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  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 Since 1979 a host of further measures aimed at abating sulphur emissions have followed at the international (UNECE), European (EC/EU) and national levels.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 The 1984 Air Framework Directive: This Framework Directive does not specify emission limits for any particular class of plant, but lays out the circumstances under which certain types of plant (including large combustion plant) may be authorised to operate and which plants and substances will be subject to controls. The Air Framework Directive introduced the concept of best available technology not entailing excessive costs (BATNEEC) into EU legislation. New plants must conform to BATNEEC, whilst existing (pre-1987) plants must gradually be adapted to BATNEEC or closed down, taking into account a range of considerations including the length of the plant’s remaining life. Excessive costs are defined in relation to the sector as whole not to the economic circumstances of individual plant. The LCP Directive was issued as a daughter Directive to the Air Framework Directive. BATAELs ( BAT A ssociated E mission L evels) are indicative emission levels (found in the BREFs) and relate to the efficiency of the techniques. They do not take account of process fluctuations and cannot be applied to specific circumstances. They should only be used as a reference for establishing specific site ELVs. ELV s ( E nvironment L imit V alues) are safeguards to prevent/minimise environmental impact at the site location . They are not set in the BREF documents. They are legally binding.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 The 1985 UNECE Helsinki Protocol on the Reduction of Sulphur Emissions or their Transboundary Fluxes by at least 30 per cent: Twenty-one countries,including Germany, the Netherlands and France, are Parties to this Protocol, which entered into force in 1987. It established uniform 30% national emission reduction targets for 1993 ( c.f. a 1980 baseline) for all Parties. The UNECE targets cover all sulphur emissions, not simply those from large combustion plant. The United Kingdom refused to sign this protocol.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 A ‘daughter’ Directive to the 1984 Air Framework Directive (84/360/EEC), the LCP Directive regulates emissions to air from new and existing large combustion plant. Defined as boiler plant with a thermal input equal or greater than 50MWth (Art 1). The approach taken by the Directive to the regulation of emissions from new plant was classic ‘command and control’. Setting uniform emission limits values (differentiated by plant size and fuel type) for a range of pollutants: sulphur dioxide (SO2), nitrogen oxides (NOx) and dust (Art 4 & Annexes III to VII). In December 1994 the LCP-Directive was amended by the Council Directive 94/66/EC By contrast the approach taken to the regulation of existing plant was much more flexible. The Directive established progressive staged national emissions reduction targets (also expressed as national emissions ceilings) for SO2 and NOx, with ‘existing plants’ defined as those licensed before 1 July 1987: Art 2, 10). These national targets were differentiated between member states. However, no differentiation within those aggregate national targets was specified within the Directive . The Directive left the choice of policy instruments to achieve those aggregate national emissions reduction targets to individual member states. The implementation of the existing plant emissions reductions targets is of particular interest from a theoretical perspective because of the freedom of choice which the Directive allowed member states in the selection of policy instruments. By contrast the requirements with respect to new plants left relatively little room for differences in implementation practice.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 I t is clear that the greatest degree of over-compliance was initially achieved in Germany (130%, in 1993). Remarkably, in 1993 all four case study countries achieved greater than 95% over-compliance with the Directive’s ‘Phase 1’ SO2 emission reduction objectives, although of course the target for the UK was less stringent those for Germany, the Netherlands and France. The 1996 compliance figures are interpolated (from the 1993 and 1998 reduction targets) as no reduction target was set for this year in the Directive. In each case the 1996 figures show a reduction in the degree of over-compliance achieved. At the time of writing SO2 emissions data for 1998 was not available for Germany or the Netherlands. However, in the case of the UK and France, both countries continued to cover-comply with their respective national SO2 emission reduction targets in 1998. Although again in both cases there was a further significant reduction in the degree of over-compliance achieved.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 The 1994 UNECE Oslo Protocol on Further Reduction of Sulphur Emissions: The aim of this Protocol was to base national emission reduction targets on the contribution that each country made to acid deposition on sensitive ecosystems. As a result the Protocol established a series of differentiated national emission reduction targets, for the years 2000, 2005 and 2010. The Protocol also fixed emission standards for new sources and set out details of the ‘best available technologies’ to be used by plant operators. The Protocol entered into force on 5 August 1998.10 As with the 1985 Protocol the reduction targets cover all sulphur emissions, not simply those from large combustion plant.
