TURKISH REGULATION ON LARGE COMBUSTION PLANTS

TURKISH REGULATION ON LARGE COMBUSTION PLANTS Neslihan AĞARTAN Environment and Urbanization Expert General Directorate of Environmental Management Air Management Department Industrial Air Pollution IPPC Division

COMPARISON BETWEEN FLUE GAS RELEASING COMBUSTION PLANTS AND PROCESS PLANTS Process plants including combustion: Plants in which fuels are treated with raw materials or the energy gained by fuel is used for drying, roasting or similiar procedures; flue gases and combustion gases are concurrently or separately released from one stack. Power Generation / Combustion Plants: Plants in which the chemical energy gained by combusting fuels is turned into heat energy as well as steam boilers, hot oil boilers, thermal plant boilers, gas turbines, gas engines that provide energy by producing hot water and steam. (Industrial plants) (Power plants and energy generation plants for industrial use)

THE IMPORTANCE OF CONTROLLING AIR POLLUTION CAUSED BY POWER PLANTS Importance : In our country; 60% of SO 2 pollutants and 34% of NO X pollutants are caused by combustion plants 23% of SO 2 pollutants and 11% of NO X pollutants are caused by process plants

REGULATORY CHRONOLGY OF INDUSTRIAL AIR POLLUTION R E G U L AT I O N O N P R O T E C T I N G A I R Q U A L I T Y ( 1 9 8 6 ) R E G U L AT I O N O N T H E C O N T R O L O F I N D U S T R I A L A I R P O L L U T I O N ( 2 0 0 4 ) R E G U L AT I O N O N T H E C O N T R O L O F I N D U S T R I A L A I R P O L L U T I O N ( 2 0 0 6 ) R E G U L AT I O N O N T H E C O N T R O L O F I N D U S T R I A L A I R R E G U L AT I O N O N L A R G E P O L L U T I O N ( 2 0 0 9 ) C O M B U S T İ O N P L A N T S ( 2 0 1 0 )

CURRENT LEGISLATION ON THE CONTROL OF AIR POLLUTION CAUSED BY POWER GENERATION AND PROCESS PLANTS Regulation on the Control of Industrial Air Pollution (RCIAP); published in the Official Journal dated 03.07.2009, numbered 27277, covers combustion plants within any type of power generation and industrial process plants, whose total rated thermal inputs are equal to or greater than 1 MW and which are used for heating purposes regardless of their thermal inputs. Regulation on Large Combustion Plants (RLCP); published in the Official Journal dated 08.06.2010, numbered 27605, drafted as part of transposition of EU 2001/80/EC LCP Directive, covers all power generation plants with total rated thermal input equal to or greater than 50 MW. * RCIAP is currently under revision to be merged with RLCP in one Regulation.

STACK APPROACH PRESCRIBED BY THE CURRENT REGULATION ON THE CONTROL OF AIR POLLUTION CAUSED BY POWER GENERATION AND PROCESS PLANTS Stack approach shall be used according to the total rated thermal input of a power generation plant based on the Regulation on Industrial Air Pollution or Large Combustion Plants One combustion plant may be composed of more than one combustion units releasing their waste gases through one common stack. The total rated thermal input per stack shall be considered as the baseline. Combustion plants with rated thermal input equal to or greater than 50 MW or connected to more than one stacks are defined as Large Combustion Plant which shall be assessed only under LCP Regulation. One combustion installation may be composed of more than one stacks with rated thermal input equal to or greater than 50 MW. Each stack shall be assessed separately as a single Large Combustion Plant. Company Installation Plant / Stack Unit

THE REGULATIONS AS PER RATED THERMAL INPUT OF EACH PLANT Governorates Plant A Total Rated Thermal Input 70 MW LCP Stack 1 Thermal Input 50 MW Stack 2 Thermal input 20 MW RIAPC(Regulation on Industrial Air Pollution Control) Ministry Plant B Thermal input 110 MW Stack 1 Thermal input 40 MW Stack 2 Thermal input 35 MW Stack 3 Thermal input 35 MW RIAPC

