Requirements concerning Large Combustion Plants under the IPPC Directive. Christian Wimmer

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1 Requirements concerning Large Combustion Plants under the IPPC Directive Christian Wimmer

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

3 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)

4 Annex 1 to IPPC Directive Energy industries Production and processing of metals Mineral industries Chemical industry Waste management Others activities

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

6 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

7 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 SO NOx 500 / 200 (as of 2016)

8 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 deadline.

9 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

10 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

11 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

12 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.

13 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;

14 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)

15 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.

16 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

17 LCP BREF Adopted July 2006 Revision

18 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

19 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

20

21

22 Pollutants considered in LCP BREF SO 2 NOx CO PM10 GHG such as N 2 O, CO 2 Heavy metals Halides Dioxins

23 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

24 Thermal efficiency

25 Particulate matter

26 Heavy metals As, Cd, Cr, Cu, Ni, Pb, V, Zn: BAT is high performance dedusting devices (ESP, FF) Hg, Se: Flue-gas desulfurisation, SCR

27 SO 2 emissions (1) BAT is > 100 MW < 100 MW to use low sulfur fuel desulphurisation In addition, abatement measures Due to high costs, wet scrubber is not BAT

28 SO 2 emissions (2)

29 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)

30 NOx emissions (2)

31 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 Large Combustion Plants (LCP) Directive Directive on the limitation of emissions of VOC from solvents 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

32 Recast of directives on IE Through the Commission s 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

33 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

34 1. Problem identification LCPs: main source of industrial emissions 74% (SO 2 ), 49% (NO x ) of 2005 NECD industrial emissions 60% (SO 2 ), 19% (NO x ) 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

35 Current emissions vs BAT levels EEA (2008) based on EPER 2004 data

36 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): SO 2 : 80-97% NO x : 59-87% LCPD emission inventories 2006 about 70% of LCPs have emissions above BAT levels Note: analysis excludes opted out + Accession Treaty derogations

37 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))

38 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 MW capacity

39 Indicative timeline for the legal proposal 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 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

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