  • Control of emissions from large combustion plants - those whose rated thermal input is equal to or greater than 50 MW - plays an important role in the Union's efforts to combat acidification, eutrophication and ground-level ozone as part of the overall strategy to reduce air pollution TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 This Directive applies to combustion plants (technical apparatus in which fuels are oxidised in order to use the heat thus generated) with a rated thermal input equal to or greater than 50 MW, irrespective of the type of fuel used (solid, liquid or gaseous). Its purpose is to limit the amount of sulphur dioxide, nitrogen oxides and dust emitted from large combustion plants each year. It encourages the combined production of heat and electricity (cogeneration).
  • ELVs depend on fuel/capacity/age TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • 1. The ELVs for new plants are daily mean values, see Art 14. The reference oxygen contents are 6% for solid fuels and 3% for liquid and gaseous fuels. 2. Where the ELVs cannot be met due to the characteristics of the fuel, installations shall achieve 300 mg/m3 SO2, or a rate of desulphurisation of at least 92% shall be achieved in the case of plants with a rated thermal input of 300MWth, together with a maximum permissible ELV of 400mg/m3. 3. Gas turbines licensed before 27 November 2002 are excluded from the scope of the LCPD 4. 75mg/Nm3 for gas turbines used in combined heat and power systems having an overall efficiency greater than 75%; gas turbines used in combined cycle plants having an electrical efficiency greater than 55% and gas turbines for mechanical drives. For single gas turbines not falling into any of the above categories, but having an efficiency greater than 35% the ELV shall be 50*(gas turbine efficiency)/35. TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 Member States have two options for controlling emissions from existing plants : The Directive requires significant cuts in emissions at “existing plants”. These cuts are to be achieved: by achieving compliance, plant by plant, with the emission limits applicable to plants , or through a national emission reduction plan applicable to the total emissions of the plants it covers. Member States must send the Commission their national emission reduction plan for existing plants. A national emission reduction plan, whether used alone or as part of a combined approach, must address all the three pollutants covered by the Directive for all the plants covered by the plan. These plans must contain objectives, measures and timetables for attaining them, and a monitoring mechanism. The Commission has publish ed guidelines to help the Member States draw up their national plans.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 Driven primarily by UK who perceived that there would be advantages by setting limits based on emission mass instead of concentration, a more flexible and cost effective way of implementing the LCP Directive Essentially a form of emissions trading. Measures to Achieve Targets in a National Emissions Reduction Plan - Necessary to identify measures such as fuel switching, combustion modifications, abatement techniques, etc. The determination of actual compliance measures is a matter for the individual Member State, taking into account; cost effectiveness, practicability, impact on security and diversity of energy supplies, legal obligations, etc.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 Emission limit values for existing plants 1. The ELVs for existing plants are calendar monthly mean values, see Art 14. The reference oxygen contents are 6% for solid fuels and 3% for liquid and gaseous fuels. 2. Plants greater or equal to 400MWth, which do not operate more than the following number of hours a year (rolling average over a period of 5 years), shall be subject to an ELV for SO2 of 800mg/m3: • until 31 December 2015, 2000 hours; and • from 1 January 2016, 1500 hours. 3. Where the ELVs cannot be met due to the characteristics of the fuel, a rate of desulphurisation of at least 60% shall be achieved in the case of plants with a rated thermal input of 100MWth and 300MWth. For plants > 500MWth, a desulphurisation rate of at least 94% shall apply or of at least 92% where a contract for the fitting of FGD or lime injection equipment has been entered into, and work on its installation has commenced, before 1 January 2001. 4. Until 31 December 2015 plants >500MWth which from 2008 do not operate more than 2000 hours per year (rolling average over a period of 5 years) shall, in the case of plant subject to a National Plan, have their contribution to the National Plan assessed on the basis of an ELV of 600mg/Nm3. From 1 January 2016 such plants, which do not operate more than 1500 hours per year (rolling average over a period of 5 years), shall be subject to an ELV for NOx of 450mg/Nm3. 