LCP BREF review – IED Art.13 Forum Meeting Brussels, CCAB, 20 October 2016 Final Draft for the opinion of the IED Article 13 forum Revised Best Available Techniques (BAT) Reference Document for Large Combustion Plants (LCP BREF)
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Final Draft for the opinion of the IED Article 13 forum
Revised Best Available Techniques (BAT)
Reference Document for
Large Combustion Plants (LCP BREF)
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Outline of the presentation
Scope of the LCP BREF
Overview of the LCP BREF review process
Structure of the revised LCP BREF
Main changes in the revised LCP BREF
Key features of the BAT conclusions
Comments received from IED Article 13 forum members on the Final Draft of the revised LCP BREF
Issues proposed for clarification or discussion
2
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Scope of the LCP BREF
The BREF covers the following activities within the scope of
Annex I of Directive 2010/75/EU:
1.1: Combustion of fuels in installations with a total rated
thermal input of 50 MW or more, only when this activity takes
place in combustion plants with a total rated thermal input of
50 MW or more.
1.4: Gasification of coal or other fuels in installations with a
total rated thermal input of 20 MW or more, only when this
activity is directly associated to a combustion process.
5.2: Disposal or recovery of waste in waste co-incineration
plants for non-hazardous waste with a capacity exceeding 3
tonnes per hour or for hazardous waste with a capacity
exceeding 10 tonnes per day, only when this activity takes
place in combustion plants covered under 1.1 above.
3
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Issues covered by the LCP BREF (1/3)
General processes and techniques applicable to LCP in
general
Gasification
Combustion of solid fuels:
coal/lignite
biomass/peat
Combustion of liquid fuels
in boilers
in engines
in turbines
4
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Issues covered by the LCP BREF (2/3)
Combustion of gaseous fuels:
Natural gas
in boilers
in engines
in turbines
Iron and steel process gases
in boilers
in turbines
Combustion of gaseous and/or liquid fuels on offshore
platforms
5
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Issues covered by the LCP BREF (3/3)
Multi-fuel combustion
Solid multi-fuel combustion
Combustion of liquid and gaseous process fuels
from the chemical industry
Co-incineration of waste
6
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Overview of the LCP BREF review process (1/2)
Main steps Date
TWG reactivation January 2011
Call for wishes March 2011
Kick-off meeting October 2011
Collection of information (deadline) June 2012
Draft 1 June 2013
Commenting period, 8510 comments (deadline) September 2013
24 Site visits in 7 Member States (until) October 2013
Additional data collection for averaging periods March-June 2014
7
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Overview of the LCP BREF review process (2/2)
Main steps Date
Informal intermediate TWG meeting June 2014
Data collection on energy efficiency (deadline) October 2014
Draft revised BAT conclusions + background paper April 2015
Final TWG Meeting 1-9 June 2015
"Leftovers" addressed by webinar and written consultation
July-September 2015
Revised draft BREF after final TWG meeting February 2016
Final Draft for the opinion of the IED Article 13 forum
June 2016
8
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Information exchange
~ 580 plant level
questionnaires ~ 225 reports, case
studies 24 Site visits in 7
Member States
TWG Subgroup on
gasification
TWG Task force on
energy efficiency (2014)
Data collection for
averaging periods
(2014)
8510 Comments to
D1 / ~ 200 attached
documents
Draft text proposals
Bilateral meetings
Informal intermediate TWG
meeting (June 2014)
LCP BREF review process: knowledge / transparency
Largest EIPPCB database of
plant-specific data
9
289 TWG Members
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Structure of the revised LCP BREF (1/2)
Preface
Scope
Chapter 1 – General information on the structure of the sector
Chapter 2 – Processes for energy generation
Chapter 3 – General techniques to prevent and/or reduce emissions and consumption