THE SCOPE OF LCP REGULATION SCOPE Combustion plants with total rated thermal input equal to or greater than 50 MW, constructed only for energy generation purposes and fired only with solid, liquid or gaseous fuels. OUT OF SCOPE a) Plants in which the products of combustion are used for direct heating, drying or any other treatment of objects or materials: heating furnaces, heat treatment furnaces. b) Post-combustion plants i.e. any technical apparatus designed to purify the waste gases by combustion which is not operated as an independent combustion plant; c) Facilities for regeneration of catalytic cracking catalysts; ç) Facilities for conversion of hydrogen sulphide into sulphur; d) Reactors used in the chemical industry; e) Coke battery furnaces; f) Cowpers (Blast furnaces); g) Gas turbines used on offshore platforms; ğ) Jet, plane, helicopter, ship, train and gas engines; h) Reciprocating disel, petrol and gas engine with internal combustion such as movable generator ı) Waste incinerators.

LCP Regulation (Offical Journal: 08/06/2010-27605) EFFECTIVE DATE For all new plants aside from liquid fuel fired plants; 08/06/2010 For SO 2 parameters of liquid fuel fired * existing plants and liquid fuel * fired new plants; 01/01/2012 For existing plants; 08/06/2019 Existing plants: Before LCP Regulation was published, this definition referred to the plants which were permitted before or after their operations. (*) : As per the Regulation on Reducing Sulphur Content of Certain Fuel Oil Types (In compliance with SCLF Directive); As of 01/01/2012 fuel oil types with more than 1% sulphure content shall not be used within borders of the country.

LCP Regulation - Content General Provisions Emission Limit Values for New Plants - Steam turbines firing solid fuels - Steam turbines firing liquid fuels - Steam turbines firing gaseous fuels - Gas turbines Emission Limit Values for Existing Plants - Steam turbines firing solid fuels - Steam turbines firing liquid fuels - Steam turbines firing gaseous fuels Gas turbines General Requirements Multi-fuel firing plants Adjustments made in plants Conditions for discharging waste gases Malfunction in flue gas treatment plants Requirements for Measurement and Monitoring Measurement methods Assesment of emissions Reporting conditions Various and Final Provisions Derogations Stricter conditions Penalty provisions Repealed provisions Permitting procedure Enforcement Implementation Annexes

Operation Rules for the NEW PLANTS Article 5: Emission Limit Values for SOLID FUELS: ANNEX-1 (Based on 6% O 2 volume) Emisyon Sınır Değerleri (mg/nm 3 ) Yakıt türü Yakıt Isıl Gücü Toz SO 2 NO 2 (NO ve NO 2 ) CO Katı yakıt Petrol koku Biyokütle 50 MW Yakıt ısıl gücü <100 MW 50 850 400 150 Yakıt ısıl gücü 100 MW 30 200 200 200 50 MW Yakıt ısıl gücü <100 MW 20 400 400 150 Yakıt ısıl gücü 100 MW 20 200 200 200 50 MW Yakıt ısıl gücü <100 MW 200 400 100 MW Yakıt ısıl gücü <300 MW 200 300 Yakıt ısıl gücü 300 MW 200 200 Furthermore; for Benzopyrenes 0,001 mg/nm 3 emission limit value shall not be exceeded. In case the emission limit values for SO 2 can not be complied due to characteristics of the fuel; desulphurization rate of 92%-95% can be applied.

Operation Rules for the NEW PLANTS Article 6: Emission Limit Values for LIQUID FUELS: ANNEX-2 (%3 Hacimsel O 2 esas alınarak) Emisyon Sınır Değerleri (mg/nm 3 ) Yakıt Isıl Gücü Toz SO 2 NO 2 (NO ve NO 2 ) CO 50 MW Yakıt ısıl gücü <100 MW 50 400-200 100 MW Yakıt ısıl gücü<300 MW 30 (lineer azalma) 200 Yakıt ısıl gücü 300 MW 200 850 400 80 Furthermore; total emission limit value of 1 mg/nm 3 can not be exceeded for heavy metals.