5. Until 1 January 2018 in the case of plants that in the 12 month period ending on 1 January 2001 operated on, and continue to operate on, solid fuels whose volatile content is = 500MWth burning solid fuel with a heat content of less than 5800kJ/kg, a moisture content > 45% by weight, a combined moisture and ash content > 60% by weight and a calcium oxide content > 10%. 7. An ELV of 100mg/Nm3 may be applied to plants 0.06%. 8. Special provisions apply to multi-firing units using two or more fuels as detailed in Art 8. These are briefly summarised as follows: i. In the case of plants with a multi-firing unit involving the simultaneous use of two or more fuels (Art 8(1)), ELVs shall be set firstly by taking the ELV of each fuel and pollutant; secondly by determining the fuelweighted ELVs, obtained by multiplying the individual ELV by the thermal input delivered by each fuel, the product of multiplication being divided by the sum of the thermal inputs delivered by all fuels; and thirdly by aggregating the fuel-weighted ELVs. ii. In multi-firing units using the distillation and conversion residues from crude-oil refining for own consumption, alone or with other fuels (Art 8(2)), the provisions for the fuel with the highest ELV (the determinative fuel) shall apply, notwithstanding point (i) above, if during the operation of the combustion plant the proportion contributed by that fuel to the sum of the thermal inputs delivered by all fuels is at least 50%. Where the proportion of the determinative fuel is lower than 50%, the ELV is determined as described in Art 8(2), second paragraph. iii. As an alternative to point (ii), an average ELV for SO2 may be applied (irrespective of the fuel combination used) of 1,000mg/Nm3, averaged over all existing plants within the refinery (Art 8(3)). iv. In the case of plants with a multi-firing unit involving the alternative use of two or more fuels (Art 8(4)), the ELVs corresponding to each fuel used shall be applied.
  • Where SO2 ELVs cannot be met due to characteristics of solid fuel used, there is a possibility to apply a minimum rate of desulphurisation TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010 The Directive allows existing plants to be exempted from compliance with the emission limits and from inclusion in the national emission reduction plan on condition that the operator undertakes not to operate the plant for more than 20 000 hours between 1 January 2008 and 31 December 2015.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • The total SO2, NOX and dust emissions (in kilotonnes, kt) from reported LCPs in the EU-27, for each year 2004- 2006, are shown in Figure. total SO2, NOX and dust emissions from LCPs in the EU have decreased over the time period 2004 to 2006. Dust emissions decreased most markedly (by 23%), followed by SO2 emissions (by 8.6%), whilst the total NOX emissions decreased least (by 1.8%) over the 2004-2006 period. Additional analysis has been undertaken at the level of individual LCPs. Calculating emission factors – mass of pollutant emitted per unit energy input – allows for an assessment of the environmental performance of LCPs. This has been undertaken at a LCP level, at the MS level and overall for the EU. TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • The total SO2, NOX and dust emissions (in kilotonnes, kt) from reported LCPs in the EU-27, for each year 2004- 2006, are shown in Figure. total SO2, NOX and dust emissions from LCPs in the EU have decreased over the time period 2004 to 2006. Dust emissions decreased most markedly (by 23%), followed by SO2 emissions (by 8.6%), whilst the total NOX emissions decreased least (by 1.8%) over the 2004-2006 period. Additional analysis has been undertaken at the level of individual LCPs. Calculating emission factors – mass of pollutant emitted per unit energy input – allows for an assessment of the environmental performance of LCPs. This has been undertaken at a LCP level, at the MS level and overall for the EU. TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • It is possible to further analyse the EU emission factors for each pollutant, split by capacity class. Figure 4.14 plots the EU SO2, NOX and dust emission factors for each capacity class, for the years 2004, 2005 and 2006. Alongside the capacity class splits are EU emission factors for all LCPs. The SO2 plot shows that the previously described trend of declining average mass of SO2 emitted per unit of energy input across the EU over the period 2004 to 2006 is true for all capacity classes, with the 300-500 MWth capacity class emission factors decreasing the most. The plot also shows that smaller capacity classes have lower SO2 emission factors. This reflects the higher proportion of LCPs in these capacity classes that are natural gas fired, as illustrated in Figure 4.6. Averaged over 2004-2006 the natural gas fraction of total energy input is 46% for the 50-100MWth capacity class, and 32% for the 100-300MWth class. This compares to 31% for 300-500MWth and 24% for >500MWth. The NOX plot12 in Figure 4.14 shows that the previously described trend of declining average mass of NOX emitted per unit of energy input across the EU over the period 2004 to 2006 is true for all but one capacity class: the smallest capacity