Burning issue
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Are you MCPD ready? O
With the latest piece of emission legislation in place for over six months with little fanfare, Charlie Mowbray, Ideal Commercial Boilers commercial product manager, looks at the implications for both new and existing boilers
ver recent years our industry has worked hard to improve the impact our products have on human health and the environment. As
well as manufacturers constantly innovating, regulation and legislation has been introduced to shape the industry and set emissions targets. Following on from the ErP Ecodesign Directive of 2015 comes the latest piece, the Medium Combustion Plant Directive (MCPD). Like ErP this is a European Union Directive that has been since become law in all member states. As MCPD came into effect on December 20, 2018 it will still be law after the United Kingdom leaves the EU.
The MCPD sets out emission limit values (ELVs) of nitrogen oxides (NOx), sulphur dioxide (SO2) and dust produced by an individual combustion plant (eg. boiler) with a thermal input equal to or greater than 1mW and less than 50mW. This is different to ErP and Building Regulations Part L which are both based on the output of a boiler; it will be vital for specifiers, installers, building owners and facilities managers to make sure that they are looking at the correct figures once individual boilers around 1mW are being reviewed. The individual boiler element also has to be considered carefully. If a plant
room contains two separate boilers which each have an input of 576kW, MCPD would not apply (Building Regulations Part L would). If a single boiler, such as a modular boiler, with an input of 1,056kW was installed instead in the same plant room, MCPD would apply. Enforcing the rules will be five regulators across the United Kingdom and
Republic of Ireland: • The Environment Agency (England) • Scottish Environment Protection Agency (SEPA) • Natural Resources Wales (NRW) • Northern Ireland Environment Agency (NIEA) • Environmental Protection Agency, Ireland (EPA)
Table 1 Emission limit values (mg/Nm3) for new MCP other than engines and gas turbines The MCPD treats new and existing medium
combustion plant (MCP) differently. New MCP is that which has been installed and become operational after December 20, 2018. Even if a plant was installed before December 20, 2018, unless an operator can provide evidence that the plant was operational before that date, then it will be regarded as new. This is likely to impact large projects which can have long periods after installation before a system is commissioned. MCP must be registered with the relevant regulator mentioned earlier before operation and must comply with these ELVs (Table 1).
Registration and permitting is a key consideration. The regulators are
indicating that applications for permits for new MCP should be made at least three months ahead of the plant being operational (SEPA state at least 4 months); it is vital that these timescales are respected to avoid situations where MCP is ready to use but cannot be turned on due to not having a permit. Existing MCP does not need to be registered and achieve ELVs immediately,
but there are deadlines in place. If Existing MCP has an input above 5MW and below 50MW, it must have a permit by January 1, 2024 and achieve the ELVs by January 1, 2025. For existing MCP with input between 1MW and 5MW, a permit must be in place by January 1, 2029 and be compliant with ELVs a year later. (See Table 2 & Table 3) Existing MCP that does not achieve the emission targets now may need to
be replaced or rectified ahead of these deadlines with additional equipment, new components or new MCP that does, but building owners, facilities managers and maintenance contractors should audit their assets now and be aware of the action that they may need to take. As we get closer to the deadlines, the wait for a permit could very possibly extend to over six months, and budget proposals and business cases may need to be built, submitted and approved if additional equipment, new components or new MCP is required to hit the ELVs. Although the deadlines may seem a while off, they will soon come around; planning is required now to ensure properties are compliant. Existing MCP can become new MCP. If existing MCP is altered or repaired in such a way that its ELVs change, if a boiler is converted from running on oil to running on natural gas for example, then it will be considered as new MCP. Alternatively, if existing MCP is substantially refurbished, it will be become new MCP. Substantially refurbished is classified as the cost of refurbishment is over 50% of the investment cost of a comparable new MCP unit. Boilers worth close review are pressure jet boilers. Modern, condensing
Table 2 Emission limit values (mg/Nm3) for existing MCP with a rated thermal input greater than 5MW other than engines and gas turbines
pressure jet boilers mated with up-to-date burners should have no problem in meeting the standards in the MCPD. However older style pressure jet boilers and their accompanying burners may not be able to achieve the ELVs, either as new or existing MCP. If there are uncertainties about your pressure jet boilers’ emissions, it is best to arrange to have them tested, as that will be required anyway as part of the registration process. The MCPD is the latest piece of legislation that will aid improving air
Table 3 Emission limit values (mg/Nm3) for existing MCP with a rated thermal input equal to or greater than 1MW and less than or equal to 5MW
quality for all us for years to come. It has been with us for over six months now and has received little coverage. For new MCP, it is vital that plant with individual inputs of over 1MW are compliant with the ELVs set out in the MCPD and that plenty of time is allowed for the new MCP to be registered and a permit issued before it is operational. Although the deadlines for registration and compliance of existing MCP are at least four and a half years away, it is vital that planning takes place now to ensure that any last-minute delays are avoided.
July 2019
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