IChemE Webinar The Medium Combustion Plant Directive - what does it mean for UK industry? David Graham and Steve Griffiths November 2017

Transcription

1 IChemE Webinar The Medium Combustion Plant Directive - what does it mean for UK industry? David Graham and Steve Griffiths November 2017

2 We are Uniper Our operations: Where we operate: Employees: 12,635 Power Generation Commodity Trading Energy Storage Energy Sales Power generation, Storage, Services - Europe Power generation - International Commodity Trading, Energy Sales Energy Services 40+ countries around the world 4 th largest generator in Europe 2.12 bn EBITDA 100 years Experience 38.2 GW Total generation Main activities: Gas fired plants 19.2 GW Coal fired plants 10.5 GW Energy storage Gas fields Gas pipelines and Gas: 8.5 bn m 3 infrastructure Regasification Nuclear plants 1.9 GW Hydroelectric plants 3.6 GW Trading Energy sales (small to large clients, electricity and gas) Services 2 Data: Uniper Annual and Sustainability Reports 2016

3 Our energy services Air, Water and Land quality Bio-energy advice By-products management Climate change adaptation Environmental management systems Environmental regulatory risk Fuel management Noise Quantified risk assessment Regulatory emissions compliance

4 Why a Medium Combustion Plant Directive? Assessment of the need for MCP controls required by the Industrial Emissions Directive (IED) Recital (28): The combustion of fuel in installations with a total rated thermal input below 50 MW contributes significantly to emissions of pollutants into the air. With a view to meeting the objectives set out in the Thematic Strategy on Air Pollution, it is necessary for the Commission to review the need to establish the most suitable controls on emissions from such installations. Article 73(2) Review: The Commission shall review the need to control emissions from the combustion of fuels in installations with a total rated thermal input below 50 MW; The Commission shall report the results of that review to the European Parliament and to the Council accompanied by a legislative proposal where appropriate. 4

5 Why a Medium Combustion Plant Directive? REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL [COM(2013) 286 final] Emissions of the key atmospheric pollutants from combustion installations below 50 MW can be controlled and substantially reduced at EU level in such a way that the environmental and health benefits outweigh the compliance costs for operators Care needs to be taken in assessing potential options for a regulatory approach in order to avoid excessive administrative costs The most promising options for controlling emissions from combustion installations between 1 and 50 MW will be undertaken in the context of the air pollution policy review 5

6 Why a Medium Combustion Plant Directive? Environmental Impacts: EU 27 in 2010 Emissions Number of plants 6

7 Why a Medium Combustion Plant Directive? Total annualised costs for operators (2025) Gothenburg: EU wide ELVs for NO x, SO 2 and PM for both new and existing plants (including alignment with those set in the Gothenburg protocol) + exemption for limited number of operating hours 7

8 What is the Medium Combustion Plant Directive? New European Directive to control emissions from Medium Combustion Plants ( 1MW th to < 50MW th ) Entered into force on 19 Dec 2015 Must be transposed into Member State law by 19 Dec 2017 Sets Emission Limit Values (ELVs) for: New combustion plants 1MW th (aggregated) from the start of operations (post 20 Dec 2018) Existing combustion plants of >5MW th to < 50MW th from 1 January 2025 (individual units) Existing combustion plants of 1MW th to 5MW th from 1 January 2030 (individual units) Out of scope: IED Ch III (LCP) and Ch IV (WI); directly fired plants; propulsion (vehicles); Non-Road Mobile Machinery; research, development and testing activities 8

9 What is a Medium Combustion Plant? Existing vs New Permit granted Start of operation MCPD status Any time After 20 Dec 2018 NEW Before 19 Dec Dec 2018 or before EXISTING New MCPs may be bigger than 50 MW th The aggregation rule for new combustion plants is defined in Article 4 as follows: A combination formed by two or more new medium combustion plants shall be considered to be a single medium combustion plant for the purposes of this Directive and their rated thermal input shall be added together for the purpose of calculating the total rated thermal input of the plant, where the waste gases of such medium combustion plants are discharged through a common stack, or taking into account technical and economic factors, the waste gases of such medium combustion plants could, in the judgement of the competent authority, be discharged through a common stack. 9