class (50-100 MWth) exhibits a small increase in EU average of MS NOX emission factor over 12 Note The period 2004 to 2006. It is not clear why this trend appears. The plot also indicates that the EU emission factor for (not split by capacity) is skewed by the class of LCPs >500 MWth. The dust plot in Figure 4.14 shows that the previously described trend of declining average mass of dust emitted per unit of energy input across the EU over the period 2004 to 2006 is true for all capacity classes, with the largest drop between 2004 and 2005. Contrary to the SO2 and NOX plot, the dust plot does not confirm the trend that larger capacity classes exhibit higher emission factors: the 300-500MWth capacity class has a higher average dust emission factor than the >500MWth class over all years 2004-2006 TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • Calculating an emission factor (EF) of mass of pollutant emitted per unit energy input allows for an assessment of the environmental performance of LCPs . This can be done at the MS-level, if total emissions are divided by total energy input, or at the individual LCP-level. When looking at this statistic at an EU-level, two variations exist: i. By first calculating an average emission factor for each MS, and then averaging these factors across the EU, provides a direct mean of all MS LCP environmental performance, attaching equal weighting to those MS with 100 LCPs and those with 10. This is the ‘EU average of MSs’ emission factors’. ii. Alternatively, the total EU emissions can be divided by the total EU energy input to provide an ‘ average EU emission factor’, which adds weight to those MS with more heavily polluting LCPs, and which provides an indication of the performance of the EU as a whole. This analysis interprets the EU average emission factor as method ii. Table 4.19 compares the MS and EU SO2, NOx and dust emission factors for 2004, 2005 and 2006. Factors could not be calculated for the Netherlands, Sweden (2004, 2005) and Italy (2004). The table shows considerable variation between MS. TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • These two figures demonstrate that for some Member States, opt-outs contribute a significant proportion to total LCP capacity and emissions. For example, for some Member States such as France, Malta, Slovakia and the UK, opted-out plants contributed at least 25% of total LCP emissions of SO2, NOX and dust in 2006. This contribution to total emissions is likely to be even higher (as a %) since 1 January 2008 as existing plants that have not chosen to opt-out now have to comply with LCPD ELVs or NERP requirements TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • LCP performance derived from the inventories can also be compared to the LCP BREF BAT-AELs, which are emission levels indicating what can be achieved if an installation applies the best available techniques (BAT), as indicated in the LCP BREF document. For SO2 almost 30% of LCPs in this analysis appear to have operated above the LCPD ELVs in 2006, approximately 40% below the LCPD ELVs but above the upper BREF BAT-AEL range and a further 20% between the lower and upper ranges. Only 10% of LCPs appear to have been operating below the lower BREF BAT-AEL rangeons includes approximately 55% of all plants by number reported in Member States’ LCP emission inventories. For NOX the number of LCPs (excluding gas turbines) that appear to have been operating above the LCPD ELVs in 2006 is similar to the results for SO2. However, over 50% of LCPs appear to have been operating between the LCPD ELVs and upper BREF BAT-AEL range with a much smaller proportion operating lower (approximately 16% and 2% between the upper and lower ranges of the BREF BAT-AELs and below the lower range, respectively). For gas turbines, approximately two thirds of LCPs appear to have been operating above the LCPD ELV with the remainder below it. This may reflect the fact that some Member States appear to have reported emissions data for gas turbines which are excluded from the LCPD (those licensed before 27 November 2002); and For dust the situation is quite different. An approximately equal proportion of LCPs included in this analysis (between 22-28%) appear to have been operating in 2006 at each category of performance. TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th - 15 th October 2010
  • The Proposal for a Directive on industrial emissions recasts seven existing Directives related to industrial emissions into a single clear and coherent legislative instrument. The recast includes the IPPC Directive, the Large Combustion Plants Directive , the Waste Incineration Directive , the Solvents Emissions Directive and 3 Directives on Titanium Dioxide. Minimum requirements of the sectoral Directives are often used as default emission limits for IPPC permits, disregarding existing legal requirements. This is a problem in particular for Large Combustion Plants (LCP) that contribute significantly to the EU-wide emissions of key air pollutants such as SO2 (~ 80% of total emissions) and NOx (~30% of total emissions).