Chapter 4 – Gasification
Chapter 5 – Combustion of solid fuels
Chapter 6 – Combustion of liquid fuels
Chapter 7 – Combustion of gaseous fuels
10
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Structure of the revised LCP BREF (2/2)
Chapter 8 – Multi-fuel combustion
Chapter 9 – Waste co-incineration
Chapter 10 – BAT conclusions
Chapter 11 – Emerging techniques
Chapter 12 – Concluding remarks and recommendations for future work
Chapter 13 – Annexes
Glossary
References
11
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Main changes in the revised LCP BREF
A general update of the document
Plant-specific data from LCP questionnaires
presented in numerous tables and graphs
Exclusion of process furnaces/heaters
New chapter on gasification
New subchapter on the combustion of process gases
in iron and steel works
New subchapter on the combustion of process fuels
from the chemical industry
New specific sections on mercury
BAT conclusions in line with IED requirements
12
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Structure of the BAT conclusions (1/2)
Scope, definitions , general considerations
10.1 General BAT conclusions:
• Environmental Management Systems (EMS)
• Monitoring of emissions to air and water
• General environmental and combustion performance
• Energy efficiency
• Water usage and emissions to water
• Waste management
• Noise emissions
13
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Structure of the BAT conclusions (2/2)
10.2 - 10.7 BAT conclusions for the combustion of specific
fuel types (see structure of BREF). They cover:
• General environmental performance
• Energy efficiency
• NOX, N2O, CO, VOC and CH4 emissions to air
• SOX, HCl, HF emissions to air
• Dust and particulate-bound metal emissions to air
• Mercury, PCDD/F emissions to air
10.8 Description of techniques
14
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Key features of the BAT conclusions (1/2)
A total of 74 BAT conclusions set for the whole LCP
sector
72 BAT-AEEL ranges for energy efficiency
15 BAT-AEL ranges for emissions to water
257 BAT-AEL ranges for emissions to air, including also
Emissions of Hg, HCl, HF, particulate-bound metals
Emissions from off-shore platforms
Emissions from diesel engines
Detailed BAT conclusions on monitoring of emissions to
air and water 15
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Key features of the BAT conclusions (2/2)
For emissions to air from new plants (generally):
Daily and yearly average BAT-AELs
Indicative yearly levels for CO
For emissions to air from existing plants (generally):
Daily and yearly average BAT-AELs for plants
operated ≥ 1500 h/yr
Only daily average BAT-AELs for plants operated
between 500 h/yr and 1500 h/yr
Indicative daily levels for plants operated <500 h/yr
Indicative yearly levels for CO for plants operated ≥
1500 h/yr
16
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Degree of consensus
High degree of consensus on most BAT conclusions
89 split views assessed as valid and recorded in
Chapter 12
17
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Comments of the IED Article 13 forum on the Final Draft
TOTAL Considered consensual
Considered consensual subject to
certain amendments
Considered as representing the views of
certain members
Comment on the process -
considered not relevant for
the forum opinion
454
32 Member States and
organisations
67 51 329 7
18
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Issues proposed for clarification (1-3)
Issue to clarify
(Comment no.)
Classification and source of comment
Considered consensual
Considered
consensual
subject to certain
amendments
Considered as
representing the
views of certain
members
IED Art. 32-35
derogations
(59, 60, 61, 62)
FR 1, PL 1,
EURELECTRIC 1,
Euroheat&Power
3
Exclusion of units
<15MWth from scope
(63-66)
FR 2, SE 6,
EURELECTRIC 2,
Euroheat&Power 4
Operating hours
thresholds for CO
levels
(331–335)
IT 6, MARCOGAZ 2,
EUTurbines 12, ETN
14, EURELECTRIC 41
19
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
IED Art.32-35 derogations [# 59, 60, 61, 62] (1/2)
Eurelectric 1, Euroeheat&Power 3: Add an explicit reference
to IED articles 33, 34 and 35 temporary derogations either
in the scope the BAT conclusions or in the definition of
combustion plant.