10 Overlap with IED Chapter II Courtesy of EDF 10

11 Aggregation Examples Stack xx Existing unit (XX MW th ) xx New unit (XX MW th ) Plant Regulated as Notes x 20 MW th MCPs Both existing 2 x 20 MW th MCPs 1 existing, 1 new 1 x 40 MW th MCP New 1x10 MW th & 1x 45 MW th MCP Both existing 1 x 55 MW th MCP New 1 x 55 MW th LCP & 1x10 MW th MCP No aggregation of existing plants No aggregation of existing with new plants Aggregation rule applies for new plants Below IED Ch III threshold of 50 MW th due to 15MW th minimum for IED aggregation. Subject to IED Ch II as above site threshold of 50MW th. As above, but subject to MCPD new plant aggregation rule. 1 unit above IED Ch III threshold. 1 unit below 15MW th minimum for IED aggregation. 1 x 60 MW th LCP Aggregated value > IED Ch III threshold, so regulated as LCP

12 Permitting / Registration requirements Member States set up the appropriate permitting or registration regime to ensure MCPD compliance Operators are obliged to inform the Competent Authority of the operation, or intention to operate, any MCP providing a defined list of information (MCPD Annex I) MCPs covered by the IED will not need a separate permit. Where the Annex I information is not covered by the existing IED permit, this will need to provided 12

13 MCP Registration or Permitting Operators must provide the following information when registering Rated thermal input (MW) of the MCP Type of MCP: diesel engine; gas turbine; dual fuel engine; other engine or other medium combustion plant Type and share of fuels used by fuel category: solid biomass; other solid fuels; gas oil; other liquid fuels; natural gas; other gaseous fuels Date of the start of the operation Activity sector of the MCP or the facility in which it is applied (NACE code) Expected number of annual operating hours and average load in use Signed declaration that the MCP will not be operated > 500h/a (as applicable) Name and registered office of the operator and the address where the plant is located. 13

14 Emission Limit Values The MCPD sets out ELVs for SO 2, NO x and dust in Annex II ELVs are defined by technology, thermal rating and fuel type For boilers, ELV tables are split into 1-5MW th and 5-50MW th size ranges for existing plants only For engines and gas turbines a single ELV table applies for 1-50MW th Footnotes set different ELVs for specific circumstances Stricter ELVs may be set when air quality limit values are exceeded 14

15 Emission Limit Values - Gas Turbines mg/m 3 at 273K, kpa, 15% O 2 for gas turbines NEW plants EXISTING plants 15

16 Emission Limit Values - Boilers mg/m 3 at 273K, kpa at: 3% O 2 for gas and oil fired boilers and 6% O 2 for solid fuel fired boilers NEW plants 16

17 Emission Limit Values - Boilers EXISTING plants: 1 MW th to 5 MW th EXISTING plants: > 5 MW th to < 50 MW th 17

18 Emission Limit Values - Engines mg/m 3 at 273K, kpa, 15% O 2 for recip engines Engine Emission Limit Values are subject to complex derogations For NEW plants, NO x ELVs are 95 mg/m 3 for natural gas firing and 190 mg/m 3 for liquid fuel firing For existing plants, NO x ELVs are 190 mg/m 3 for all fuels. SO 2 ELVs apply to engines firing liquid fuels other than Gas Oil and gaseous fuels other than natural gas. Dust ELVs apply to engines firing liquid fuels other than Gas Oil 18

19 Emission Limit Value - optional derogations The following plants can be excluded from ELV compliance: Existing MCPs which do not operate more than 500 hours per year as a 5 year rolling average (a dust ELV still applies for biomass and other solid fuels) New MCPs which do not operate more than 500 hours per year as a 3 year rolling average (a dust ELV still applies for biomass and other solid fuels) Temporary derogation from ELV compliance may be granted: For up to 6 months where an MCP using low sulphur fuel cannot comply with the SO 2 ELV due to an interruption in supply resulting from a serious shortage For up to 10 days where an MCP using gaseous fuels has to resort exceptionally to the use of other fuels due to a sudden interruption in supply 19

20 Monitoring Requirements (MCPD Annex III) Periodic manual monitoring - annual or 3-yearly Existing plants - first measurement within 4 months of permit/registration New plants - first measurement must be carried out within 4 months of the start of operations Every 3 years for 1-20MW th Every year for >20MW th For all pollutants for which an ELV is set out by the MCPD and for CO For plants utilising the 500 hour exemptions, alternative frequencies may be applied Periodic measurements must not exceed the ELV in order to demonstrate compliance 20

