LCP Directive 200180EC Case study

1
LCP Directive 2001/80/EC Case study

• Twinning project in Hungary
• Anneli Karjalainen
• Ministry of the Environment,
• Finland

2
LCP Case (1)

• An existing combination of combustion plants with
  the total thermal effect of 945 MW
• 3 plants - each plant with thermal effect of 315
  MW
• all 3 plants have been licensed before 1 July
  1987
• built 1960 (I), 1964 (II) and 1972 (III)
• fuels coal- sulphur content app. 0,8
• SO2 emissions without cleaning 1 600 mg SO2 /m3
  (n)
• additive fuels heavy fuel oil (start-up, shut
  down)
• produces heat and electricity combined heat
  power (CHP)

3
LCP Case (2)

• 2 plants in base-load use (II and III)
• one plant (I) in reserve or peak-load use
• two stacks 134 m and 82 m
• have to apply an environmental permit by 31
  December 2004 (integrated permit)
• waste gas cleaning at the moment
• dust removal, desulphurisation, NOx removal
  (primary measures) based on national legislation
• emission limit values expressed at yearly
  averages for SO2 and NOx

4
LCP Case (3)

• from 1 January 2008
• requirements for existing plants of LCP directive
  shall apply as a minimun requirements
• 4 alternatives
• (1) emission limit values of Annexes III A to VII
  A or
• (2) inclusion into the national reduction plan or
• (3) notify to use the option for remaining life
  time of 20 000 hours
• (4) use the specified NOx limit values for plants
  of limited hours of operation
• from 27 November 2004 requirement for continuous
  measurements of emissions according to Annex VIII

5
Requirements from LCP Directive for plant I

• with thermal effect of 315 MW
• operation hours between 500 to 2000 per year
• from 2008 option to choose
• option 1 ELVs
• use of low sulphur coal to reach the ELV of 1100
  SO2 /m3 (n) and
• use primary measures (low-Nox-burners ) to reach
  the ELV of 600 mg NO2 /m3 (n) and
• dust removal to reach the ELV of 100 mg/m3 (n)
• option 1 not realistic taking into account that
  plant built in 1960 and investments to be done

6
Requirements from LCP Directive for plant I

• option 2 operation of 20 000 hours
• use the option of remaining operation time of 20
  000 hours to close down the plant by the end
  of 2015
• current ELVs will stay in force until 2016
• emission measured discontinuously every six month
• no investments to further waste gas cleaning
• closer of the plant on 31 December 2015 at the
  latest
• if the plant I is needed for a longer period a
  new permit application regarded as a new plant

7
Requirements from LCP Directive for plants II and
III

• operation hours between 5 600 to 7 800 per year
• thermal effect of 315 MW for each
• from 2008
• for SO2 ELV of 1 100 mg SO2 /m3 (n) for solid
  fuels (IIIA)
• for NOx ELV of 600 mg NO2 /m3 (n) for solid
  fuels (VI A)
• for dust ELV of 100 mg/m3 (n) for solid fuels
  (VII A)
• malfunction or breakdown provision of in 48 hours
  to inform authorities
• limit of 120 hours/year for unabated situations
• change from yearly average (mg/MJ) to short-term
  values in mg/m3 (n)

8
Requirements from LCP Directive for plants II and
III

• continuous measurements for all three pollutants
• how to reach the limit values ?
• desulphurisation unit for SO2 - limit value could
  be lower if wet scrubber is chosen
• desulphurisation rates of 90 if the sulphur
  content is high
• primary measures (low-NOx-burnes, over flow)
• dust removal ESP (electrostatic precipitator)
  multicyclone cannot be considered

9
Permit regulations for plant s II and III (base
load)

• Emissions of SO2 not exceed 700 mg SO2 /m3 (n)
  in 6 O2
• Emissions of NOx not exceed 600 mg NO2 /m3 (n)
  in 6 O2
• Emissions of dust not exceed 50 mg/m3 (n) in 6
  O2
• In situations when the desulphurisation unit is
  not in operation because of malfunction or
  breakdown of equipment
• use of low sulphur fuel or toe return to normal
  operation as soon as possible but in 24 hours at
  the latest possible to extend 24 hours time
• information to permit authorities in 48 hours

10
Permit regulations for plant s II and III (base
load)

• Emissions of SO2, NOx and dust shall be measured
  continuously from 27 November 2004
• Temperature, oxygen content and pressure shall be
  measured continuously
• the operator shall by the end of February each
  year report to the competent authority of
• total emissions of SO2, NOx and dust of previous
  year
• exceedances of limit values and the reasoning of
  it
• fuel amounts used in the plants and the operation
  hours, their sulphur content
• emissions of heavy metals
• exceptional situations

11
Permit regulations for plant I (peak-load)

• The operational hours of plant I shall not exceed
  20 000 hours starting from 1 January 2008 and
  ending by 31 December 2015.
• The operator shall report competent authorities
  annually
• how much of 20 000 hours is remaining
• fuel amounts used in the plant and their sulphur
  content
• total emission of SO2, NOx and dust
• results of measurements
• exceptional situations

12
Permit regulations for plant I (peak-load)

• The existing regulations will stay in force
• the sulphur content of coal shall nor exceed 0,8
  
• no continuous measurements required
• the SO2 emissions shall be determined by mass
  balance calculation based on the sulphur content
  of coal and fuel oils
• the emissions of NOx shall be measured every
  three years or after 3 000 hours of operation
• the dust emissions shall be measured continuously
  (or in another way adopted by the competent
  authority) ELV 50/100 mg/m3 (n)

13
Monitoring programme of emissions

• operator puts forward a proposal for an emission
  monitoring plan/programme
• includes details of
• emission measurements
• emission reporting
• quality control for measurements
• monitoring of process parameters
• what is done in exceptional situations (breakdown
  of equipment, violation of limit values)
• adopted in the permit or
• in separate decision

14
National emission reduction plan option for
existing plants

• combustion plants licensed before 1 July 1987 can
  be subject to a national emission reduction plan
• all existing combustion plants over 50 MW have to
  be included
• these 3 plants could be included in this plan
• total emission reduction target over all plants
  calculated divided to plants as an emission
  ceiling for each
• some kind of emission trading
• plant I would be excluded from because
• if uses remaining operation time option of 20 000
  hours