The time-line for MCPD implementation is shown in the figure.


Monitoring Requirements


Periodic monitoring of the pollutants for which ELVs are defined is required every three years for MCPs ≥ 1 to ≤ 20 MWth and every year for MCPs > 20 MWth. Monitoring is always required for carbon monoxide (CO) even though this is not subject to an Emission Limit Value. Plants that operate for ≤ 500 hours per annum with an ELV exemption are not exempted from the monitoring requirements but the frequency at which monitoring is required, which is based on cumulative operating hours, is not entirely clear.


Table 2 Gas Turbine ELVs for EXISTING plants Other


Natural Gas


NOx SO2


Dust


150 - -


Gaseous 200 15 -


First monitoring is required within four months of the plant being permitted/ registered, for existing plants, or prior to starting operation, for new plants. If


Gas Oil


200 - -


Other Liquid


200 120 10


Combustion plants - other than gas turbines and engines - have Emission Limit Values as shown in Table 3 for new plants and Table 4 for existing plants in mg/m3


at 3% O2


and liquid fuel firing and at 6% O2 solid fuels. There are various SO2


, dry at 273K, 101.3 kPa for derogations for plants firing


woody biomass, straw, biogas, coke oven gas, blast furnace gas and other solid fuels and also for Heavy Fuel Oil (HFO) firing on existing small MCPs until 2030, noting that secondary abatement would be required to meet the HFO ELVs. There are also various dust derogations for existing plants firing biomass, other liquid and other solid fuels.


Table 3 Boiler/Other Combustion Plant ELVs for NEW plants


Natural Gas


NOx SO2


Dust


100 - -


Other Gaseous


Gas Oil


Other Liquid


Solid Biomass


Other Solid


200 200 300 300 300 35 -


20 20


Table 4 Boiler/Other Combustion Plant ELVs for EXISTING plants ≥ 1 MWth to ≤ 5 MWth


Natural Gas


NOx SO2


Dust


250 - -


Natural Gas


Dust


200 - -


Other Gaseous


Gas Oil


Other Liquid


Solid Biomass


Other Solid


250 200 650 650 650 200 -


50 50 50


> 5 MWth to < 50 MWth Other


Gaseous


NOx SO2


Gas Oil


Other Liquid


Solid Biomass


- 350 200 1100 -


Other Solid


250 200 650 650 650 35 -


30 30 30


Engine Emission Limit Values are subject to complex derogations. In broad terms, the NOx


ELVs for new plants are 95 mg/m3 natural gas firing and 190 mg/m3 for for liquid fuel firing at 15% O2 ,


dry, 273K, 101.3 kPa. For existing plants, the NOx ELV is 190 mg/m3 for all fuels. There are SO2


than Gas Oil and gaseous fuels other than natural gas. Also, dust ELVs for engines firing liquid fuels other than Gas Oil.


In geographical zones that are not compliant with the EU’s Ambient Air Quality Directive Member States must assess the need to apply stricter ELVs provided that these would contribute to a ‘noticeable improvement in air quality’. The emission levels associated with best available and emerging technologies must be taken into account when assessing the need for stricter ELVs, following an information exchange with Member States, industry and non-governmental organisations (time-scales unspecified).


ELVs for engines firing liquid fuels other


- 350 200 400 -


The Source Testing Association


The Source Testing Association (STA) was established in 1995 the membership comprises representation from process operators, regulators, equipment suppliers and test laboratories. The STA is a non-profit making organisation. The STA is committed to the advancement of the science and practice of emission monitoring and to develop and maintain a high quality of service to customers.


Its aims and objectives are to:


(i) contribute to the development of industry standards, codes, safety procedures and operating principles; (ii) encourage the personal and professional development of practicing source testers and students; (iii) maintain a body of current sampling knowledge; (iv) assist in maintenance of a high level of ethical conduct;


(v) seek co-operative endeavours with other professional organisations, institutions and regulatory bodies, nationally and internationally, that are engaged in source emissions testing. The Associations headquarters are based in Hitchin, Hertfordshire with meeting rooms, library and administration offices. The Association’s offers a package of benefits to its members which include: • Technical advice relating to emission monitoring • Conference and exhibition opportunities • Seminars and training on a variety of related activities • Representation on National, European and International standards organisations • Training in relation to many aspects of emission monitoring • Liaison with regulators, UK and International, many of whom are members.