Final boca    history , scope, requirements lcp Final boca history , scope, requirements lcp Presentation Transcript

  • The LCP Directive history, goals, requirements, and implementation of LCP in the EU TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 GABRIELA BOCA The Environmental Protection Agency Mures, ROMANIA
  • Content
      • History and goals behind the LCP directive
      • LCP directive scope and requirements
      • Implementation of LCP in the EU
      • New developments in LCP legislation
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • 1952 - London smog disaster
    • ‘ dilution was the solution’
    • 1950-1970 strong economic growth increased total energy consumption and also the total emissions of sulphur dioxide
    • 1967 – Svante Oden – Swedish scientist – acidification of forest soils and forest productivity losses – ’72 UN Conference on Human Environment – Stockholm
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 Historical basis and goals behind the LCP directive
    • 1973 oil crisis - decreasing emission on Western Europe, increasing emissions on Eastern Europe
    • International measures EMEP 1977
    View slide
    • from 1979 CLRTAP is one of the central means for protecting our environment - UNECE (United Nations Economic Commission for Europe)
    • Scope - to protect man and his environment against air pollution and shall endeavour to limit and, as far as possible, gradually reduce and prevent air pollution including long-range transboundary air pollution .
    • The Contracting Parties, shall by means of exchanges of information, consultation, research and monitoring, develop without undue delay policies and strategies which shall serve as a means of combating the discharge of air pollutants, taking into account efforts already made at national and international levels .
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 View slide
    • 1980, the Directive on air quality standards for smoke and SO2 (80/779/EEC) l imit and guide values for sulphur concentration in ambient air.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • By the early eighties it was obvious that air pollution from industry needed to be controlled on an EU level, although some countries had already implemented comprehensive national legislation
    • 1983 Germany implemented Federal Imissions Control Act (BImSchG), leads in ten years to a 89% reduction of SO 2 , driven by high awareness of environmental damage to forests.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Air Framework Directive 84/360/EEC established system of permitting
      • Use of Best Available Technology Not Entailing Excessive Cost (BATNEEC)
      • Plant must not cause significant air pollution, i.e. applicable emission limit values and air quality values must be met.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
      • 1985 – first CLRTP (Helsinki) Protocol - Required 30% reduction in national SO2 emissions c.f. 1980 levels by 1993. G ermany, Netherlands and France were all signatures. The United Kingdom was not.
      • into force in 1987
    • Obvious that LCP sector required particular regulation as a major source of SO 2 and NOx emissions.
    • Long drawn out highly politicised and contested process with first proposal of LCP directive presented in 1983 as a daughter directive to the Air Framework Directive. Finalised in 1988 as Directive 88/609/EEC, the first LCP Directive set s Emission Limit Values (ELVs) for new plant and gave a national ‘bubble’ of emissions for existing plants.
      • New Plant – licence granted after July 1987.
