THE EUROPEAN UNION’S MEDIUM COMBUSTION PLANT DIRECTIVE – MONITORING AND COMPLIANCE REQUIREMENTS
The European Union’s Medium Combustion Plant Directive (MCPD) entered into force in December 2015 and this must be transposed into national legislation within each of the Member States by 19 December 2017. The MCPD applies to existing individual Medium Combustion Plants (MCPs) in the net thermal input range 1 to <50 MWth and new aggregated plants above 1 MWth potentially aggregating to more than 50 MWth (provided that these do not qualify as a Large Combustion Plant under the Industrial Emissions Directive). Emission Limit Values are defi ned for NOx
, SO2 and dust for both conventional combustion plants and gas turbines and engines, excluding
start-up and shut-down periods. These limits will be applied to new MCPs from 20 December 2018 and to existing MCPs from 1 January 2025 (> 5 MWth) or from 1 January 2030 (1 to 5 MWth).
Periodic monitoring is required annually for MCPs > 20 MWth and three-yearly for smaller MCPs and all pollutants with specifi ed Emission Limit Values and CO must be monitored. Optional exemptions are provided for MCPs that operate for no more than 500 hours per annum, district heating plants and isolated plants in remote locations and for those subject to interruption of their regular fuel supply. However, more stringent requirements can be imposed on MCPs within Air Quality exceedance zones.
There are signifi cant implementation challenges associated with the assessment and demonstration of compliance and also the suitability and scheduling of manual periodic measurements following plant registration or permitting.
Scope of the Medium Combustion Plant Directive
The MCPD nominally applies to Medium Combustion Plants (MCPs) in the thermal input size range ≥ 1 to < 50 MWth. The thermal input is assumed to be based on the net calorifi c value of the fuel (the lower heating value) in line with other European legislation.
Most stationary combustion plants are in scope of the MCPD, including boilers, engines and turbines, except for Large Combustion Plants (regulated under Chapter III of the Industrial Emissions Directive (IED) and waste incineration plants (regulated under Chapter IV of the IED). Mobile generating units covered by the Non-Road Mobile Machinery Directive are also exempt from scope.
Emission Limit Values (ELVs) are defi ned for nitrogen oxides (NOx sulphur dioxide (SO2
(with the exception of gas oil). Only NOx natural gas and gas oil fi red MCPs.
),
) and dust for solid and liquid fuel fi red MCPs ELVs are specifi ed for
A new plant is defi ned as an MCP that is put into operation on or after 20 December 2018 whilst an existing plant is an MCP operating before that date. ELV compliance is required from 20 December 2018 for a new plant and from 1 January 2025 for an existing plant (> 5 to < 50 MWth) or from 1 January 2030 (≥ 1 to ≤ 5 MWth).
Existing MCPs are regulated as individual units whilst new MCPs are regulated as aggregated units at stack level. As the IED excludes units smaller than 15 MWth when deciding on Large
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Combustion Plant (LCP) status, a new MCP, which includes units smaller than 15 MWth, may therefore aggregate to more than 50 MWth without being classed as an LCP.
Any MCP located on an IED regulated site will fall within the scope of the IED general provisions, creating a regulatory overlap; however, it is clear that any MCPs in this category will be permitted under the IED with MCPD emission limit values also applying as a minimum requirement.
Registration or Permitting
MCPs must be either registered or permitted, as determined by each Member State, before fi rst operation for a new MCP, or at least one year prior to the required ELV compliance date for existing MCPs.
Operators must provide the following information when registering or applying for a permit:
• Rated thermal input 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 > 500 hours per annum (if applicable)
• Name and registered offi ce of the operator and the address where the plant is located.
Emission Limits Values (ELVs)
Certain ELV compliance exemptions apply to all classes of MCP. Those located in the Canary Islands, French Overseas Departments, the Azores and Madeira are indefi nitely and fully exempted from ELV compliance. Gas fi red MCPs that suffer a fuel supply interruption may be exempted when fi ring alternative fuels
NOx SO2
Dust
that would require secondary abatement to comply with the applicable ELVs (for ten days interruption unless the operator can demonstrate to the Competent Authority that a longer period is justifi ed). MCPs that normally fi re low sulphur fuel may similarly be exempted from their SO2
ELVs for a maximum of six months if
there is an interruption in the supply of low sulphur fuel due to a serious shortage.
In addition to these exemptions, there are a number of other optional exemptions that a Member State may or may not adopt. For existing plants, the main provision is an exemption from ELVs for plants operating ≤ 500 hours per annum, as a rolling average over fi ve years, subject to meeting a dust ELV of 200 mg/m3
for
plants fi ring solid fuels. This may optionally be extended to 1000 hours for heating plants during exceptionally cold weather events.
There are also time limited derogations for Isolated Systems (applicable to island communities), district heating systems and gas compressor stations within national transmissions systems noting that, in some cases, less stringent ELVs are imposed.
For new plants, the main optional exemption is again available for plants operating < 500 hours per annum, as a rolling average over three years, subject to meeting a dust ELV of 100 mg/m3
for MCPs
fi ring solid fuels. There is also an optional series of derogations, specifying less onerous NOx
ELVs, for engines operating between
500 and 1500 hours per annum dependent upon engine type and fuelling. This provision for new engines is surprising given that there is no equivalent provision for existing engines.
The most important ELV provisions are described below by technology type.
Gas turbine Emission Limit Values are given in Table 1 for new plants and in Table 2 for existing plants in mg/m3
at 15% O2
273K, 101.3 kPa. NOx there are higher SO2
for small MCPs. Table 1 Gas Turbine ELVs for NEW plants
Natural Gas
50 - -
Other
Gaseous 75
15 -
Gas Oil 75 - -
Other Liquid
75
120 10
, dry,
ELVs are only applicable over 70% load and ELVs specifi ed for biogas and higher dust ELVs
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