Contact details Address: Unit 11 Theobald Business Centre, Knowl Piece, Wilbury Way, Hitchin, Herts SG4 0TY Telephone: +44(0) 1462 457535 Facsimile: +44(0) 1462 457157 Email: General Enquiries sam@s-t-a.org Technical support andy@s-t-a.org steve@s-t-a.org Web site: www.s-t-a.org Contacts: General Enquiries Samantha Harvey Technical Support Andrew Curtis or Dave Curtis


Author Contact Details David Graham and Steve Griffiths. Uniper Technologies • Technology Centre, Ratcliffe-on-Soar, Nottingham NG11 0FE Tel 02476 192688 • Email: stephen.griffiths@uniper.energy • Web: www.uniper.energy


- 350 200 400 - 20


early registration is not allowed then all of the required monitoring for existing plants would be limited to a four month window and would need to be repeated in the same time frame either one or three years later. This is clearly unworkable, given the likely number of MCPs within Europe (hundreds of thousands). Early registration/permitting should therefore be encouraged.


, dry, for natural gas


With regards to test methods: ‘Sampling and analysis … shall be based on methods enabling reliable, representative and comparable results … EN standards shall be presumed to satisfy this requirement ….the plant shall be operating under stable conditions at a representative even load … start-up and shut-down periods shall be excluded’


There is therefore not an absolute requirement to use ISO 17025 accredited test laboratories or CEN standards (the Standard Reference Methods for NOx


, SO2 , CO and dust are defined by


individual CEN standards). However, if these are employed they will automatically satisfy the MCPD monitoring requirements. In any case, the equipment specified for manual dust measurement, and some of the detailed test procedures within the relevant CEN standard, are not suitable for application on plants that are smaller than 20 MWth and further guidance will be required.


In many Member States, boiler emissions are already measured during annual or six-monthly service visits using equipment that is certified to appropriate CEN standards that apply to boiler testing. Provided that the procedures, staff training and quality systems that underpin these measurements are robust and can satisfy the MCPD requirements, it may be possible to use such an approach, at least for plant ≤ 20 MWth. This would also share the burden with regards to the scheduling of test work.


The MCPD does allow Competent Authorities to specify


continuous monitoring, as an alternative to periodic monitoring, although this would normally require calibration according to EN 14181using Standard Reference Methods.


Operators with abatement equipment are expected to define how they will demonstrate that this equipment continues to operate effectively which could, for example, include continuous indicative dust monitoring.


Concluding Remarks


The Medium Combustion Plant Directive is intended to improve air quality and reduce the impacts of pollution on human health by controlling emissions to air from medium sized stationary combustion plant, much of which is located in urban areas, notwithstanding the fact that mobile sources (the transport sector) are responsible for the bulk of these impacts.


Whilst the MCPD defines Emission Limit Values for key pollutants, and periodic monitoring requirements, the method for assessing compliance is not clearly defined. This will be particularly challenging for aggregated MCPs with different types of combustion units, possibly operating at different times, that are exhausting through a common stack and also for units fitted with pollution abatement equipment since the operator is required to demonstrate that the abatement is continually effective.


Monitoring requirements are also not defined in detail, requiring national guidance on which equipment, methods and quality assurance systems will be needed in order to demonstrate compliance. In the case of dust measurement, the applicable CEN standard defines sampling equipment for Large Combustion Plant that is not suitable for Medium Combustion Plant.


The Member State may elect to either simply register or grant a permit for a Medium Combustion Plant. However, the first emissions monitoring must be conducted within four months of either registration or permitting. This presents enormous practical challenges in relation to the scheduling and resourcing of periodic monitoring and some means of spreading the monitoring burden, such as early registration for existing plants, needs to be found. The frequency of monitoring is also unclear for plants operating for less than 500 hours per annum.


With regards to future developments, the European Commission will review the need to revise Emission Limit Vales for new plants, and whether or not there is a need to regulate CO emissions, by 1 January 2023. Following that, the MCPD will be reviewed every ten years with a focus on new plant provisions.


www.envirotech-online.com IET March / April 2017


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