Annual Guide 2019 I SOURCE TESTING ASSOCIATION
There is also a general requirement (for Tranche A and B generators) that the regulator must include stricter measures in the permit where this is required to comply with air quality standards.
The Environment Agency has recently published supporting documentation covering the permit application process and dates for MCPs and specifi ed generators, including standard rules permits, monitoring guidance and air quality modelling guidance. Existing Tranche B specifi ed generators will require a permit by 1 January 2019, whilst Tranche A generators on sites of greater than 5 MWth with emissions of greater than or equal to 500 mg/m3
(at 15% O2 ) which operate for more than 50 hours per year will require a permit by 1 October 2019.
Specifi ed generators must also comply with the MCPD requirements where they are in scope.
Monitoring Requirements
Periodic monitoring of the pollutants for which ELVs are defi ned 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.
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 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.
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 defi ned by
individual CEN standards). However, if these are employed they will automatically satisfy the MCPD monitoring requirements. In any case, the equipment specifi ed 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 is required. In the
UK, MCERTS accredited monitoring is required for plants that are deemed to pose a signifi cant environmental risk.
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 plants, 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 defi nes Emission Limit Values for key pollutants, and periodic monitoring requirements, the method for assessing compliance is not clearly defi ned. 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 fi tted with pollution abatement equipment since the operator is required to demonstrate that the abatement is effective.
Monitoring requirements are not defi ned 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 defi nes sampling equipment for Large Combustion Plants that is not suitable for Medium Combustion Plants. In the UK, further guidance is provided in the Environment Agency’s Technical Guidance Note M5.
The Member State may elect to either simply register or grant a permit for a Medium Combustion Plant. However, the fi rst 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.
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In many EU Member States, boiler emissions are already measured during annual or six-monthly service visits using equipment that is certifi ed 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 plants ≤ 20 MWth
. This would also share the
burden with regards to the scheduling of test work. In the UK, a simplifi ed monitoring approach for MCPs that are considered to pose a low environmental risk is defi ned in the Environment Agency’s Technical Guidance Note M5 (2018).
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