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BAT for LCPs, Self-monitoring and Monitoring.

ECENA Training Workshop

Bristol, March 2008

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Introduction

This presentation, Session 3, addresses: BATs for LCPs Setting Emission Limit Values in an IPPC License for

an LCP. Technical approaches adopted in other Member

States. Self-monitoring and monitoring. New Directive on Industrial Emissions.

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Practical Issues

The good news! A wealth of information is available on compliance

issues, technologies, costs, etc, for control of NOx, SO2 and particulates.

Drafting and enforcing a permit is not complex. The bad news!

Because LCPs are so large the costs involved can be enormous running into hundreds of millions of Euro.

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IPPC Permit

LCP directive only specifies Emission Limit Values (ELVs) to air.

An IPPC permit is far more complex; conditions relating to: Management of facility Emissions to other media such as surface water, groundwater,

noise, odour. Waste minimisation Energy efficiency Accident prevention Monitoring of emissions

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IPPC Permits

Permits must contain ELVs based on Best Available Techniques (BAT) for pollutants likely to be emitted in significant quantiies.

BAT is NOT ‘Best of the Best’. EU environmental legislation is based on:

proportionality: consideration of whether the alleviating measure is proportionate to the potential risk, in light of the scientific information available;

cost/benefit analysis: including economic and non-economic considerations;

public transparency.

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Emission Limit Values (ELVs)

ELVs to be based on Best Available Techniques (BAT), without prescribing the use of any technique or specific technology.

ELVs can be site specific, similar facilities in different locations can have different ELVs.

Most industrial sectors, including Large Combustion Plants have BAT Reference Documents (BREFs) published by EU IPPC Bureau. http://eippcb.jrc.es/

ELVs only become legally binding when written into an IPPC permit!!!!

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General BAT in EU Guidance (BREFs)

The general BAT provided are a reference point against which to judge the current performance of an existing installation or to judge a proposal for a new installation.

It is foreseen that new installations can be designed to perform at or even better than the general BAT levels presented.

Note BREFs: Have no legal basis. Are not prescriptive. Are not site specific. Report emission levels associated with BAT and not ELVs.

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BAT for New Installations / Community ELVs

Equipment has been readily available for a number of years to meet recognised BAT, e.g. LCP directive, incineration directive, BREFs, TA Luft (Germany).

New equipment should ideally meet these standards. The EU can set Community ELVs under Article 18 of the

IPPC Directive; this has been done for LCPs, incinerators and titanium oxide industry.

Member States can set ELVs / conditions more stringent than those given in the directives above.

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LCP Directive 2001/80/EC and Emission Limit Values

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Emission Limit Values in LCP Directive 2001/80/EC

“New-New” Plants (Article 4.2) Emission limit values in Annex III to VII part B. Must consider potential for combined heat and power

applications (Article 6). Average emission limit values for refineries (Article 8.3(b)).

“Old-New” plants (Article 4.1) Those licensed after 1 July 1987 and before 27 November 2002. Emission limit values in Annex III to VII Part A.

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Example – Emission Limit Value SO2

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Emission Limit Values SO2

Alternative requirements where previous ELVs cannot be met because of fuel characteristics: Rate of desulphurisation approach 60% to 94%

depending on plant size (Annex III nb). Article 5 (1):

Until 31/12/2015 < 800 mg/Nm3 < 2,000 hrs*. From 1/1/2016 < 800 mg/Nm3 < 1,500 hrs*. *(rolling average over a period of five years).

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BAT for Existing Installations

It is also considered that existing installations should move towards the general BAT levels or do better, subject to the technical and economic applicability of the techniques in each case.

The appropriate limit values for any specific case will need to be determined taking into account the objectives of the IPPC directive and the local considerations.

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BAT for Existing Facilities

BREF Preface “In the case of existing installations, the economic

and technical viability of upgrading them also needs to be taken into account. Even the single objective of ensuring a high level of protection for the environment as a whole will often involve making trade-off judgements between different types of environmental impact, and these judgements will often be influenced by local considerations.”

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Using the BREFs

Although LCPs are addressed by one very large BREF it is usually necessary to review a number to build a complete picture.

