Introduction to Large Combustion Plant LCP Directive and Compliance Issues' ECENA Training Workshop

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Introduction to Large Combustion Plant (LCP)
Directive and Compliance Issues.ECENA Training
Workshop

• Bristol, March 2008

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Introduction

• This presentation, Session 1, will address
• The history and goals behind the LCP directive.
• Its interface with IPPC and the E-PRTR.
• How other Member States have implemented the LCP
  Directive.
• New developments in LCP legislation.

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Historical Basis

• Pollution levels in European cities in 18th and
  19th century over a 100 times current limit
  values, e.g. famous London smog.
• 20th Century led to development of large
  centralised power plants with tall stacks,
  dilution was the solution.
• This led to transboundary pollution,
  acidification and dying forests.

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Moneypoint Coal Fired Power Station Ireland
(large stacks)
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Estimated Source of Air Releases(as of Total
UK Emissions)
Source National Air Quality Strategy, DETR
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Pollution from LCPs

• LCPs accounted for about 75 of SO2 and 21 of
  NOx of UK totals in 1998.
• Widespread use of coal in power generation
  throughout Europe led to similar values.
• Expected that these values will fall sharply over
  2000 2010 by
• SO2 1,000 kilotonnes
• NOx 4,000 kilotonnes
• Particulates 100 kilotonnes
• Savings in less material damage, morbidity and
  mortality alone estimated by EU at 38,444
  million.

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Historical Basis (First Step)

• 1983 Germany implemented Federal Imissions
  Control Act (BImSchG), leads in ten years to a
  89 reduction of SO2, driven by high awareness of
  environmental damage to forests.

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Control of Air Pollution from Industry

• By the early eighties it was obvious that air
  pollution from industry needed to be controlled
  on an EU level, although some countries had
  already implemented comprehensive national
  legislation.
• Air Framework Directive 84/360/EEC established
  system of permitting
• Use of Best Available Technology Not Entailing
  Excessive Cost (BATNEEC).
• Plant must not cause significant air pollution,
  i.e. applicable emission limit values and air
  quality values must be met.

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German Control Measures for Pollution from LCPs

• Public outcry over the death of forests
  (Waldsterben) led to the 13 BImSchV of 1983.
• With a command and control approach a general
  SO2 limit of 400 mg/m3 was adopted which LCPs had
  to meet by 1993 or close down.
• By 1988 W.Germany had retrofitted flue gas
  desulphurisation to 70 LCPs, roughly 75 of
• the total capacity.
• Final cost of desulphurisation 14.3 Billion DM.

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Implementation of Desulphurisation in Germany

• With regard to achieving a dramatic reduction in
  SO2 discharges the legislation was a major
  success.
• However, its implementation was rushed processes
  were not optimised, contractors were overloaded,
  estimated that nowadays it would cost 30 less.
• However, it did lead to the 1988 LCP directive.

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EU Control of Pollution from LCPs

• Obvious that LCP sector required particular
  regulation as a major source of SO2 and NOx
  emissions.
• Long drawn out highly politicised and contested
  process with first proposal of LCP directive
  presented in 1983 as a daughter directive to the
  Air Framework Directive.
• Finalised in 1988 as Directive 88/609/EEC,which
  set Emission Limit Values (ELVs) for new plant
  and gave a national bubble of emissions for
  existing plants.
• New Plant licence granted after July 1987.
• Existing Plant licence granted before July
  1987.

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First LCP Directive 88/609/EEC

• Scope of Directive 88/609/EEC limited to
• Rated thermal input 50 MW.
• Combustion plants for the production of energy.
• Direct use of the products of combustion in
  manufacturing process
• Does not include
• Combustion of waste or combustion for air
  emissions control.
• Situations where products of combustion used for
  direct heating or drying, e.g. furnaces.
• Diesel, petrol or gas engines or gas turbines.

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Approach of First LCP Directive

• Goal was to reduce emissions of SO2, NOx and
  particulates.
• Classic command and control approach for new
  plants setting uniform Emission Limit Values
  (ELVs) based on plant size and fuel type.
• More flexible approach for existing plants
  staged reduction (national emissions ceilings)
  for SO2 and NOx for 1993, 1998 and 2003.