Operation Rules for the NEW PLANTS Article 7: Emission Limit Values for GASEOUS FUELS: ANNEX-3 Yakıt türü Genel Durum Doğal gaz, fuel gaz, LPG, vb. (Based on 3 % O 2 volume) Emisyon Sınır Değerleri ( mg/nm 3 ) Yakıt Isıl Gücü NO 2 Toz SO 2 (NO ve NO 2 ) 50 MW Yakıt ısıl gücü <300 MW 150 Yakıt ısıl gücü 300 MW 5 35 100 Yüksek fırın gazı 10 200 Demir-çelik sanayinde ortaya 400* çıkan ve başka yerlerde de 30 kullanılabilecek olan gazlar 200** Sıvılaştırılmış gaz 5 5 Kok fırınında oluşan düşük kalorili gazlar 30 400 Yüksek fırınlarda oluşan düşük kalorili gazlar 10 200 200 CO 100

Operation Rules for the NEW PLANTS Article 8: Emission limit values for GAS TURBIMES: ANNEX-4 (Based on 15% O 2 volume) Emisyon Sınır Değerleri (mg/nm 3 ) Yakıt türü SO 2 NO 2 (NO ve NO 2 ) CO İslilik (Bacharach) Genel olarak gaz yakıtlar 11,7 Sıvılaştırılmış gaz 1,7 Kok fırınında oluşan düşük 117 kalorili gazlar Yüksek fırınlarda oluşan 67 düşük kalorili gazlar 120 100 Doğal gaz 11,7 50 Gaz yakıtlar (doğal gaz 120 hariç) Sıvı yakıtlar 120 2 (sürekli çalışma) 4 (başlama)

Operation Rules for the NEW PLANTS Article 8: Emission Limit Values for GAS TURBINES Gas turbines used only for emergency cases and operated less than 500 hours per year, shall be subject to derogation for NO X and CO emission limit values. Operators of such plants shall submit all the records including operating hours of the previous year, the gas amounts consumed during emergency and frequency of emergecy cases to the competent authority by adding dates (year/day) every year until 31st of January. This derogation and obligation are valid for existing plants.

Operation Rules for the NEW PLANTS Article 9: Cogeneration* of Heat and Energy The operators of new plants or plants with renewed capacity ** shall provide information and conduct research and development activities upon request of a competent authority considering market conditions according to technical and economic feasibility study results of cogeneration and combined cycled heat and power generation in order to abate green house gases discharged by combustion systems and to ensure energy efficiency. Cogeneration and combined cycle: It is the use of heat engine or power station to simultaneously generate electricity and useful heat or to make use of waste heat released from all heat engines. Plants covered by** Article 15 (increasing or altering plant capacities)

Operation Rules for the NEW PLANTS Article 10: Emission Limit Values for SOLID FUELS: ANNEX-5 (Based on 6% O 2 volume) Emisyon Sınır Değerleri (mg/nm 3 ) Yakıt türü Katı yakıt Petrol koku Yakıt Isıl Gücü 50 MW Yakıt ısıl gücü <100MW 100 MW Yakıt ısıl gücü <500 MW 100 Yakıt ısıl gücü 500 MW Toz SO 2 2000 2000-400 (lineer azalma) NO 2 (NO ve NO 2 ) 600 50 400 200 50 MW Yakıt ısıl gücü <100 MW 600 20 400 Yakıt ısıl gücü 100 MW 200 CO 200 Furthermore; the emission limit value of 0,001 mg/nm 3 for Benzopyrene shall not be exceeded.

