EN14181, 4) disproportionately high costs to reduce the concentration of emissions for units operating less than hours compared to the

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1 Comment number Country BAT number Paragraph in Chapter 10 1 DK General Definitions 5 New (shall be considered as of a "combustion plant") page in chap 10 Comment Text proposal Rationale spot marked, 3) Costly to follow BAT AELS do not apply to emergency units and monitoring frequency does not apply for emergency units 500 hours compared to the, 5) According to IED, gas and gas oil fired gas turbines that operate less than 500 operating hours per year are not covered by the emission limit values. Emergency boilers can be as fast as gas turbines: 60 MW in 15 min. 260 MW after 90 min. 6) If there is an overriding need to maintain energy supplies, acccording to IED, the competent authority may grant a derogation from the time limit of 120 hours cumulative duration of unabated operation, or minor comment Paragraph in Backgro page in BP Location in D1 Affected boilers Bemærkning KYV21, KYV22, KYV28 fælles skorsten. BAT 32: "NOx gasolie kedler", KYV21, KYV22, KYV28 NOx krav kan ikke overholdes. KYV21 og KYV22 som units vil værre omfattet af kategorien "Emergency units". KYV51+KYV52+MAV31 er direkte omfattet af BREF men alle 3 GT er emergency units (og plants). 2 DK General Definitions 5 New steam generator" unit Auxiliary start up steam generator: Units that operate less that 1500 hours every year, with a BAT AELS do not apply to auxiliary start up steam generator units and monitoring frequency does not apply for auxiliary start up steam generator units, AVV hjælpedamp kedel og KYV28 3 BAT 3 ter Monitoring In D1 monitoring (measurement) frequency for noise level was specified at 3 times /yr. EIPPCB proposes to add a noise management plan to the Environmental Management Plan. We welcome the proposal but would like to comment on provision a (under xvi). 4 BAT 3 ter General 1.1 Define separate BAT conclusions on the monitoring.for. Cf. BAT 3 ter. In BAT 3 ter. It is stated that NOx and Sox emissions from HFO and/or gas oil fired boilers and engines must be monitored continuously except plants with a rated thermal input of < 100 MWth. We would suggest that this provision includes oilfired emergency load and peak load 5 BAT 3 ter Monitoring Generally there should be no monitoring requirements for parameters not covered by BAT AEL xvi: a protocol for modelling noise impact from the plant in case new machinery etc. or other modifications not included in the intial permit is being planned. The purpose of the modelling is to ensure that the planned activities may be carried through without leading to non compliance with noise impact provisions. In the case of HFO and/or gas fired plants operated in emergency load mode or peakload mode, the monitoring frequency of SO2 and NOx may be reduced to at least once every year, provided that the plant is operated in that year. If the plant is not operated, no measurement is required. Add footnote to the table in BAT 3 ter: No monitoring requirements for substance/parameter not covered by BAT AEL It does not as such makes sense to monitor at the plant boundary in as far as compliance with noise regulation is based on compliance with noise levels in noise reception points in the vicinity of the plant. Compliance is modelled based on noise source measurements (machinery etc.) integrated in a noise model of the plant in question. The emission from oil fired plants are normally quite uniform and emissions may be calculated based on a emissionfactor documented by way of performance tests pp Alle anlæg For parameteres not covered by BAT AEL monitoring requirements is out of scope. There is no rationale doing measurement if no BAT AEL has to be meet 6 BAT 3 ter Monitoring According to IED Annex V part 3, the competent authority may decide not to require the continous measurements in several cases. The measurement requirements in BAT 3 ter has to be in compliance with the IED excemption rules Add a generel footnote to the table in BAT 3 If the competent authority has decided ter: No continous monitoring requirements if not to require continous measurements the competent authority has decided not to according to IED Annex V part 3 for a require continous measurements according to IED Annex V part 3 given LCP the BREF requirements must be aligned to that decision

