1. 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
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13. LCP reduction attainments for SO2 TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
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17. Timing TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 stricter than Part A ELV
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23. ELVs SO2 (mg/Nmc) – solid fuel TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
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25. “ 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”
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31. TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 Perception of Emissions’ Value
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33. 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
34. TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010
35. 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.
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38. Implementation of LCP in Romania emission ceilings under the Treaty of Romania Accession to EU emission targets under the National Emission Reduction Program NOx
39. 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
40. Implementation of LCP in Romania emission ceilings under the Treaty of Romania Accession to EU emission targets under the National Emission Reduction Program dust
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48. TAIEX INFRA 42623 Workshop on Large Combustion Plant, Skopje, 14th-15th October 2010 Thank you very much for your attention !
Editor's Notes
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, and 95% for plants > 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, 75% for plants > 100MWth and <= 300MWth and 90% for plants > 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 <10%, 1200mg/Nm3 shall apply. 6. An ELV of 100mg/Nm3 may be applied to existing plants >= 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 <500MWth burning liquid fuel with an ash content > 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).
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