Requirements concerning Large Combustion Plants under the IPPC Directive

Christian Wimmer

Table of content
Integrated Pollution Prevention and Control Directive LCP BREF LCP chapter of Industrial Emissions Directive

European Council Directive 2008/01/EC of 15 January 2008 concerning integrated pollution prevention and control (IPPC)
Codified version of 96/61/EC a framework directive aiming at a high level of protection for the environment as a whole - all environmental media operating permits for industry with conditions to be based on best available techniques (BAT) provides for an exchange of information on BAT Article 16(2)

Annex 1 to IPPC Directive

Energy industries Production and processing of metals Mineral industries Chemical industry Waste management Others activities

Energy industries
Combustion installations with a rated thermal input exceeding 50 MW Mineral oil and gas refineries Coke ovens Coal gasification and liquefaction plants

Interaction of IPPC and Large Combustion Plants Directives

LCP Directive: sets minimum requirements, MS may choose to go further LCP + IPPC: any stricter requirements under IPPC overrule minimum WI requirements

Comparison of ELVs/BAT-AELs for a coal fired existing plant of > 500MW (mg/m3 daily averages)
Directive 2001/80/EC (ELV) Dust SO2 NOx 50 400 500 / 200 (as of 2016) Directive 2008/1/EC BREF (BAT-AEL) 5-20 20-200 50-200

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 appropriate permit conditions. 2007 deadline.

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 and inspections by authorities) Take enforcement actions if necessary Review, update permit conditions

IPPC is about Integrated Permits

emissions to air

emissions to water

emissions to land

prevention and control of accidents

waste prevention and recovery

energy & water use

Noise

Vibration

Heat

Odour

IPPC is about Prevention of Pollution and implementation of Best Available Techniques

Best
most effective in achieving a high general level of protection of the environment as a whole

Available
developed on a scale to be implemented in the relevant industrial sector, under economically and technically viable conditions, advantages balanced against costs

Techniques
the technology used and the way the installation is designed, built, maintained, operated and decommissioned

From Article 9(4)

permit conditions must, without prejudice to compliance with environmental quality standards, be based on the best available techniques, without prescribing the use of any technique or specific technology, but taking into account the technical characteristics of the installation concerned; its geographical location; and the local environmental conditions.

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;

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 the environment; The information published by the Commission pursuant to Article 17 (2)

Article 17(2) - Exchange of information

The Commission shall organise an exchange of information between 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.

32 BAT Reference Documents (BREFs) adopted by the Commission based on an information exchange

Member State experts

European Commission IPPC Bureau

Industry experts

NGO experts

LCP BREF
http://eippcb.jrc.es/reference/ Adopted July 2006 Revision 2012 - 2014

Structure of the LCP BREF

Executive Summary Preface Common Techniques for Energy Generation Common Processes and Techniques to Reduce Emissions from LCPs 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

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

Pollutants considered in LCP BREF

SO2 NOx CO PM10 GHG such as N2O, CO2 Heavy metals Halides Dioxins

BAT unloading, 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

Thermal efficiency

Particulate matter

Heavy metals
As, Cd, Cr, Cu, Ni, Pb, V, Zn:
BAT is high performance dedusting devices (ESP, FF)

Hg, Se:
Flue-gas desulfurisation, SCR

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

SO2 emissions (2)

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)

NOx emissions (2)

The current situation

European Industry is subject to a range of industrial emissions legislation.... IPPC Directive
Waste Incineration Directive Directives related to the titanium dioxide industry Directive on the limitation of emissions of VOC from solvents European Pollutant Emission Register (EPER) European Pollutant Release and Transfer Register (E-PRTR)

Large Combustion Plants (LCP) Directive

This makes enforcement at Community level very difficult and leads to unnecessary administrative burden

Recast of directives on IE
Through the Commissions proposal for a Directive on industrial emissions 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

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

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 the TSAP objectives: LCPs play a key role

Current emissions vs BAT levels

EEA (2008) based on EPER 2004 data

Current emissions vs BAT levels: summary

EPER 2004 data from 450 power plants (EEA study) Uptake of BAT still very incomplete Very significant emission reduction potential if all plants would operate within BAT levels (upper lower end): SO2: 80 - 97% NOx: 59 - 87% LCPD emission inventories 2006 about 70% of LCPs have emissions above BAT levels
Note: analysis excludes opted out + Accession Treaty derogations

Issue 1: Insufficient implementation of Best Available Techniques (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 as it is justified (Article 16(3))

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 of new activities to the scope of IPPC (based on assessment of cost and benefits)
Combustion activities of 20-50 MW capacity

Indicative timeline for the legal proposal

01/2009 12/2007 12/2010 07/2012 01/2014 07/2015 01/2016

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