Large Combustion Plants Under the IPPC Directive

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    Requirements concerning

    Large Combustion Plantsunder the IPPC Directive

    Christian Wimmer

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    Table of content

    Integrated Pollution Prevention and Control Directive

    LCP BREF

    LCP chapter of Industrial Emissions Directive

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    European Council Directive 2008/01/ECof 15 January 2008concerning integrated pollution prevention andcontrol (IPPC)

    y Codified version of 96/61/EC

    y a framework directive aiming at a high level of

    protection for the environment as a whole - all

    environmental media

    y operating permits for industry with conditions to be

    based on best available techniques (BAT)

    yprovides for an exchange of information on BAT -Article 16(2)

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    Annex 1 to IPPC Directive

    Energy industries

    Production and processing of metals

    Mineral industries

    Chemical industry Waste management

    Others activities

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    Energy industries

    Combustion installations with a rated thermal input

    exceeding 50 MW

    Mineral oil and gas refineries

    Coke ovens

    Coal gasification and liquefaction plants

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    Interaction of IPPC and Large Combustion PlantsDirectives

    LCP Directive: sets minimum requirements, MS may choose

    to go further

    LCP + IPPC: any stricter requirements under IPPC overrule

    minimum WI requirements

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    Comparison of ELVs/BAT-AELs

    for a coal fired existing plant of > 500MW(mg/m3 daily averages)

    Directive 2001/80/EC(ELV) Directive 2008/1/EC BREF(BAT-AEL)

    Dust 50 5-20

    SO2 400 20-200

    NOx 500 / 200 (as of 2016) 50-200

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    IPPC Implementation

    First step in IPPC implementation is

    transposition to national law.

    Next step is for operator to make application

    for permit.

    Finally, authority determines appropriatepermit conditions.

    2007 deadline.

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    Role of competent authorities(national, regional or local)

    Receive permit applications

    Ensure integrated approach and consult between

    authorities

    Consult the public

    Refuse permit or set permit conditions

    Monitor compliance (self-monitoring by operators andinspections by authorities)

    Take enforcement actions if necessary

    Review, update permit conditions

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    IPPC is about Integrated Permits

    waste prevention

    and recovery

    energy &

    water use

    preventionand control

    of accidents

    Noise Vibration Heat

    emissionsto water

    emissions

    to land

    Odour

    emissions

    to air

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    IPPC is about Prevention of Pollution andimplementation of Best Available Techniques

    most effective

    in achieving a

    high generallevel of

    protection of

    the

    environmentas a whole

    Best

    developed on a scale

    to be implemented in

    the relevant industrialsector, under

    economically and

    technically viable

    conditions, advantagesbalanced against costs

    the technology

    used and the

    way theinstallation is

    designed, built,

    maintained,

    operated anddecommissioned

    TechniquesAvailable

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    From Article 9(4)

    permit conditions must, without prejudice to compliance withenvironmental quality standards, be based on the best availabletechniques, without prescribing the use of any technique orspecific technology, but

    taking into account the technical characteristics of theinstallation concerned;

    its geographical location; and

    the local environmental conditions.

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    Annex IV

    1. the use of low-waste technology;

    2. the use of less hazardous substances;

    3. recovery and recycling .. ;

    4. comparable processes .. ;

    5. technological advances & knowledge;

    6. the nature, effects and volume of the emissions

    concerned;

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    Annex IV continued

    7. commissioning dates for installations;

    8. time to introduce BAT;

    9. consumption of raw materials and energy efficiency;

    10. prevent or reduce overall impact of emissions on

    environment and risks to it;

    11. prevent accidents and minimise consequences for theenvironment;

    The information published by the Commission pursuant to

    Article 17 (2)

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    Article 17(2) - Exchange of information

    The Commission shall organise an exchange of informationbetween Member States and the industries concerned on

    best available techniques, associated monitoring, and

    developments in them. Every three years the Commission

    shall publish the results of the exchanges of information.

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    32 BAT Reference Documents (BREFs) adopted by the

    Commission based on an information exchangeEuropeanEuropean

    CommissionCommission

    IPPC BureauIPPC Bureau

    NGONGO

    expertsexperts

    Member StateMember State

    expertsexperts

    IndustryIndustry

    expertsexperts

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    LCP BREF

    http://eippcb.jrc.es/reference/

    Adopted July 2006

    Revision 2012 - 2014

    http://eippcb.jrc.es/reference/http://eippcb.jrc.es/reference/
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    Structure of the LCP BREF

    Executive Summary

    Preface

    Common Techniques for Energy Generation

    Common Processes and Techniques to Reduce Emissions fromLCPs

    Combustion Techniques for Coal and Lignite

    Combustion Techniques for Biomass and Peat

    Combustion Techniques for Liquid Fuels

    Combustion Techniques for Gaseous Fuels

    Co-Combustion of Waste and Recovered Fuels

    Concluding Remarks

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    Scope of LCP BREF

    Combustion installations > 50 MW

    Power generation industry

    Industries that use commercially available fuels

    Other BREFs cover sector specific combustion

    Waste incineration not covered

    upstream and downstream activities

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    Pollutants considered in LCP BREF

    SO2

    NOx

    CO

    PM10

    GHG such as N2O, CO2

    Heavy metals

    Halides

    Dioxins

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    BATunloading, storage and handling of fuel

