This presentation 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) as defined in Ch II of the IED.
Large Combustion Plants (LCPs) must comply with specific Ch III and Annex V 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. Incineration and co-incineration plants must comply with specific Ch IV and Annex VI provisions
The IED also requires permit conditions to be based upon more stringent Associated Emission Levels (BAT-AELs) defined in the applicable BAT Reference Notes (BREFs). The BAT Conclusions for Large Combustion Plants were published on 17 August 2017 with compliance for existing plant being required within four years. The LCP 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 Waste Incineration (WI) BAT Conclusions were published on 12 November 2019 with compliance for existing plant again being required within four years. The WI BREF again specifies BAT-AELs for a wide range of pollutants that must be considered when burning either hazardous or non-hazardous waste.
For both plant types, the BAT-AEL is defined as a concentration range from which the Member State determines the Emission Limit Value for a given plant or sub-category of plants. However, at the lowest concentrations, the measurement uncertainty for a given pollutant can dominate the compliance assessment which is the responsibility of each Member State. Different approaches are being developed to address these issues, e.g., employing fixed absolute uncertainties for assessing compliance. However, it is clear that improvements in the underpinning calibration methods are urgently required in order to improve the Quality Assurance of monitoring in a low emissions world.
This contribution is submitted on behalf of the VGB Technical Group: Emissions Monitoring.