FR 1: Introduce in the scope the following provision:
"These BAT conclusions do not address the following: [...]-
combustion plants benefitting from limited life time
derogation according to the article 33 of the directive
2010/75/EU on industrial emissions.„
PL 1 "BAT AELs set in these BAT conclusions do not apply to
combustion plants, benefiting from derogation mechanisms,
set in article 32 to 35 of IED, until a given derogation ends.
20
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
IED Art.32-35 derogations [# 59, 60, 61, 62] (2/2)
21
Proposal: consider related comments as non-consensual.
Issue already partially addressed in FAQ: "For combustion
plants benefitting from the time-limited and specific
derogation provisions of Articles 32 to 35, Article 15(3)
does not apply for certain air pollutants and these plants
are not required, for those air pollutants, to comply in
addition with the conditions for the derogation set out in
Article 15(4);
- TNP plants and Article 34 plants not concerned as they
come to an end of derogations before BATC become
applicable
- Derogations are limited in scope and time
- Remaining issues can be dealt with under Article 15(4)
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Exclusion from Scope of Units < 15 MWth [# 63 - 66] (1/2)
22
FR 2, SE 6, Eurelectric 2, Euroeheat&Power 4: Re-introduce
in the scope the provision of draft D1: "These BAT
conclusions do not address the following activities:
combustion of fuels in units with a rated thermal input of
less than 15 MWth"
This text was removed after D1 as it was considered already
included in the definition of combustion plant.
However, the 15 MWth threshold in the definition only refers to the
calculation of the total rated thermal input of an aggregated
combustion plant, which does not exclude from the scope units of
less than 15 MWth that are part of a combustion plant ≥ 50 MWth
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Exclusion from Scope of Units < 15 MWth [# 63 - 66] (2/2)
23
The data collection, consistently with the conclusions of the
KoM on activities to be covered within the scope of the LCP
BREF review, included
1.1 Combustion in installations with total rated thermal input of 50
MWth or more, including plants composed of aggregated units
of 15 MWth or more, and including diesel engines, gas turbines
and gas engines on off-shore platforms.
Proposal: Re-introduce in the scope the mentioned provision
of D1 excluding from the scope the combustion of fuels in
units with a rated thermal input of less than 15 MWth
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Operating hours thresholds for CO levels [# 331 - 335] (1/3)
IT 6, MARCOGAZ 2, EUTurbines 12, ETN 14, EURELECTRIC 41: Delete
the reference to '≥ 500 h/yr' in the bullet points of the statement
for indicative CO levels after Table 10.27, as indicative CO levels for
existing plants should only refer to ≥ 1500 h/yr:
‘As an indication, the yearly average CO emission levels will generally be as
follows for each type of existing combustion plant operated ≥ 1500 h/yr
and for each type of new combustion plant:
• ...
• Existing OCGT of ≥ 50 MWth and operated ≥ 500 h/yr (excluding
turbines for mechanical drive applications): < 5–40 mg/Nm3…
• …
• …
• Existing gas turbines of ≥ 50 MWth for mechanical drive applications
operated ≥ 500 h/yr: < 5–40 mg/Nm3…’
24
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Operating hours thresholds for CO levels [# 331 - 335] (2/3)
It was agreed at the FM:
to ‘set yearly average indicative emission levels for
CO as a general approach’;
not to set yearly average emission levels for existing
plants operated < 1500 h/yr
Being indicative levels, it was decided to move them
outside (just below) the NOx BAT-AEL tables.