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Additional Requirements of LCP Directive

• Member States to determine total annual emissions
  for both new and existing plants.
• National emission reduction targets to be agreed
  with EU. Compliance programmes to achieve targets
  to be developed with the operators.
• Options include fuel switching, energy saving
  measures, pollution abatement technologies.
• Licences need to consider measurement methods and
  measures in event of failure of control devices,
  etc.

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LCP Reduction Targets
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Updating of LCP Directive

• By 2001 the LCP directive was updated
  (2001/80/EC) reflecting the progress in
  technology and EU environmental legislation and
  the need to include gas turbines, promote
  combined heat and power and tighten up
  monitoring.
• Updated ELVs for modern LCPs operational after
  27/11/2003.
• ELVs set for gas turbines, which were becoming
  increasingly common, in addition to those set for
  solid fuel and liquid fuel fired LCPs.
• Diesel, petrol and gas engines still excluded.

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End of Life Exemption

• Directive 2001/80/EC included the following
  important exception
• An existing plant may be exempted from compliance
  with the ELVs and from inclusion in the national
  plan if the operator declares by 30 June 2004
  that the plant will not be operated for more than
  20,000 hours beyond 1 January 2008 and up to 31
  December 2015 end of life.

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LCP Directive 2001/80/EC

• Member States have two options for controlling
  emissions from existing plants
• (a) applying the new plant ELVs in the original
  Directive to existing plant by 1 January 2008, or
• (b) by 1 January 2008, reducing emissions from
  existing plant under a national plan to the same
  levels which would have been achieved by the
  application of the new plant ELVs to existing
  plant in operation in the year 2000.

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Interface with IPPC Directive

• Recital 8 of LCP directive Compliance with the
  Emission Limit Values laid down by the LCP
  directive should be regarded as necessary but not
  sufficient for compliance with the requirements
  of directive 96/61/EC (IPPC) regarding the use of
  Best Available Techniques. Such compliance may
  involve more stringent ELVs, ELVs for other
  substances and other media, and other appropriate
  conditions.

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Conclusions on LCP / IPPC Interface

• In all cases an IPPC permit is required.
• This is a more complex issues than the ELVs
  specified in the LCP directive.
• The IPPC permit must contain BAT based ELVs, for
  which there is flexibility for existing plants.
• Where BAT based ELVs are less demanding than LCP
  directives ELVs possible to use national plan
  option.

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European Pollution Emissions Register (EPER)

• Gives access on pollution emissions of 50
  pollutants from approx. 12,000 IPPC facilities in
  the EU. Updated every 3 years.
• http//www.eper.cec.eu.int/eper/

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European Release and Transfer Register (E-PRTR)

• European Release and Transfer Register (E-PRTR)
  will replace EPER for 2007. Number of pollutants
  is expanded to 91.
• E-PRTR and LCP directive include combustion
  plants with a heat input of gt 50 MW.
• Relevant pollutants for LCPs among the 91
  include
• CO2, CO
• NOx, SO2, PM10
• Heavy Metals

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European Release and Transfer Register (E-PRTR)

• Thresholds set for pollutants above which
  reporting required.
• Consider 50 MWt Combine Cycle Gas Turbine
  (cleanest power generation), running for 8,200
  h/a, i.e. continuous load, with low emissions
  (NOx 50 mg/m3, CO 25 mg/m3 and PM10 2 mg/m3).
• Does this require reporting??

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50 MWt CCGT Plant ? E-PRTR
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Interface between LCP and E-PRTR

• Appears likely that even the smallest LCPs will
  have some reporting requirements under the E-PRTR
  each year!
• More on reporting in Session 3!

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How have other Member States implemented the LCP
Directive?