21 Monitoring Requirements Monitoring methods must enable reliable, representative and comparable results harmonised EN standards are presumed to meet this requirement The plant must be operating under stable conditions at a representative even load (excluding start-up and shut-down) Other procedures verified and approved by the Competent Authority may be used to determine SO 2 emissions (e.g. calculations based on fuel sulphur content) In the event of non-compliance, operators must ensure that compliance is restored within the shortest possible time Where non-compliance causes a significant degradation of local air quality, operation must be suspended 21

22 MCPD Compliance - UK situation Large numbers of plant (~10,000 to 16,000 in UK) Service organisations already perform frequent emissions checks (e.g., once/twice per year) using existing equipment standards: EN 50379:2012 Specification for portable electrical apparatus designed to measure combustion flue gas parameters of heating appliances. Part 1 General requirements and test methods Part 2 Performance requirements for apparatus used in statutory inspections and assessment Part 3 Performance requirements for apparatus used in non-statutory servicing of gas fired heating appliances Most of these organisations operate to a recognised QA standard on Environmental Management 22

23 Key Dates 19 Dec 2015 Entry into force 19 Dec 2017 Member State Transposition 20 Dec 2018 ELV compliance of new MCP 1 Jan 2020 Commission review of need to set MCP energy efficiency standards 1 Jan 2021 Member State summary reporting of MCP CO emissions data 1 Jan 2023 Commission review of new plant ELVs and need to regulate CO 1 Jan 2024 Existing plant > 5 MW th registration deadline 1 May 2024 Existing plant > 5 MW th first measurement deadline 1 Jan 2025 Existing plant > 5 MW th ELV compliance starts 1 Oct 2026 Existing plant > 5 MW th Member State implementation report 1 Jan May Jan 2030 Existing plant 1-5 MW th registration deadline Existing plant 1-5 MW th first measurement deadline Existing plant 1-5 MW th ELV compliance starts, >5MWth exemptions lapse 1 Oct 2031 Existing plant 1-50 MW th Member State implementation report 1 Jan 2033 Commission review of ELVs (repeats every 10 years) 23 23

24 Specific derogations in England & Wales 500h exemptions - implemented as a 5-year (existing plant) or three year (new plant) rolling average Biomass plants delayed dust ELVs - not implemented District heating delayed ELVs - not implemented Small and Micro Isolated Systems delayed ELVs - implemented Gas compressor stations > 5MW th - delayed ELVs - implemented Compliance approach and detailed monitoring requirements not yet defined national guidance will follow 24

25 Specific additions in England & Wales Substantial growth in arrays of new-build diesel and gas reciprocating engines in recent years under Electricity Market Reforms Individual units often < 5MW th so unregulated until 2030 HMG concerned over consequential environmental impacts New Recips securing contract in Capacity Market Auctions 2014 &

26 Specific additions in England & Wales HMG is introducing new requirements for all MCPs which are electricity generators and operate > 50 hours/year Plants which began operation on or after 1 Dec 2016 must meet NO x emission limit of 190 mg/nm 3 from 1 Jan 2019 Emission level must be achieved within 10 minutes where secondary abatement is required Capacity Market 2014/15 plants exempted from additional requirements until end of their contract provided that the scope of supply is not subsequently changed but. Plants emitting > 500 mg/nm 3 NO x must assess their air quality impacts and operating hour restrictions may be imposed (> 5MW th aggregated) Environment Agency will regulate all Medium Combustion Plants including generators 26

27 Conclusions MCPD is a new European directive requiring emissions compliance with ELVs for NO x, SO 2 and dust for plants with combustion units in the size range 1 to 50 MW th (>10,000 plants in the UK) Medium Combustion Plants with limited annual operation are largely exempt from ELVs (< 500 hours/year) Overlap with legislation affecting large sites regulated under the IED Periodic monitoring is required (also for CO) within 4 months of permitting/registration possible scheduling difficulties Detailed monitoring requirements and compliance assessment approach to be developed in later guidance Scope of regulation extending to all small generators in England & Wales operating for > 50 hours/year 27

28 Thank you! If you need any further information, please contact: or David Graham & Steve Griffiths Uniper Technologies Technology Centre, Ratcliffe-on-Soar Nottingham NG11 0EE Tel Tel Uniper disclaimer: This presentation may contain forward-looking statements based on current assumptions and forecasts made by Uniper SE management and other information currently available to Uniper. Various known and unknown risks, uncertainties and other factors could lead to material differences between the actual future results, financial situation, development or performance of the company and the estimates given here. Uniper SE does not intend, and does not assume any liability whatsoever, to update these forward-looking statements or to conform them to future events or developments.