      • Existing Plant – licence granted before July 1987.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 First LCP Directive 88/609/EEC
    • Scope of Directive 88/609/EEC limited to :
      • Rated thermal input ≥ 50 MW.
      • Combustion plants for the production of energy.
      • Direct use of the products of combustion in manufacturing process
    • Does not include:
      • Combustion of waste or combustion for air emissions control.
      • Situations where products of combustion used for direct heating or drying, e.g. furnaces.
      • Diesel, petrol or gas engines or gas turbines.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Goal was to reduce emissions of SO 2 , NOx and particulates.
      • Classic ‘command and control’ approach for new plants setting uniform Emission Limit Values (ELVs) based on plant size and fuel type.
      • More flexible approach for existing plants; staged reduction (national emissions ceilings) for SO 2 and NOx for 1993, 1998 , 2003.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • Additional Requirements of LCP Directive
    • Member States to determine total annual emissions for both new and existing plants.
    • National emission reduction targets to be agreed with EU. Compliance programmes to achieve targets to be developed with the operators.
    • Options include fuel switching, energy saving measures, pollution abatement technologies.
    • Licences need to consider measurement methods and measures in event of failure of control devices, etc.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • LCP reduction attainments for SO2 TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • 1993 , Directive on the sulphur content of liquid fuels (93/12/EC) - Limited sulphur content of gasoil to 0.3%
    • 1994, the f irst LCP Directive is amended by Directive 94/66/EC - have revised the emission limit values for SO2 for new (solid fuel) plant
    • 1994, second CLRTAP Sulphur (Oslo) Protocol - Differentiated national targets for sulphur reduction from all sources for 2000, 2005 and 2010, new plant emission limits and fuel specifications based on EU Directives - entered into force on 5 August 1998 .
    • 1996, EU Directive on Integrated Pollution Prevention and Control (IPPC) - this framework Directive requires the adoption of Best Available Techniques (BAT) to prevent or minimize pollution of the environment as a whole.
    • 1999 Gothenburg Protocol to Abate Acidification, Eutrophication and Ground-level Ozone, which entered into force on 17 May 2005.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • NEW LCP Directive 2001/80/EC - Scope
    • By 2001 the LCP directive was updated (2001/80/EC) reflecting the progress in technology and EU environmental legislation and the need to include gas turbines, promote combined heat and power and tighten up monitoring.
    • The overall SCOPE of the new LCP Directive is to reduce emissions of acidifying pollutants, particles, and ozone precursors.
    • Applies to combustion plants with a rated thermal input >= 50 MW
    • Sets provisions for emission reductions for sulphur dioxide (SO2), nitrogen oxides (NOx) and dust.
    • Main sectors covered: electricity supply, petroleum refineries, iron & steel, chemicals, paper, sugar, others
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Encourage the combined generation of heat and power
    • Sets specific ELVs for the use of biomass as fuel
    • Diesel, petrol and gas engines still excluded
    • Updated ELVs for new LCP instalations
    • ELVs set for gas turbines, which were becoming increasingly common, in addition to those set for solid fuel and liquid fuel fired LCPs.
    • Includes certain gas turbines in its scope in order to regulate NOX emissions
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 LCP D irective 2001/80/EC requirements
  • Timing TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 stricter than Part A ELV
  • Requirements ELVs - new plants
    • ELVs depend on fuel/ capacity/ age
    • “ New-New” plants (Article 4.2)
    • Emission limit values in Annex III to VII part B
    • Must consider potential for combined heat & power
    • Average emission limit values for refineries (Article8.3(b))
    • “ Old-New” Plants (Article 4.1)
    • those licensed after 1 July 1987 before 27 November 2002
    • Emission limit values in Annex III to VII Part A
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Emission limit values for new plants
    • Options:
      • applying the new plant ELVs in the original Directive to existing plant by 1 January 2008 , or
      • by 1 January 2008, reducing emissions from existing plant under a national emission reduction plan ( NERP) to the same levels which would have been achieved by the application of the new plant ELVs to existing plant in operation in the year 2000.