    Particulate matter

    E.g. enclosed conveyors

    Water contamination

    E.g. pipelines above ground

    Fire prevention

    E.g. automatic systems

    Fugitive emissions

    Efficient use of natural resources

    Health and safety risks regarding ammonia

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    Thermal efficiency

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    Particulate matter

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    Heavy metals

    As, Cd, Cr, Cu, Ni, Pb, V, Zn:

    BAT is high performance dedusting devices (ESP, FF)

    Hg, Se:

    Flue-gas desulfurisation, SCR

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    SO2 emissions (1)

    BAT is

    to use low sulfur fuel

    desulphurisation

    > 100 MW

    In addition, abatement measures

    < 100 MW

    Due to high costs, wet scrubber is not BAT

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    SO2 emissions (2)

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    NOx emissions (1)

    Primary measures for pulverized lignite:

    Advanced low NOx burners

    Flue gas recirculation Staged combustion

    Causes incomplete combustion (higher levels of fly ash, CO)

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    NOx emissions (2)

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    The current situation

    European Industry is subject to a range of industrial

    emissions legislation....

    IPPC DirectiveDirective on the limitation

    of emissions of VOC from

    solventsWaste Incineration

    Directive

    Large Combustion

    Plants (LCP) Directive

    Directives related to thetitanium dioxide industry

    European Pollutant

    Emission Register

    (EPER)

    European Pollutant

    Release and Transfer

    Register (E-PRTR)

    This makes enforcement at Community level very difficult and

    leads to unnecessary administrative burden

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    Recast of directives on IE

    Through the Commissions proposal for a Directive on industrialemissions the following legislation is recast into one single act

    Directive 2008/1/EC concerning integrated pollution

    prevention and control (IPPC)

    Directive 1999/13/EC on VOC solvent emissions (SE)

    Directive 2000/76/EC on waste incineration (WI)

    Directive 2001/80/EC on large combustion plants (LCP)

    Directives 78/179/EEC, 82/883/EEC and 92/112/EEC

    related to the titanium dioxide industry

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    Structure of Recast Proposal

    Chapter I: Common provisions

    Chapter II: Special provisions for activities listed in Annex I [IPPC]

    Chapter III: Special provisions for combustion plants Chapter IV: Special provisions for waste (co-)incineration plants

    Chapter V: Special provisions for installations and activities using

    organic solvents Chapter VI: Special provisions for installations producing TiO2

    Chapter VII: Committee, transitional and final provisions

    Annexes I - VIII

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    1. Problem identification

    LCPs: main source of industrial emissions

    74% (SO2), 49% (NOx) of 2005 NECD industrial emissions

    60% (SO2), 19% (NOx) of 2005 NECD total emissions

    BAT implementation is lagging behind

    large gap between current emissions and BAT levels (LCP BREF)

    LCP Dir minimum ELVs are generally much higher than

    BAT levels from LCP BREF

    Significant emission reductions are needed to achieve theTSAP objectives: LCPs play a key role

    Current emissions vs BAT levels

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    Current emissions vs BAT levels

    EEA (2008) based on EPER 2004 data

    Current emissions vs BAT levels: summary

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    Current emissions vs BAT levels: summary

    EPER 2004 data from 450 power plants (EEA study)

    Uptake ofBAT still very incomplete

    Very significant emission reduction potential if all plants wouldoperate within BAT levels (upper lower end):

    y SO2: 80 - 97%

    y NOx: 59 - 87%

    LCPD emission inventories 2006

    about 70% of LCPs have emissions above BAT levels

    Note: analysis excludes opted out + Accession Treaty derogations

    I 1 I ffi i i l i f B A il bl

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    Issue 1: Insufficient implementation of Best AvailableTechniques (BAT)

    BREFs contain emission

    levels associated with the

    use of BAT (BAT-AELs)

    Permits must contain

    emission limit values (ELVs)

    set by the competent

    authority that do not exceed

    BAT-AELs (Article 16(2))

    Derogation from these limits is

    allowed in specific cases as long asit isjustified (Article 16(3))

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    LCP chapter of Industrial Emissions Directive

    Tightening of minimum ELVS from 2016 on

    Aligned with current BAT (upper end of the range)

    Significant contribution to the objectives of the TSAP

    Net benefits of 7-28 billion per year

    Introduction ofnew activities to the scope of IPPC

    (based on assessment of cost and benefits)

    Combustion activities of 20-50 MW capacity

    I di ti ti li f th l l l

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    Indicative timeline for the legal proposal

    12/2007 01/2016

    07/201201/2009

    12/2010 01/2014

    07/2015

    Depending on the co-decision procedure the Commission expects the following to take place

    The Commission adopts its proposal for a Directive on industrial emissions as well as issuing

    its Communication Towards an improved policy on industrial emissions

    First reading in the European Parliament and political agreement in Council

    Completion of the co-decision process and publication of the Directive within the Official Journal

    MS fully transpose the new Directive (18 months after entry into force).

    The Directive applies to all new installations from this date onwards

    All existing installations previously subject to IPPC, WID, SED and TiO2 Directives must meet the

    requirements of the new Directive.

    Large Combustion Plants do not yet need to meet the new ELVs prescribed within the Directive.Existing installations performing the newly prescribed activities (e.g. combustion plants 20-50

    MW, wood based panel production, wood preservation) must meet the requirements of the new

    Directive.Large Combustion Plants must meet the requirements set out in Chapter 2 of the new Directive,

    as well as the Emission Limit Values set out in Annex V