2 7 BAT 3 ter Monitoring No requirement for continuous minimum Delete "gas oil fired gas turbines" for monitoring frequency for gas oil fired gas substance/parameter NOx and CO turbines for NOx and CO No BAT AEL for NOx and CO for gas oil fired gasturbines as Table has been deleted. 8 BAT Energy efficiency 33 Techniques to increase energy efficiency Move technique description to BAT 7 plant are described i BAT 7. BAT 18 describes only one technique to increase energy efficiency of coal and/or lignite combustion. The BREF will be more simple moving BAT Alle kulanlæg 18 to BAT 7. With present formulation it is unclear if both the techniques in BAT 7 and BAT 18 should be complied with or if the requirement is a combination of the two BAT sections 9 DK BAT Nox, N₂and CO em46 SNCR is described as generally applicable. This is not the case for all existing boilers if the operating temperature window is located between the superheaters. In the backgroundpaper it is written that "negative impact of load variations and boiler design can be offset by acting on the reagent type or droplet size, and/or the number of levels of reagent injection." That does not correspond to your experience. 10 DK BAT Nox, N₂and CO em46 SNCR is due to existing boiler design not applicable for all boilers between 100 and 300 MWth and SCR is not technoeconomical feasible for biomass boilers of that size. Therefore it is necessary to increase NOx BAT AEL for boilers between 100 and 300 MWth. Add text to SNCR applicability: The Applicability may be limited for existing boilers if the operating temperature window for SNCR is located in or between the superheaters. Add footnote: These BAT-AEL do not apply reduced NOx-emission exceeds 4 EUR/kg Using UREA will increase the applicable temperature window and penetration depth of SNCR. But the upper temperature limits is still approximately 1050C. Urea cannot be used between or just before the superheaters, because it creates risk of corrosion. Changed drop size / spray pattern and volume of water can do something if the temperature in the boiler is too high, but the effect is limited, and exessive water consumption reduces the boiler effeciency. Cf. SNCR tests at ASV2. SNCR test at Skærbæk power plant has showed that it is very difficult to dose NH3 in between the hanging superheaters with success, as the residenstime is very short and the flow and temperature conditions are complicated Referenceplant 29VC (HEV), has a temperature window for SNCR temperature at full load between the hanging superheaters, and it will be difficult/impossible to install SNCR between the hanging superheaters. The i f hi f l Add footnote: The higher end of the BAT-AEL range can be as high as 220/240 mg/nm3 yearly/daily for MWth boilers, in the case of limitations of SNCR applicability due to boiler design. When SNCR is not applicable due to existing boiler design, there are three possibities left: NOx reduction via primary measures, SCR or closing the NOx, in the remaining expected lifetime of the boiler. Primary measures are not always enough to ensure a very low NOxemission, this is confirmed since only 4 out of 17 referenceplants with only primary measures live up to the proposed BAT AEL. Of these 4 none is GB, 1 is CFB, 1 is WBB, 2 is BFB but one of the BFB is a new plant from 2010 and the other has higher CO emissions than the BAT AEL. Using SCR is often not technoeconomical feasible for smaller biomass fired boilers. This is confirmed by EIPPCB in the background paper page 92 since the reference tecnique for this plant size is primary measures and SNCR. Furthermore the CAPEX for tail end SCR to reference plant 29VC has been estimated to 26,8 mio. EUR together with OPEX this is equivalent to 15,8 EUR/kg reduced NOx emission or 4,5 times higher than the Danish NOx tax. Closing the boiler and building new is f i l h BAT con88 89 Assesment HEV, AVV2bio Table Assesment HEV, AVV2bio

3 11 DK BAT Nox, N₂and CO em46 Some existing boilers can't with a technoeconomical proportional solution live up to BAT AEL for CO reduced CO emission exceeds 0,5 EUR/kg 12 DK BAT SOx, HCl and HF 13 DK BAT SOx, HCl and HF 48 SO2 BAT AEL do not leave enough room for the BAT Technique "Fuel choice". 48 HCl BAT AEL do not leave enough room for all techno economical optimal solutions for biomass usage in LCP's CO, in the remaining expected lifetime of the for existing grate and BFB fired boilers. Increase BAT AEL for existing plants <100 MWth to 350 mg CO/Nm3. Increase BAT AEL for existing plants >100 MWth to 250 mg CO/Nm3. Increase BAT AEL for new plants >300 MWth to 160 mg CO/Nm3. Excisting boilers with derogation according to IED art. 33 and 35 are exempted from requirements to CO in the derogation period. Proposal 4: Increase BAT AEL for existing GB and BFB plants <100 MWth to 350 mg CO/Nm3. Increase BAT AEL for existing GB and BFB plants >100 MWth to 250 mg CO/Nm3. Increase BAT AEL for new GB and BFB plants >300 MWth to 160 mg CO/Nm3. i i b il ihd i di Increase yearly/daily BAT AELs for new and existing plants to minimum 70/100 mg SO2/Nm3. Increase yearly/daily BAT AELs for existing plants >300 MWth to 70/100 mg SO2/Nm3. reduced SO2 emission exceeds 4 EUR/kg SO2, in the remaining expected lifetime of the Increase yearly/daily BAT AELs for new and existing plants to 50/75 mg HCl/Nm3. Increase yearly/daily BAT AELs for existing plants to 50/75 mg HCl/Nm3. reduced HCl emission exceeds 4 EUR/kg HCl, in the remaining expected lifetime of the CO has a minor impact on air quality, health and environment compared to emissions of NOx, SO2, HCl and HF. This is supported by CEEH Scientific Report No 3: ISSN: For plants between 100 and 300 MWth 8 of 24 reference plants can't meet BAT AEL. Of the 8 plants not consistent with the BAT AEL 6 is BFB and 2 is GB. For BFB and GB there is 14 and 3 CO reference plants MWth. That is 43% of BFB and 67% of BG can't meet BAT AEL for CO. That is consistent with the Danish experience for other bio fired GB. Examples are: SKV40 under construction >300 MWth (due to aggregation rule) guarantee value 200 mg CO/Nm3, AVV2bio >300MWth (due to aggregation rule) 550 mg CO/Nm3, Randers MWth 900 mg CO/Nm3, Måbjerg <100 MWth 350 mg CO/Nm3. Strict CO BAT AEL will increase NOxemissions, many plants are already optimizing on the ratio between NOx and CO emissions. BFB and GB often burn difficult fuels i di lik b k bi d The "optimal" techno economical SO2 emission level is very different from AEL for SO2. In that context BAT AEL for SO2 is slightly too low if you want to use the BAT technique "Fuel choice". Below are a chase study explaining why: Ref. plant 27VC achieves SO2 emissions after wet FGD of 1 mg/nm3, burning wood pellets. Before wet FGD the SO2 emission is between 20 and 70 mg/nm3, when burning only wood pellets. The relatively high SO2 emission is due to the fact that it is necessary to inject coal fly ash together with the wood pellets to protect the super heaters from slagging and Cl corrosion. With protected super heaters it is possible to maintain high steam temperatures and thereby electric efficiency. Furthermore the SCR catalyst is protected against very rapid deactivation. Some plants like 29VC do not have high steam temperatures or SCR and therefore injection of coal fly ash is not i hi d i i f The "optimal" techno economical HClemission level is very different from AEL for HCl. There is very little experience with optimal techno economical removal of HCl from biomass. As an example of this, there is only 31 reference boilers for HCl and out of them only 19 has continous monitoring. In comparison there is 139 reference plants for NOx from coal/lignite boilers. In that context it is recomended to have fairly high BAT AEL's and demand of continous HCl measurement where relevant. Thereby valueable knowledge about HCl reduction and emission levels from biomass will be available for the next revision of the BAT conclusions. In the background paper it is acknowleged that the effect of a combination of a gas gas heater and high Cl biomass is unknown, but it is not reflected in the BAT AELs. In the background paper 33V is i d f f l SKV40, SSV3, AVV2bio, ASV2(konverted SSV3 SSV3, HEV, AVV2HK, AVV1, AVV2bio, SKV40, Måbjerg, ASV2