While doing so, levels for plants operated < 1500 h/yr
were erroneously reported where BAT-AELs were defined
for NOx
For consistency with the agreed general conclusions on
CO indicative levels and on plants operated < 1500 h/yr,
and to avoid confusion, the CO indicative levels should
only be defined for new plants and for existing plants
operated ≥ 1500 h/yr
25
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Operating hours thresholds for CO levels [# 331 - 335] (3/3)
Proposal 1: Consider as consensual deleting the reference to '≥
500 h/yr' in the bullet points of the statement for CO indicative
levels after Table 10.27:
‘As an indication, the yearly average CO emission levels will generally be
as follows for each type of existing combustion plant operated ≥ 1500 h/yr
and for each type of new combustion plant:
• Existing OCGT of ≥ 50 MWth and operated ≥ 500 h/yr (excluding
turbines for mechanical drive applications): < 5–40 mg/Nm3…
• Existing gas turbines of ≥ 50 MWth for mechanical drive applications
operated ≥ 500 h/yr: < 5–40 mg/Nm3…’
Proposal 2: To check throughout the BAT conclusions and change if
needed the BAT statements so that indicative CO levels are clearly
and only set for new plants and existing plants operated ≥ 1500
h/yr
26
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Issues proposed for discussion (1-3)
Classification and source of comment
Issue to discuss (Comment no.)
Considered consensual
Considered consensual subject to certain
amendments
Considered as representing the views of certain
members
Table 10.27 –footnote 13 NOx for OCGT with
EE>39% Extension to existing OCGT (323, 339)
EUTurbines 9, ETN 11
Plant/Unit size thresholds for BAT- AEELs (310–314)
IT 4, MARCOGAZ 1,
EUTurbines 5, ETN 6, EURELECTRIC 37
Table 10.3 – footnote 7 NOx for coal plants older
than 1987 operated <1500 h/yr (170–173)
BE 3, FR 4, EEB 6, EEB 14
27
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Issues proposed for discussion (4-5)
Issue to discuss (Comment no.)
Classification and source of comment
Considered consensual
Considered consensual subject to certain amendments
Considered as representing the views
of certain members
Table 10.20 NOX for new HFO- and gas-oil-fired engines (273, 276, 278, 280)
FR 3, GR 6,
EUROMOT 13, EURELECTRIC 29
Measurement uncertainty/ BAT-AELs
(98-100, 105-109, 120-123, 179, 180, 195-197, 203-205, 214-216, 244, 245, 252, 253,
258-261, 376, 384-395)
CEWEP, ESWET, FEAD, Cefic, FuelsEurope,
EURELECTRIC, Euroheat&Power, ETN, EUTurbines
28
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for existing OCGT with EE>39% [# 323 - 339] (1/2)
EUTurbines 9, ETN 11: Apply footnote 13 also to existing
plants 29
Table 10.27: BAT-AELs for NOX for gas turbines
Type of combustion plant
Combustion plant total
rated thermal input (MWth)
BAT-AELs (mg/Nm3) (3) (22)
Yearly average (7) (14)
Daily average or average over the sampling
period
Open-cycle gas turbines (OCGTs) (11)
New OCGT ≥ 50 15–35 (13) 25–50 (13) Existing OCGT (excluding
turbines for mechanical drive applications) – All but plants
operated < 500 h/yr
≥ 50 15–50 25–55 (5)
(13) For plants with a net electrical efficiency (EE) greater than 39 %, a correction factor may be applied to the higher end of the range, corresponding to [higher end] x EE / 39, where EE is the net electrical energy efficiency or net mechanical energy efficiency of the plant determined at ISO baseload conditions.
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for existing OCGT with EE>39% [# 323 - 339] (2/2)
The BAT-AELs and footnotes were agreed during the FM
The footnote on the use of a correction factor for highly
efficient turbines was discussed for new plants which
present the higher potential to achieve high level of energy
efficiency
The reasoning is also valid in the case of existing plants that
could be retrofitted to achieve high level of energy
efficiency.