Other BREFs relevant to LCPs: Cooling systems Monitoring systems Emissions from storage from bulk or dangerous materials Common waste water and waste gas treatment Economic and cross media issues Energy efficiency (just started by EIPPCB)

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Determining BAT

Identification of BAT

Costs and benefits of measure

Achievable emissions

Environmental impacts – air, land, water

BREF’s

Energy use

Technical reliability

Installation time

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Setting an ELV in a Permit

Setting an ELV for an operating plant is an iterative process, which can be summarised by:

Review of available BAT guidance for that industrial sector and the conditions of the plant, such as age, local environmental conditions, etc.

Based on the above a preliminary ELV is defined. An impact assessment is then completed to determine the impact of the

projected emissions on the surrounding environment. If the impact of the emissions is below recognised benchmark

standards, such as national Environmental Quality Standards, then the preliminary ELV can be adopted as a final ELV for the site.

If the emissions are above recognised benchmark standards then the preliminary ELV has to be reconsidered, possibly going beyond BAT or consideration given to the likelihood of remedial action elsewhere.

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UK H1 BAT and Cost Assessment Methodology

http://www.environment-agency.gov.uk/business/1745440/444663/298441/horizontal/545377/

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Impact Assessment of Preliminary ELV

ELVs usually expressed in mg/m3 based on what can be achieved by BAT.

But how many m3/h can the environment accept? As the mass flow is increased at some point an

Environmental Quality Standard (EQS) will be exceeded and stricter conditions will be required.

Impact Assessment using air dispersion modelling required.

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Air Dispersion Modelling

Stack parameters, surrounding buildings, local weather conditions and surrounding terrain entered into mathematical model.

Internationally software has been developed by US EPA (Aermod), the German Environment Agency (Austal 2000), the UK Environment Agency (ADMS3), the Danish National Environmental Research Institute (OML).

At best these models over predict concentrations by a factor of two or three, they are tools not absolutes.

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When to model?

Modelling involves time and expense, it is only justified for larger stack discharges, like LCPs. Simple rules on when modelling required given in UK H1 Guide (Section 3.3).

Model output in form of hourly or annual average concentrations which should be superimposed as contours on a map of the area.

Irish example; Planned municipal incinerator and planned 400 MWe gas turbine power plant to be located near existing large cement plant.

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Irish Example of Three Stacks (NO2 99.8th percentile)

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Interpretation of results

Outputs in percentiles corresponding to air quality standard, e.g. maximum hourly NO2 based on 99.8th percentile (18 highest of 8,768 hourly values removed).

Percentiles reduce values by about 25% when compared to absolute maximum.

Peak value will be limited to small area on the stack downwind side. With multiple stacks unlikely that peaks will overlap.

Background concentrations need then to be added to stack predictions, rules for this provided in H1 Guide.

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Comparison with benchmark values

Benchmark values include: EU Environmental Quality Standards; air pollution

limit values in directives 96/62/EC, 1999/30/EC and 2000/69/EC for NO2, SO2, particulates, lead, carbon monoxide and benzene.

World Health Organisation (WHO) Air quality guidelines for Europe (35 compounds).

Occupational Exposure Limits divided by 40.

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Desulphurisation Technologies Available!

Desulphurisation with lime / powdered limestone slurry in a scrubbing system to produce calcium sulphate dihydrate (gypsum): CaO + SO2 CaSO4

The alternatives are sea water scrubbing or direct injection of powdered limestone into a fluidised bed furnace.

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Limestone Gypsum Process

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DeNOx Technologies Available!

Primary DeNOx technologies are based on combustion control as at > 1,400°C thermal NOx occurs from oxidisation of the nitrogen in the combustion air. These can be up to 60% effective.

Secondary DeNOx technologies are based on Selective Catalytic Reduction (SCR) at circa. 300°C and Selective Non-catalytic Reduction (SNCR) at circa. 950˚C. NH3 + NOx N2 + H2O

SCR can be up to 90% effective and SNCR 50 to 70%.

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Moneypoint: SCR DeNOX and Desulphurisation

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Drax: Desulphurisation and Low NOx Technology (Boosted Over Fire Air System)

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Summary of Approach in Western Europe

Oil fired: Closed / reduced hours on low sulphur fuels.

Coal fired: Desulphurisation with primary DeNOX or secondary DeNOx at more modern plants.

Gas fired: New gas turbine plants with no sulphur emissions and primary DeNOx controls.