4 14 DK BAT SOx, HCl and HF 15 DK BAT Nox and CO 16 DK BAT Nox and CO 17 DK BAT Nox and CO 48 HF BAT AEL do not leave enough room for all techno economical optimal solutions for biomass usage in LCP's 53 Auxiliary start up steam generator units to the aggregation rule. SCR abatement techniques to meet the BAT AEL for 53 Emergency units "Combustion 52 Exclude single units operating less than Increase all HF BAT AELs to the same level as coal. Increase all HF BAT AELs for existing plants to the same level as coal. reduced HF emission exceeds 20 EUR/kg HF, in the remaining expected lifetime of the AELs do not apply for Emergency units. (mg/nm3) i.e. at the top level: BAT AEL is not applicable for units with less than 1500 operating hours per year as a rolling average over a period of 5 years The "optimal" techno economical HFemission level is very different from AEL for HF. There is very little experience with optimal techno economical removal of HF from biomass. As an example of this, there is only 19 reference boilers for HF and out of them only 6 has continous monitoring. In comparison there is 139 reference plants for NOx from coal/lignite boilers. In that context it is recomended to have fairly high BAT AEL's and demand of periodic HF measurement. Thereby valueable knowledge about HF reduction and emission levels from biomass will be available for the next revision of the BATconclusions. The BAT AEL do not reflect the potential effect of a combination of a gas gas heater and high HF biomass. The very low HF BAT AEL may exclude some of the described BAT technologies for reduction of acid gas emissions. f h l l l i spot market, 3) Costly to follow EN14181, perspective set by the IED. SSV3, HEV, AVV2HK, AVV1, AVV2bio, SKV40, Måbjerg, ASV Kan udelades hvis "New Kan udelades hvis "New DK BAT Sox, HCl and HF 19 DK BAT Sox, HCl and HF 55 Auxiliary start up steam generator units to the aggregation rule. 55 Emergency units "Combustion AELs do not apply for Emergency units.emergency units (gas turbines and boilers): Units operating less than 500 hours every year, and have contracts to provide fast start to secure backup of energy supply with the spot market 3) Costly to follow EN14181, Kan udgå hvis "New Kan udgå hvis "New

5 20 DK BAT Sox, HCl and HF 21 DK BAT Dust and 22 DK BAT Dust and 23 DK BAT Dust and 24 BAT Sox and dust emisisons to air 25 BAT Sox and dust emisisons to air 55 Exclude single units operating less than 56 Auxiliary start up steam generator units to the aggregation rule. 56 Emergency units "Combustion 56 Exclude single units operating less than AELs do not apply for Emergency units. 64 Emergency units Table Add footnote at BAT AELs "Combustion (mg/nm3) i.e. at the top level: These BATplant" or part of a "combustion plant") AELs do not apply for Emergency units. 64 Exclude single units operating less than Table Add footnote at BAT AELs spot market, 3) Costly to follow EN14181, Kan udgå hvis "New Kan udgå hvis "New spot market, 3) Costly to follow EN14181, Kan udgå hvis "New