THE SOURCE TESTING ASSOCIATION ANNUAL GUIDE 2012
The impact of the Industrial Emissions Directive on Source Testing at Large Combustion Plant
David Graham, STA Process Operators Chairman, E.ON New Build & Technology
he Industrial Emissions Directive (IED), published in December 2010, replaces numerous European Directives that govern the environmental regulation of process plant. The IED applies to new combustion plant permitted from 7 Jan 2013 and the remaining existing combustion plant from 1 Jan 2016 with some permitting aspects applying from 7 Jan 2014.
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This article summarises the key requirements of the IED in relation to both environmental control and emissions monitoring for large combus- tion plant. Whilst the monitoring requirements are broadly similar to before, there has been a harmonisation of approach that will make it easier to apply CEMs Quality Assurance (QA) standards. However, reductions in emission limit values have an impact on QA and there are some new requirements for both continuous and periodic monitoring.
General provisions
The over-arching objectives of the Industrial Emissions Directive (IED) are the protection of human health and the environment, and the improvement of environmental quality, by controlling the emissions from industrial activities. The IED takes an integrated approach to the prevention and control of emissions to air, water and land in addition to waste management, energy efficiency and accident prevention. The IED supersedes and harmonises the requirements of the Integrated Pollution Prevention and Control (IPPC) Directive and those of six other Directives related to industrial emissions, including the Large Combustion Plant Directive (LCPD) and the Waste Incineration Directive (WID).
The major provisions of the IED, listed in Chapters I & II, include: the permitting of installations; the setting and updating of emission limit values (ELVs) to be based on Best Available Techniques (BAT); the establishment of BAT reference documents (BREFs) and the formulation of BAT Conclusions that summarise the BREFs and are the basis for compliance. In circumstances where the application of BAT would result in disproportionately high costs, when compared with the environmental benefit, deviations from BAT are allowed from a specific site provided that the mandatory ELVs defined in the IED are not exceeded. The IED applies integrated pollution control to a wide range of industries previously covered by the IPPC Directive, including the Energy industries (combustion and gasification). With regards to combustion plant, the IED applies to installations with a total (combined) rated
6 Source Testing Association Annual Guide 2012 thermal input ≥ 50MW.
Chapter III defines special provisions for large combustion plant and Chapter IV defines special provisions for waste incineration plant. Chapters V and VI apply to the solvents and titanium dioxide industries and these will not be considered further here.
Chapter VII requires each Member State to regularly report on
the effectiveness of the IED implementation in relation to BAT and the setting of ELVs. IED mass emissions inventory reporting for large combustion plant is also required. The Large Combustion Plant Directive is repealed from 1 Jan 2016 and is no longer applied from 7 Jan 2013 for new plant. The remaining Directives, including the IPPC Directive and the Waste Incineration Directive, are repealed from 7 Jan 2014. By 31 Dec 2012, the Commission will also review the need to con- trol emissions from smaller combustion installations with an aggregated thermal input below 50MW.
Provisions for Large Combustion Plant The requirements of Chapter III of the IED, and the mandatory minimum ELVs defined in Annex V, apply to individual stationary large combus- tion plant with a rated thermal input ≥ 50MW, subject to specified aggregation rules. Chapter III does not apply to direct heating, drying or heat treatment processes or gas turbines and engines used on offshore platforms.
Emission Limit Values (ELVs) are defined for SO2 , NOx and Dust for
plant fired by solid and liquid fuels. For gas fired plant, ELVs are also defined for CO. For gas turbines, ELVs are specified for NOx and CO
IED Annex V ( > 300 MW thermal input ) Existing Plant (part 1) Solid fuel 200
SO2 NOx
Dust CO
Ref O2 dry
200 20
- 6%
150 20
- 3%
only. ELVs apply during normal operation only (excluding start-up and shut-down periods).
Existing plant should not exceed the limit values defined in Part 1 of Annex V from 1 Jan 2016. Existing plant are those permitted before 7 Jan 2013 - or those for which the complete permit application has been submitted before that date and which commence operations by 7 Jan 2014.
New plant, permitted from 7 Jan 2013, should not exceed the more stringent limit values defined in Part 2 of Annex V which defines ELVs for different sizes of large combustion plant, based on aggregated thermal input. As an example, the ELVs for both new and existing plant greater than 300 MW thermal input, e.g., large utility boilers, are given in Table 1. This is an overview only since the ELV varies somewhat for specific fuels and technology types. There are additional provisions for plant that operate for less than 1500 hours per year as a five year rolling average. In broad terms, the existing plant limit values are about 50% of the current LCPD values and this has implications for monitor- ing as discussed later. There are obviously large costs associated with the installation of the necessary control technologies such as Selective Catalytic Reduction (SCR) for NOx and Flue Gas desulphurisation (FGD) for SO2
, if not already fitted.
Under the LCPD, emission limit values are not defined for existing gas turbines (permitted before 27 Nov 2002) and limit values are defined for new turbines only.
This is different under the IED; for existing large gas turbines, the baseline NOx limits are defined in Table 2. However, there is also an
Liquid fuel 200
Natural gas 35
100 5
100 3%
Table 1 Mandatory Emission Limit Values for large boilers and furnaces
New Plant (part 2) Solid fuel 150
150 10
- 6%
Liquid fuel 150
100 10
- 3%
Natural gas 35
100 5
100 3%
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