    • I t is possible to adopt a "combined approach" for the implementation of the LCP Directive for existing plants, which may consist of:
    • a) applying a national emission reduction plan for some plants and an emission limit value approach for others for all the compliance periods (2008-2015, 2016-2017, and 2018 onwards),
    • or b) adopting a national emission reduction plan for a/some compliance period(s) and complying with emission limit values for the rest of the compliance periods,
    • or c) mixing options a) and b) above.
    Requirements ELVs - existing plants TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Member states can implement a National Emission Reduction Plan which:
        • shall reduce the total annual emissions of NOx, SO2 and dust
        • from existing plants
        • to the level that would have been achieved by applying the emission limit values… to the existing plants in operation in the year 2000
        • on the basis of each plant’s actual operating time, fuel used and thermal input
        • averaged over the last 5 year of operation up to and including 2000’
    National Emission Reduction Plan TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Emission limit values for existing plants
  • ELVs SO2 (mg/Nmc) – solid fuel TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • ELVs SO2 (mg/Nmc) – solid fuel Minimum desulphurisation rate TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 rate of desulphurisation ( %) = (sulphur not emitted) ( suplhur introduced through fuel)
    • “ natural” desulphurisation – presence of Ca rich fly ash
    • abatement measures (FGD)
  • “ Common stack” TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 Commission interpretation : Existing and new plants whose waste gases are discharged through a common stack should be considered as a single plant for the purposes of the Directive (might include several boilers) Art. 2(7) “ Where two or more separate new plants are installed in such a way that, taking technical and economic factors into account, their waste gases could , in the judgement of the economic authorities, be discharged through a common stack , the combination formed by such plant shall be regarded as a single unit”
  • ‘ End of Life’ Exemption
    • Directive 2001/80/EC included the following important exception:
      • An existing plant may be exempted from compliance with the ELVs and from inclusion in the national plan if the operator declares that the plant will not be operated for more than 20,000 hours between 1 January 2008 and 31 December 2015; “end of life”.
      • In addition, the Directive authorizes derogations from compliance with the emission limit values for plants which burn specific types of fuel .
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Member States must ensure that waste gases from combustion plants are discharged via stacks high enough to safeguard human health and the environment.
    • Continuous monitoring of SO2, NOx and dust in waste gases from plats > 100 MW
    • Monitoring at least every 6 months for plants <100 MW
    • Derogations from monitoring:
        • Plants with a life span < 10 000 hours
        • SO2, dust in case of natural gas
        • SO2 in case of oil with known sulphur content and no abatement
        • So2 in case of biomass combustion that cannot exceed ELV
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • RELATED ACTS
    • Commission Recommendation 2003/47/EC of 15 January 2003 on the guidelines to assist a Member State in the preparation of a national emission reduction plan further to the provisions of Directive 2001/80/EC on the limitation of emissions of certain pollutants into the air from large combustion plants
    • Council Decision 2003/507/EC of 13 June 2003 on the accession of the European Community to the Gothenburg Protocol to the 1979 CLRTAP to abate acidification, eutrophication and Ground-level ozone
    • National Emission Ceilings Directive 2001/81/EC (NECD) sets pollutant-specific emission ceilings for each MS to be met by 2010 .
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • Interface with IPPC Directive
    • In all cases a LCP installations require an IPPC permit.
    • Compliance with the Emission Limit Values laid down by the LCP directive should be regarded as necessary but not sufficient for compliance with the requirements of directive 96/61/EC (IPPC) regarding the use of Best Available Techniques.
    • LCP installation compliance with IPPC may involve more stringent ELVs, ELVs for other substances and other media, and other appropriate conditions, account of the LCP BREF among other factors. Where BAT based ELVs are less demanding than LCP directive’s ELVs possible to use national plan option
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • The IPPC permit must contain BAT based ELVs, for which there is flexibility for existing plants. This is a more complex issues than the ELVs specified in the LCP directive
    • Where BAT based ELVs are less demanding than LCP directive’s ELVs possible to use national plan option.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 Perception of Emissions’ Value
  • Implementation of LCP in the EU TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • key policies affecting emissions of air pollutants from LCPs in the EU
    • option of choosing a national emission reduction plan for existing plants instead of ELVs; mixture of abatement, fuel switching and reductions in load factors and will be decided by the operating companies themselves, closer to the LCPD compliance deadline for existing plants of 1 January 2008.
