CEM 2020

CEM 2018 - Abstract

Abstract Title: Emissions Regulation within the European Union
Abstract Type: Seminar
Session Choice: Emission regulation and future monitoring challenges
Presenter Name: Mr David Graham
Co-authors:Mr Frans Blank
Company/Organisation: Uniper
Country: United Kingdom

Abstract Information :

This paper provides an overview of existing and forthcoming environmental legislation within the European Union (EU) and focusses on compliance with Emission Limit Values (ELVs), start-up and shut-down provisions and emissions monitoring requirements.

The EU's Industrial Emissions Directive (IED) came into force for existing plants on 1January 2016. All combustion plants with an aggregated thermal input ≥ 50 MWth must comply with general permitting requirements and apply Best Available Techniques (BAT). Large Combustion Plants (LCPs) must comply with specific additional provisions, noting that ELVs are defined, as a minimum standard, for NOx, SO2, Dust and CO (gas fired plants only). Start-up and shut-down requirements are defined in a separate EU Implementing Decision.

The IED also requires permit conditions to be based upon more stringent Associated Emission Levels (AELs) defined in the applicable BAT Reference Note (BREF) which was finalised, for Large Combustion Plants, in December 2017 with compliance for existing plant being required by August 2021. The BREF defines more stringent monitoring requirements and addresses a wider range of pollutants from solid fuel fired plant, including mercury, HCl, HF and NH3. Flue gas flow rate measurement is included, as a peripheral measurement, for the first time in EU primary legislation.

The EU's Medium Combustion Plant Directive (MCPD) was published in November 2015 and had to be transposed into Member State law by 19 December 2017. The MCPD applies to existing individual plants in the net thermal input range 1 to 50 MWth and all new aggregated plants above 1 MWth which results in regulatory overlap with the IED. ELVs for NOx, SO2 and Dust (as appropriate to the combustion technology) apply to new MCPs from 20 December 2018 and to existing MCPs from 1 January 2025 or 1 January 2030, depending on plant size. There are generic derogations for plants that operate for less than 500h per year. Compliance is based on periodic monitoring and CO must also be measured even though ELVs are not defined. There are likely to be practical difficulties relating to the scheduling of emissions monitoring within four months of plant registration/permitting given the anticipated large number of plants affected.