Operation rules for EXISTING PLANTS Article10: Emission limit Values for SOLID FUELS: ANNEX-5 Derogations: For old plants dust limit values can be more flexible In cases when characteristic features of fuel prohibit compliance with emission limit values, 60%94% desulphurization rate can be used for SO 2 For plants with less operating hours, SO 2 and NO 2 limit values can be more flexible For fuels with less volatile content, NO 2 limit values can be more flexible.

Operation rules for EXISTING PLANTS Article 11: Emission limit Values for LIQUID FUELS: ANNEX-6 (Based on 3% O 2 volume) Yakıt Isıl Gücü 50 MW Yakıt ısıl gücü <300 MW 300 MW Yakıt ısıl gücü<500 MW Emisyon Sınır Değerleri (mg/nm 3 ) Toz SO 2 Ayrıca; ağır metaller için toplam olarak 2 mg/nm 3 emisyon sınır değeri aşılamaz. However, for fuels with high ash content dust emission limit values can be more flexible. 50 1700 1700-400 (lineer azalma) NO 2 (NO ve NO 2 ) Yakıt ısıl gücü 500 MW 400 400 450 CO 150

Operation rules for EXISTING PLANTS Article 12: Emission limit Values for GASEOUS FUELS: ANNEX-7 (Based on 3% O 2 volume) Emission Limit Values (mg/nm 3 ) Fuel Type Fuel thermal input Dust SO 2 NO 2 (NO ve NO 2 ) CO General situation, natural gas, fuel gas, LPG, etc. Blast furnace gas 50 MW Fuel thermal input <500 MW 5 35 Fuel thermal input 500 MW 200 50 MW Fuel thermal input<500 MW 10 800 Fuel thermal input 500 MW 200 300 300 Gases produced and used in Iron and Steel Industry and in other industries. 50 MW Fuel thermal input <500 MW Fuel thermal input 500 MW 50 35 200 300 100 50 MW Fuel thermal input <500 MW 300 Liquefied gases 5 5 Fuel thermal input 500 MW 200 Gases with low calorific value, which are produced by gasification of refinery 50 MW Fuel thermal input <500 MW 5 800 300

Operation Rules for the NEW PLANTS Article 13: Emission limit Values for GAS TURBINES: ANNEX-8 (Based on 15% O 2 volume) Yakıt türü NO 2 (NO ve NO 2 ) Doğal gaz 75 Gaz yakıtlar (doğal gaz hariç) 120 Sıvı yakıtlar 120 07/10/2004 ten önce faaliyete geçenler 300 Emisyon Sınır Değerleri (mg/nm 3 ) CO 100 Upon written applications the competent authority may grant derogations on the restriction of CO emissions.

Operation Rules for ALL PLANTS Parameters for complying with limit values by single measurement Hidrojenklorür (HCl) 100 mg/nm 3 Hidrojenflorür (HF) 15 mg/nm 3

Article 14: Double or Multi-Fuel Fired Plants Fuel based emission limit values are calculated for double or multi-fuel plants. Limit values must be calculated based on the fuel with the highest emission limit values in multi-fuel units of crude oil refineries. Emission limit values valid for new and existing plants must be used for plants with multi-fuel units firing two or more fuels as alternative.

Article 15: Increasing or Changing the Capacities of The Plants If the capacity of a combustion plant is increased at least up to 50 MW, the emission limit values valid for the new plants must be calculated according to the total thermal capacity of the plant and must also be used for its newly built sections. If a change in plant capacity is seen as hazardous for human and environmental health, the emission limit values valid for new plants must be complied with.

Article: 16 Conditions for Stack Discharge of Waste Gases According to the Annex 4 of the RCIAP concerning waste gases of combustion plants (Identification of stack height and speed for plants subject to permission) must be disposed through stacks in a controlled manner in line with the specified conditions in order to protect human and environmental health. These conditions are stated on the permits given to the plant operators.

