Air quality and Emissions Regulation

Transcription

1 Air quality and Emissions Regulation Renewable Energy Association Landfill Gas Group meeting Matt Stoaling, Isopleth Ltd.

2 Scope Pollution from combustion sources: Spark Ignition Engines (LFG and Biogas); Combined Heat and Power (CHP); Biomass Boilers; Gas Turbines. Not Fugitive Emissions (Environmental Permitting)

3 Air Quality Regulations European AQ Directive 2008 ambient air quality Directive (2008/50/EC) Until exit negotiations are concluded, the UK remains a full member of the European Union and all the rights and obligations of EU membership remain in force. During this period the Government will continue to negotiate, implement and apply EU legislation. The outcome of these negotiations will determine what arrangements apply in relation to EU legislation in future once the UK has left the EU.

4 Limits

5 AQ Standards* [Standards / Limits / Objectives / EALs] Of most relevance to combustion plant: Nitrogen dioxide (NO 2 ) Carbon Monoxide (CO) Sulphur dioxide (SO 2 ) Particulate Matter (PM 10, including PM 2.5 ) Both long and short term impacts are important.

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8 Assessment Methods

9 AQ Assessment: Screening

10 AQ Assessment: Modelling

11 Impact Interpretation Averaging times: Short term (all locations possibly) Long term (residences) Impacts and Backgrounds Process Contribution (PC) Predicted Environmental Concentration (PEC)

12 Ecological Receptors European (SAC, SPA etc) National (SSSI, Ancient Woodland) Local (LWS) Impacts (NOx and SOx): Concentration (Critical Loads) Critical Levels

13 Emissions

14 MEDIUM COMBUSTION PLANT Medium Combustion Plant (MCPs) falls between 1 and 50MWth. MCPs are used to generate heat for large buildings (offices, hotels, hospitals, prisons) and industrial processes, as well as for power generation. DEFRA estimates that there are over 30,000 plant in England and Wales. Of these, 9,000 are routinely operated MCPs with the remaining MCPs being standby and back-up, which operate infrequently.

15 MEDIUM COMBUSTION PLANT DIRECTIVE (MCPD) Operators will be required to obtain an environmental permit under the EPR in order to operate an MCP. From 20 December 2018: operators of all new plants (plants that are not already in operation as at that date) will need a permit operators of existing plants (those in operation by 20 December 2018) must obtain a permit by January 2024 if over 5MWth and by January 2029 if between 1 and 5MWth. For MCPs which are part of other regulated facilities, the conditions of the existing permit may need to be amended to apply the requirements of the MCPD.

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17 UK: Differences The UK and Welsh Governments have recently amended the current England and Wales environmental permitting regime to implement the MCPD and introduce additional emissions controls for generators. Scotland and Northern Ireland will lay their own legislation to transpose the MCPD. The Scottish Government is still reviewing the case for adopting emissions controls for generators.

18 Operator Responsibilities Obtain and maintain the required permits Monitor emissions* Record information regarding operation of the plant and any secondary abatement [*At the required frequency (including within 4-months of registration/ permitting) to ensure plants meet the ELV s and keep non-compliance to a minimum. The monitoring standards are currently proposed to be the EA s MCERTS standards which will require adequate access to the flues.]

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21 Monitoring Requirements The specific monitoring requirements and applicable ELV s (Emission Limit Values) vary depending on: the type of appliance (i.e. boiler, turbine or engine); its capacity; the fuel (solid, biomass, liquid or gas); and annual average operating hours.

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23 Limits: Normalisation All emission limit values set out in the Annex are defined at a temperature of 273,15 K, a pressure of 101,3 kpa and after correction for the water vapour content of the waste gases; and at a standardised O 2 content of: 6 % for medium combustion plants using solid fuels, 3 % for medium combustion plants, other than engines and gas turbines, using liquid and gaseous fuels and 15 % for engines and gas turbines.

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26 Conversions Converting 5% O 2 to 15% O 2 (dry, 0degC, 1atm): 95 mg/nm 3 at 15% 256 mg/nm 3 at 5% 190 mg/nm 3 at 15% 512 mg/nm 3 at 5% (factor 2.7)

27 (Possible) Exemptions MCPD contains a number of flexibilities and exemptions - DEFRA are consulting on how it intends to implement these. DEFRA may exempt plant which are operational for <500 hours per annum (as a rolling average over 5 years) from complying with the ELV s. Older stand-by plant are unlikely to have to be upgraded to meet the MCPD requirements if this is the case but may have to assessed for impacts. Excluded generator means generators subject to the provisions of Chapter II or Chapter III of the Industrial Emissions Directive. Chapter II covers Annex 1 activities (such as landfill).

28 Whilst older (Tranche A) generators will not need to comply with the MCPD ELV s until 2025 or 2030, if the NOx emission is >500mg/Nm3 (which is highly likely for all diesel powered generators), then a site specific assessment of the impact of emissions will be carried out. Similarly, back-up plant being tested for >50- hours per annum will also require a site-specific air quality assessment.

29 What does this mean for you? New regulator? (probably not for waste sites) More stringent regulations / emission limits? NOx (probably not for most newer LFG engines) and SOx (yes) Different pricing structure (permitting)? More onerous monitoring? (probably not for well run LFG installations) (*Clarification required on relocation)

30 (Thanks for listening)