There would be no reason for not applying the same criteria
for existing plants
Proposal: To apply footnote 13 to existing plants, and
likewise for CCGT: to apply the agreed correction factor
(footnote 12) for new highly efficient plants (with EE>55 %)
also to existing CCGT plants
30
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Plant/Unit size thresholds for BAT-AEELs [# 310 - 314] (1/3)
IT 4, Marcogaz 1, EUTurbines 5, ETN 6, Eurelectric 37: Keep '≥ 50
MWth' for 'Gas turbine' Open Cycle Gas Turbine in Table 10.26 as
presented in the pre-Final Draft (February 2016)
instead of
Type of combustion
unit plant
BAT-AEELs (3) (7)
Net electrical efficiency
(%)
Net total
fuel
utilisation
(%) (2) (8)
Net mechanical energy
efficiency (%) (5) (8)
New unit
plants
Existing
unit plants
New unit
plant
Existing
unit plant
Open-cycle gas turbine
Gas turbine ≥ 50 MWth 36–41.5 33–41.5 No BAT-AEEL 36.5–41 33.5–41
Table 10.26: BAT-AEELs for the combustion of natural gas
Open-cycle gas turbine
Gas turbine 36–41.5 33–41.5 No BAT-AEEL 36.5–41 33.5–41
31
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Plant/Unit size thresholds for BAT-AEELs [# 310 - 314] (2/3)
The BAT-AEELs were agreed during the written consultation
on the remaining leftovers of the FM
The basis was the report of the TWG Taskforce for Energy
Efficiency, collected data from the questionnaires and
submitted comments on the reference plants of the LCP
BREF review. Those included units of ≥ 15 MWth in
combustion plants of ≥ 50 MWth
The limitation '≥ 50 MWth' was removed because redundant
with the scope
For consistency with the underlying data analysis, when
differentiations by size ranges are stated, the BAT-AEELs
should be understood as energy efficiency levels for units
operating in plants within the size range
32
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Plant/Unit size thresholds for BAT-AEELs [# 310 - 314] (3/3)
Proposal: To change the top-left heading of all BAT-AEEL
tables consistently with those on BAT-AELs. Remove in Table
10.26 references to plants ≥ 50 MWth to avoid redundancies
with the scope
Type of combustion unit
Combustion plant rated
thermal input (MWth)
BAT-AEELs
Net electrical
efficiency (%)
Net total
fuel
utilisation
(%)
Net mechanical energy
efficiency (%)
New
unit
Existing
unit New unit
Existing
unit
Open-cycle gas turbine
Gas turbine
Combined-cycle gas turbine (CCGT)
CCGT, 50– < 600 MWth
CCGT, ≥ 600 MWth
CHP CCGT, 50– < 600 MWth
CHP CCGT, ≥ 600 MWth
33
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for coal plants <1987 operated <1500h/yr [# 170 - 173] (1/4)
Consolidated final meeting conclusions and Pre-Final Draft:
Combustion plant total
rated thermal input
(MWth)
BAT-AELs (mg/Nm3)
NOX
Yearly average Daily average …
New
plant
Existing
plant New plant Existing plant
≥ 300 coal-fired PC boiler 65–85 65–150 80–125 < 85–165 (7)
(7) In the case of plants put into operation no later than 1st July 1987,
which are operated less than 1500 hours per year and for which SCR
and/or SNCR is not applicable, the higher end of the range is 340 mg/Nm3.