Article: 17 Malfunction or Failure in Flue Gas Treatment Equipment When flue gas treatment equipment breaks down or fails, it must be fixed in 24 hours. If not, the operator must reduce the capacity or shut down the system or operate the plants by using fuels with low pollutant content. Operators must inform the compotent authority within 48 hours in such cases. Plants can not be operated without flue gas treatment over 120 hours in 12 months.

Measurement and Monitoring Article 18: Measurement Methods The operator must measure SO 2, NO X, CO and dust concentrations and parameters with specified emission limit values in waste gases discharged from all combustion plant stacks by using a continuous measurement device. Continous measurement systems must be checked at least once a year by using parallel measurements and referance methods. The competent authority must be informed in writing of all measurements and measurement results until 31st of next March.

Article 19: Assesment of Emissions Measurement and Monitoring For continuous measurements any confirmed hourly average value must not exceed 200% during total operating hours in one calendar year. Other related daily values must also be in compliance with prescribed limit values. For discontunious measurements or in cases where other kinds of measurements conforming to standards must be done, the results of each measurement serials or other monitoring results prescribed by the competent authority must not exceed emission limit values. For combustion plants obliged to comply with desulphurization rates, the continously monitored SO 2, NO X, CO and dust concentrations as well as daily measured sulphure content of fuel must be considered as in compliance with the limit values so long as daily average values aren t exceeded. The malfunction and failure or start up and shut down periods of flue gas treatment equipment must not be included in calculations.

Measurement and Monitoring Article 20: Reporting Principles The report including the following data about the combustion plant must be submitted to the competent authority until 31st of next March : Total annual SO 2, NO X and dust emissions Total annual energy input calculated with lower heating value including five fuel types which are biomass, other solid fuels, liquid fuels, natural gas and other gases.

Article 21: Derogations Concerning Energy Bottle Necks A competent authority may grant DEROGATIONS from emission limit values in line with the following terms and conditions; 1. In case of fuel shortage, maximum 6 months for SO 2; 2. In case other fuels are in use due to fuel shortage; maximum 10 days for all parameters.

Article 22: Restrictive Measures Protection Areas If the hazardous impacts of air pollution resulting from industry, transportation and heating on human beings and environment can not be prevented by conventional measures, these areas can be declared as protection areas. The competent authority: can prohibit establishment of permanent plants; can prohibit operations of mobile and permanent plants; can allow mobile and permanent plants to operate at certain times or to operate only with high level operation techniques; can prohibit or restrict fuel consumption of plants.

Article 22: Restrictive Measures In order to protect human and environmental health in cities or towns where critical weather conditions predicted or prevail and where air pollution reaches high levels, the competent authority is able to: allow operators of mobile or permanent combustion plants to operate only at certain times; prohibit or restrict use of certain fuel types with ultimately hazardous air pollutants. In cases when air pollution increasingly reaches critical levels; the warning levels determined by the regulation on Air Quality Assesment and Management must be used. If air quality levels are exceeded in one area and reach to the levels mentioned in RCIAP Annex-2 (Calculating the contribution of combustion plants to the air pollution and measuring air quality) the measures must be taken by the concerned Governorate by taking consent of the MoEU.

PREVENTING INDUSTRIAL AIR POLLUTION WITH AN INTEGRATED APPROACH IN THE EU As of 2016, LCP Directive will gradually be replaced by Industrial Emissions Directive for existing plants. The relevant chapter of the IED (Chapter III) will come into force. INTEGRATED POLLUTION PREVENTION AND CONTROL DIRECTIVE (IPPCD) INDUSTRIAL EMISSIONS DIRECTIVE (IED) dated X2010/75/EU SOLVENT EMISSIONS DIRECTIVE (SED) LARGE COMBUSTIO N PLANT DIRECTIVE( LCPD) WASTE INCINERATI ON DIRECTIVE (WID) 3 DIRECTIVES ON TITANIUM DIOXIDE

GENERAL DIRECTORATE OF ENVIRONMENTAL MANAGEMENT Thank you for your attention... neslihan.agartan@csb.gov.tr