified, a problem may arise with recognition of the measurement for fulfilling the legal obligation.
In practice the measurement date must therefore be arranged with sufficient lead time. The operator should count not only on the measurement itself, but also on preparation of technology, ensuring the operating regime, access to the measuring location, and submission of necessary supporting materials.
If the measurement date changes or is cancelled, the change must be notified in time and in the correct manner.
What the operator should prepare before measurement
Good preparation significantly reduces the risk that measurement cannot be carried out or that the result will not be usable for the given purpose.
Before measurement it is advisable to prepare mainly the following supporting materials:
| Supporting material | Why it matters |
|---|---|
| Operating permit | Sets operating conditions, emission limits, substances measured, and possibly measurement intervals |
| Identification of source and exhaust | So that it is clear which source and which exhaust are to be measured |
| Technical documentation of equipment | Helps determine operating parameters, output, fuel, raw materials, and technological regime |
| Operating rules | Enables verification that measurement corresponds to the permitted mode of operation |
| Operating records | Serve to document operating hours, consumption, production batches, and source regime |
| Information on separator or filter | Important for assessing function of equipment for reducing emissions |
| Access to measuring location | Without safe and suitable access, measurement may not be possible |
| Current operating regime | Measurement should take place under representative operating conditions |
For technologies with variable or batch operation it is advisable to describe the whole production cycle in advance. Measurement must reflect actual source operation, not a random or unrepresentative state.
What if the source has no suitable measuring location
An unsuitable or missing measuring location is a common problem especially at older technologies, subsequently modified exhausts, or operations where future emission measurement was not considered in the project.
The problem may be, for example:
- missing measuring port,
- unsuitable diameter or shape of duct,
- excessively short straight duct section,
- flow turbulence,
- poor accessibility,
- missing working platform,
- unsafe access to chimney or exhaust,
- inability to handle measuring equipment safely.
If the source has no suitable measuring location, this does not automatically mean that the measurement obligation does not apply. On the contrary, a technical solution usually has to be sought: add measuring ports, adjust access, create a safe workplace, or choose the best technically achievable measuring location.
In some cases it is advisable first to carry out a technical inspection of the source and verify whether measurement can be carried out representatively and safely. If the measuring location does not meet requirements, this should be addressed in time, not only on the day of measurement.
Practical procedure for the operator
If you are unsure whether you need emission measurement, we recommend the following steps:
- Find the current operating permit or authority decision.
- Verify which source and which exhaust are to be assessed.
- Check whether emission limits and measurement intervals are stated in the permit.
- Prepare equipment data sheets, technology description, and operating records.
- Verify whether there is a suitable and safe measuring location at the exhaust.
- If the authority requirement is unclear, have it assessed by an expert before ordering measurement.
This procedure helps avoid a situation where measurement is ordered but it subsequently turns out that a suitable measuring location is missing, measured substances are unclear, representative operation is not ensured, or another expert supporting document should have been prepared first.
Summary
Emission measurement is needed mainly when it follows from the law, decree, operating permit, or requirement of the competent body. It is typically addressed after putting a source into operation, after a significant technology change, during regular verification of compliance with emission limits, or during inspection.
However, measurement itself is not always the first step. For new projects, operational changes, unclear authority requirements, or problematic measuring locations it is often advisable first to review documentation, the operating permit, and the technical state of the source.
Send us a decision, operating permit, or authority requirement and we will verify whether you have an obligation to measure emissions, or whether it is more appropriate first to prepare another expert supporting document.