Medium Combustion Plant Directive Planning Fitness for Compliance

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1 Medium Combustion Plant Directive Planning Fitness for Compliance Sharon Kuligowski Managing Director Dunphy Combustion Ltd 1

2 what fate for the Medium Combustion Plant Directive? emissions limit values seen as best practice less stringent than values in some cities/local Authorities and other countries 2015 Defra publish Ambient Air Quality Directive 2

3 Entered into force on 18 December 2015 Law applies from 19 December 2017 The law will be enacted via amendments to the existing permitting laws; Environmental Permitting (England and Wales) Regulations Pollution Prevention and Control (Scotland) Regulations Pollution Prevention Control (Industrial Emissions) Regulations (Northern Ireland) Main regulators England & Wales: Environment Agency >20MW sites. Sites <20MW they already monitor Local Authorities any sites that fall outside this area Scotland: SEPA (Scottish Environmental Protection Agency) 3

4 Bad news more compulsory red tape more resource required for in-depth checking of NOx emission claims. Fitness for compliance Good news proven low NOx combustion equipment already The MCPD sets out emission limits for SO 2 and particulates and CO will need to be recorded, but this presentation will focus on NOx 4

5 definitions and processes within the Directive timetable for compliance plant design and specification for minimising NOx how to assess supplier emission claims case studies on sites achieving consistent low NOx 5

6 MCPD sets emissions limits for NOx from combustion plant MCPD sets emissions limits for NOx from thermal inputs between 1MW and 50MW combustion plant with Existing permitting laws already place emissions limits on installations in the region of 20 MW to 50 MW (Part B or Part C installations)-potential conflict The Clean Air Act will be amended to avoid double regulation. Emission Limit Values (ELVs) defined as the permissable quantity of a substance in waste gases from combustion plant which may be discharged into the air in a given period A combustion plant is is any technical apparatus in which fuels are oxidised in order to use the heat thus generated. Boilers, turbines and engines. 6

7 gas combustion plant used for: - drying/treatment processes, crematoria - crematoria - waste incineration/co-incineration plant operating less than 500 hours pa inc solid fuel subject to dust limit till 1 January 2030: - plant over 5MW from which 50% of useful heat is provided to district heating schemes - solid biomass subject to limit of 150mg/m3 dust time limited exemptions to ELVs around district heating schemes in times of shortage of fuel 7

8 New plant: 1MW to 50MW installed or put into operation after 20 December 2018 (What exactly is new plant?) New burners + existing boiler shell? New flue gas recirculation system? ( Currently there is no provision for definition apart from a requirement to report changes to the equipment that might affect the emissions) Existing plant: 1MW to 50MW in operation before 20 December

9 Aggregation rule two or more new medium combustion plants emitting through a common stack will be considered to be a single plant Multi plant sites will need to look closely as they replace an individual piece of plant to see how the MCPD will affect them after the change. One thing to note is that aggregated plant 20MW and below is subject to triennial testing while aggregated plant over 20MW will be subject to annual testing 9

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11 Emission Limit Values are expressed as mg/nm 3 Emission Limit Values are expressed as mg/nm and defined temperature is temperature is K and 101.3kPa pressure standard oxygen content of 3% for liquid and gaseous fuels (6% for coal fired plant) Sampling body to be established Environment Agency is eager to see low risk plants (burning natural gas, LPG, or gasoil) receive a simple approach. Standard combustion tests and calibration cert of measuring device. Unusual fuels will almost certainly require MCERTS accredited testing. 11

12 Carbon monoxide emissions will be recorded for all installations but currently no limit has been proposed. 12

13 From 20 December 2018, NOx emissions from NEW medium combustion plant must not exceed the following ELVs 13

14 All plant new and existing will require a permit. installations between 1 MW and 20 MW will be inspected every 3 years to ensure compliance with the ELVs installations over 20 MW will be tested annually. Permits are currently predicted to cost between 90 and 310 highest risk plants paying up to 800 per year. One off registration fee around 200 for low risk plants, and up to 1600 for the highest risk plants. 14

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16 City of London Air Quality Strategy

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20 ascertain the ELV relevant for each fuel determine the fuel weighted ELV (obtained by multiplying each fuel s individual ELV by the thermal input delivered by each fuel) divide the product by the sum of the thermal inputs delivered by all fuels aggregate the fuel weighted ELVs 20

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22 burner design fuel type and composition boiler geometry operating temperature and pressure 22

23 Zone 1 A sub-stochiometric stochiometric combustion zone keeps flame temperatures low and forms a stable root to the flame. Zone 2 completing the combustion process whilst maintaining low flame temperatures. zone 3 Bluff body thermodynamics induce inert flue gases back into the core of the flame. This form of internal flue gas recirculation, slows the combustion process down further through oxygen reduction thus lowering the flame temperature and resulting NOx levels. 23

24 NOx Reduction Techniques Highly effective method for lowering NOx, 30mg/m³ (natural gas) Starves combustion process from oxygen thus reducing flame temperature and thermal NOx Simple set up with low complexity Simple set up with low complexity increased reliability Oxygen trim system to compensate for varying oxygen levels Variable FGR with butterfly valve Significant increase in fan size to compensate for lack of oxygen and increase in temperature Can be used in tight furnaces Stainless steel construction for both fan and burner construction Will achieve lower NOx levels compared to internal FGR Slide 24

25 NOx Reduction Techniques Same principle of operation as air vitiation Requires additional fan operating at high pressure to overcome burner head pressure Only the annulus on the burner needs to be from stainless steel Burner dimensions remain similar to those working at room temperature Oxygen trim system to compensate for varying oxygen levels Variable FGR, via damper or VSD Can be used in tight furnaces

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27 Three pass wet back Three pass Space saving three pass Reverse flame 27

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29 Process of checking that NOX claims are genuine, proven and can be consistently achieved Do not rely on datasheet information for NOx Check that NOx levels are referenced to an oxygen level Check that they are applicable to the operating pressure or temperature at which plant will be running Check at what firing rate they are being cited 29

30 Copenhagen district heating scheme 65mg/m 3% oxygen 30

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33 thermal input of plant in MW type of plant, type and share of fuels start date of operation NACE code expected operating hours per annum average load applicable ELVs signed declaration that the plant will be operated within applicable ELVs 33

34 proof of notification to the regulating authority proof of registration record of operating hours if claiming exemption record of fuels used For coal fired plant - record of any malfunctions or breakdowns of secondary abatement equipment 34

35 confirms registration within one month of notification non compliant operators suspend plant suspend plant operation- non compliant operators withdraw registration This regulator also has the power to assess whether or not more stringent ELVs are required in zones not compliant with existing Air Quality regulations. The authority is required to report MCPD emissions to DEFRA in 2021, 2026 and

36 1MW to 20MW measure and report NOx emissions at least every three years Operating hours are 3 times average operating house for plant <20MW When plant reach the operating hours for plant 20MW-50MW 20MW to 50MW measure and report annually Plant using multiple fuels measure the mix likely to emit highest NOx emissions and in normal operating conditions 36

37 Precise detail of how the Directive will be implemented in the UK has still to be determined The draft document will be published in October with the final document published November 2017 Who will carry out the testing? What are the penalties for non-compliance? 37

38 Bad news extra red tape extra time required for validating NOx claims UK local regulations more stringent than MPCD Good news proven combustion technologies already available processes available for checking accuracy and relevance of NOx emission claims relatively generous timescales for compliance 38

39 Fitness for compliance Not too early to start planning process for new or replacement combustion plant A man who does not plan long ahead will find trouble at his Confucius 400 BC 39

40 Thank you! 40