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Is there a Return on Investment in Environmental Protection?

While it is very difficult to estimate the costs of improved environmental protection, it is even more difficult to estimate the benefits!

For example, critical for decision makers to know how much a tonne of CO2 costs in order to determine how much to promote renewable energy.

EU Externe Project to estimate External Costs; the negative impacts on the environment and health, for which not the producer but rather the general public must answer for. Recommendation of €70 /t for CO2, €3,300 /t for SO2 or NOx,

€12,000 /t for PM10 (UBA 2007).

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Externe Costs of Electricity Production in Germany (cent/kWh)Energy source for electricity generation

Externe costs in cent/kWh (2005)

Brown coal 8.7

Hard coal 6.8

Heating oil 6.1

Natural gas 3.9

Hydro 0.4

Photovoltaic 0.8

Wind power (onshore) 0.1

Electricity generation (power plant mix 2005 without nuclear)

5.8

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Monitoring - General

Any measurement system is only so good as it is maintained: Instrumentation will only function if regularly calibrated and

maintained. These operational costs must be considered in addition to the

capital cost of the equipment. The scope and availability of measurement technologies

has greatly increased in the last few years. BAT guidance document on monitoring: http://

eippcb.jrc.es/pages/FActivities.htm

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Monitoring - General

EN and ISO standards now available for analysis / instrumentation.

Reference conditions, e.g. oxygen concentration, temperature, water vapour plus sample conditioning must also be considered.

Choice of monitoring location critical: Straight sections to reduce turbulence. Good and safe access for both company and agency

personnel. http://www.epa.ie/downloads/advice/licensee/epa_guidance_ai

r_emissions_sampling_facilities.pdf

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Stack - Monitoring

Continuous emissions monitor systems (CEMS) readily available for CO2, CO, NOx, SO2, HCl, HF, Total Organic Carbon (TOC), particulates. Less common are NH3, hazardous metals.

Periodic measurements usually based on grab samples that can be later analysed at an approved laboratory.

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LCP Directive - Monitoring

Methods of measurement of emissions specified in Annex VIII of Directive 2001/80/EC.

Continuous measurement of SO2, NOx and dust is required for combustion plants > 100 MWth. Some derogations available for SO2 and dust where

instead discontinuous or appropriate determination procedures can be used as approved by the competent authority, e.g. plants fired on natural gas.

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Continuous Stack - Monitoring

Modular system for continuous stack analyser; purchase only required modules. Flame Ionisation Detection (FID) for hydrocarbons: €30,000 -

€45,000. Additional modules using Fourier Transform Infrared

Spectroscopy (FTIR) for CO, NOx, SOx, C, etc. These will increase cost of system to >€110,000.

Additional costs for sample conditioning, hardware and software for processing of raw data to Agency reporting standards, calibration gases, housing of equipment.

Typical suppliers are: ABB, Siemens, Sick Maihak, Codel.

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Self Monitoring / Monitoring by Authorities

IPPC compliance is based on self monitoring with checks by regulatory authorities.

Authorities in many accession countries supplied with stack gas analysers under Phare programme.

MCERTS the Environment Agency’s monitoring certification scheme: http://www.environment-agency.gov.uk/business/1745440/444671/466158/

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Reporting E-PRTR

New IPPC Permits in Ireland require E-PRTR reporting as part of Annual Environmental Report (AER). See Section 6.18 of Shell Corrib Licence issued in

Dec. 2007. The reporting scope is to be agreed with the EPA

each year.

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Proposed Directive on Industrial Emissions

The Commission proposes to overhaul the IPPC Directive and the six sectoral directives; LCP, Incineration, Solvents and the three directives on production of titanium dioxide.

A new Directive on Industrial Emissions is being prepared, this will take some years: http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/07/623&format=HTML&aged=0&language=EN&guiLanguage=fr

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Proposed Directive on Industrial Emissions (continued) Permitting to be based on BAT with divergence

from BAT to be restricted to specific cases. LCP threshold to be reduced from 50 MW to 20

MW. Greater emphasis on justification of conditions

in the permit. Net benefits from LCPs estimated at €7 billion

to €28 billion per year, including saving 13,000 and 125,000 premature deaths and years of life lost, respectively.

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Questions?