    • several new Member States have derogation allowances under the LCPD - most extensive derogation allowances - Estonia, Lithuania and Poland; the true extent to which the derogation allowances are less stringent than the LCPD will be dependent on various factors, notably the projected fuel mixes for the electricity supply industry in these countries
    • set national ELVs for LCPs which go beyond those included in the LCPD - for existing plants many countries go further than the LCPD in terms of ELVs for at least one or more of the LCP pollutants of SO2, NOx or dust - for new plants most countries tend to set ELVs derived directly from the LCPD rather than going beyond it.
  • Implementation of LCP in the EU TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 European Commission - Evaluation of the Member States‘ emission inventories 2004-2006 for LCPs under the LCP Directive (2001/80/EC) - Final Report September 2008 next Report 2011
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 Calculated MS and EU factors (g/GJ) over time (2004, 2005, 2006) for each pollutant. Highest five MS emission factors for each pollutant and year are highlighted in red.
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • Implementation of LCP in Romania emission ceilings under the Treaty of Romania Accession to EU emission targets under the National Emission Reduction Program NOx
  • Implementation of LCP in Romania emission ceilings under the Treaty of Romania Accession to EU emission targets under the National Emission Reduction Program SO 2
  • Implementation of LCP in Romania emission ceilings under the Treaty of Romania Accession to EU emission targets under the National Emission Reduction Program dust
  • New Developments
    • Need for further industrial emission reductions to meet Thematic Strategy 2020 targets:
      • -30% for SO 2
      • -35% for NOx
      • -24% for PM 2.5
      • -17% for Volatile Organic Compounds
    • Recent proposal from EU Commission Communication (21/12/2007) for a new Directive on industrial emissions will incorporate the above targets for licensing of LCPs .
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • Directive on industrial emissions
    • strengthening of BAT and the role of the BREFs
    • BREFs contain emission levels associated with the use of BAT (BAT AELs)
    • Permits must contain ELVs that do not exceed BAT AELs
    • Derogation from BAT AELs is allowed in specific cases as long as it is justified
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • tightening minimum emission limit values for existing and new LCP – aligned with BAT level from the LCP BREF (2006 )
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • For Existing plants , ELVs apply from 1 January 2016 but it is the possibility to have a Transitional National Plan TNP 2016 - 2020 -
    • annual ceilings with linear decrease
    • LCPD limit values IED limit value
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Co-decision procedure for approval
      • European Parliament : first reading and amendments voted in plenary on 10 March 2009
      • Council: political agreement reached on 25 June 2009
      • Common position is prepared
      • European Parliament second reading and amendments approval on 7 Julie 2010 -
      • Commission position on EP amendments on 2nd reading – decision agreement on 7 Julie 2010
      • Entry into force: 2012
      • Application for existing installation 2012 - 2016
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • The cost of upgrading every LCP would be prohibitive.
    • For older plants it is essential to consider:
      • What is the residual lifespan of older plants?
      • Are these base load stations or used to match peak loadings?
      • Which is cheaper? Upgrade or replace with new plant?
      • Consider applying for ‘end of life’ reduced hours exemption? (20,000 hrs over 8 years)
    Conclusions TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
    • Need to carefully consider economic considerations before initiating upgrade projects.
    • Justification is strong for the considerable investment required to upgrade or replace LCPs.
    • Approach taken by Member States has differed, from going nuclear (France), going gas (UK and Ireland), or major retrofitting to existing coal fired generation (Germany).
    • Future trend is that even tighter controls are technically feasible and will be sought by EU.
    TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
  • TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 Thank you very much for your attention !