• The cost of upgrading every LCP would be
  prohibitive.
• For older plants it is essential to consider
• What is the residual lifespan of older plants?
• Are these base load stations or used to match
  peak loadings?
• Which is cheaper? Upgrade or replace with new
  plant?
• Consider applying for end of life reduced hours
  exemption? (20,000 hrs over 8 years)

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Economic Considerations

• Need to carefully consider economic
  considerations before initiating upgrade
  projects.
• Dash for Gas adopted by UK and Ireland
• Combine Cycle Gas Turbines (CCGTs) have the best
  environmental performance of all LCPs?low stacks!
• CCGTs have very high efficiencies typically 55
  versus about 35 for older LCPs ? good Kyoto!
• CCGT are low cost typically 0.8 million / MW ?
  good economics!

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New CCGT Power Station (small stacks)
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Is Gas the Answer?

• Energy policy must consider security of
  supply
• 1970s oil shocks showed the folly of dependency
  on a single energy source. France takes the
  nuclear route!
• Fuel costs
• Gas is a premium fuel and will cost more than
  coal. Western European gas supplies exhausted in
  25 years!!
• Investment in gas infrastructure is required
  pipelines, compressors, etc.
• Socio-economic factors
• Is there an indigenous fuel supply worth
  developing? German reliance on coal, while
  political hostility in UK to coal industry.

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Is Gas the Answer ?

• Efficiency of CCGTs drop rapidly when load is lt
  80 ? base load technology.
• New peaking open cycle gas turbines have
  efficiencies of 45 and hold this down to 50
  load with rapid response to load changes ?
  variable load technology.
• Day / night time load demand is inherently
  variable but variability increasing due to
  renewable sources such as wind being connected to
  the grid!
• Unless considerable hydro resources available
  peaking gas turbines will need to be considered!

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What is Ireland doing?

• Older plants on End of Life exemptions
  restricted to peak load duty. Use of low sulphur
  fuels and low NOx burners.
• Moneypoint Power Station Largest in Ireland at
  915 MWe supplies 25 of countrys power. Coal
  fired plant undergoing 264 million environmental
  upgrade to meet LCP directives emission limit
  values deNOx and flue gas desulphurisation
• National Emissions Reduction Plan seeks emission
  reductions of up to 73 for SO2, and 66 for NOx
  from the levels emitted in 2002.

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What is Ireland doing?

• Emission reductions in Moneypoint to offset NOx
  emissions in other plants under National
  Emissions Reduction Plan.
• New gas fired CCGT plants under construction, gas
  turbine peaking plants under consideration.
• Older Heavy Fuel Oil plant at Tarbet (595 MWe)
  closed.
• Meeting the NOx requirements remains the greatest
  challenge!!!
• Newer CCGT power stations will help but state
  owned power supplier ESB is protesting about the
  costs that could occur.
• Over 650 MW of wind generation installed on Irish
  grid, average output for April 07 was 132 MW ? we
  need our LCPs!!!!

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What is UK doing?

• History of opposition to the LCP Directive as
  extensive Flue Gas Desulphurisation (FGD) would
  be required to existing coal plants supplying 65
  of electricity in 1989.
• Liberalisation of electricity market with
  resultant fuel switching construction of CCGTs
  and increase in nuclear power. Currently
• Gas 39 Coal 33 Nuclear 21

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New Developments

• Report for the EEA using data from 2004 would
  indicate that there is still progress to be made
  by Large Combustion Plants (LCP), particularly
  those coal and lignite fired.
• Note BAT associated emission limit values are
  lower than those in LCP Directive.

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Summary

• Justification is strong for the considerable
  investment required to upgrade or replace LCPs.
• Approach taken by Member States has differed,
  from going nuclear (France), going gas (UK and
  Ireland), or major retrofitting to existing coal
  fired generation (Germany).
• Future trend is that even tighter controls are
  technically feasible and will be sought by EU.

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New Developments

• Need for further industrial emission reductions
  to meet Thematic Strategy 2020 targets
• -30 for SO2
• -35 for NOx
• -24 for PM2.5 (lt2.5 micron particulate matter)
• -17 for Volatile Organic Compounds
• Recent proposal from EU Commission (21/12/2007)
  for a new Directive on industrial emissions will
  incorporate the above targets for licensing of
  LCPs.

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Dont be shy Question time!