Table 10.3: BAT-AELs for NOX from the combustion of coal and lignite
34
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for coal plants <1987 operated <1500h/yr [# 170 - 173] (2/4)
Final Draft:
Combustion plant total rated thermal input
(MWth)
BAT-AELs (mg/Nm3) Daily average or average over the sampling period
New plant Existing plant (7) < 100 165–330 100–300 155–210 ≥ 300, FBC boiler combusting coal and/or lignite and lignite-fired PC boiler
140–165 (10)
≥ 300, coal-fired PC boiler < 85–165 (6)
(7) In the case of plants put into operation no later than 1 July 1987, which are operated < 1500 h/yr and for which SCR and/or SNCR is not applicable, the higher end of the range is 340 mg/Nm3. (6): 220 mg/Nm3 for plants <2014 and operated <1500 hr/yr (10): 220 mg/Nm3 for coal-fired FBC <2014 and lignite-fired FBC
35
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for coal plants <1987 operated <1500h/yr [# 170 - 173] (3/4)
BE 3: Restore application of footnote (7) in Table 10.3 only to
coal-fired PC boilers ≥300
FR 4, EEB 6.1: delete footnote
EEB 6.2: amend footnote to "In the case of coal fired PC plants
put into operation no later than 1 July 1987, which are operated
<1500h/yr and for which SCR and/or SNCR is not applicable, the
higher end of the range is 340mg/Nm3, subject to prior
validation of a derogation pursuant to Article 15(4) of the
IED"
EEB 14: amend footnote to "In the case of coal fired PC plants
put into operation no later than 1 July 1987, which are operated
<1500h/yr and will stop operating by 2024 and for which
SCR and/or SNCR is not applicable, the higher end of the range
is 340mg/Nm3"
•
36
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for coal plants <1987 operated <1500h/yr [# 170 - 173] (4/4)
TWG Agreed technical and economic restrictions for retrofitting
SCR to existing plants operated < 1500 h/yr
TWG Agreed restrictions for SNCR applicability:
boilers with a high cross-sectional area
plants operated < 1500 h/yr with highly variable boiler loads
For lignite-fired PC boilers and for FBC boilers, the levels agreed at
the FM are considered generally achievable with primary
techniques
Proposal: To change 'plants' by 'coal-fired PC plants' in footnote
(7) to Table 10.3 as presented in the Final Draft: "In the case of
coal fired PC plants put into operation no later than 1 July 1987,
which are operated <1500h/yr and for which SCR and/or SNCR is
not applicable, the higher end of the range is 340mg/Nm3"
•
37
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for NEW HFO- and gas-oil-fired engines [# 273, 276, 278, 280] (1/4)
38
Consolidated final meeting conclusions and Final Draft:
Table 10.20: BAT-AELs for NOX from the combustion of HFO and/or gas oil
in reciprocating engines
Combustion plant total
rated thermal
input (MWth)
BAT-AELs (mg/Nm3)
NOX
Yearly average Daily average or average over the sampling period
New plant Existing
plant (2)(4) New plant
Existing plant
(3)(5)(6) ≥ 50 115–225 125–625 145–225 150–750
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for NEW HFO- and gas-oil-fired engines [# 273, 276, 278, 280] (2/4)
39
FR 3: Increase the higher end of the daily NOX BAT-AEL range to
245 mg/Nm3 and keep the yearly NOX BAT-AEL at 225 mg/Nm3
GR 6, EUROMOT 14, Eurelectric 29: Increase the higher end of
the daily NOX BAT-AEL range to 300 mg/Nm3 and that of the
yearly NOX BAT-AEL to 240 mg/Nm3, for new plants fitted with
SCR and located in remote islands
The levels proposed by GR 6, EUROMOT 14, Eurelectric 29
correspond to the performance of plant 691, which was taken as
reference as engine plant equipped with SCR to set the high end
of the BAT-AEL range in an interim proposal of the EIPPCB at
the final meeting
This level was finally capped at 225 mg/Nm3 by the TWG at the
FM for consistency with the technical annexes to the
Gothenburg Protocol (GP), subject to further consistency check
with the GP (recording of the FM).
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for NEW HFO- and gas-oil-fired engines [# 273, 276, 278, 280] (3/4)
40
Annex V of the most recent amendment to the GP provides for
the following monthly ELVs for new engines equipped with
SCR:
1-20 MWth: 225 mg/Nm3 (HFO-fired)
>20 MWth: 190 mg/Nm3 (and LFO-fired smaller engines)
It appears therefore that consistency with the GP:
Would not require decreasing the higher end of the daily
BAT-AEL range for NOX below 300 mg/Nm3
Would require decreasing the higher end of the yearly BAT-
AEL for NOX from 225 mg/Nm3 down to 190 mg/Nm3, at least
for gasoil-fired engines and for HFO-fired engines of ≥ 20
MWth
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
NOX for NEW HFO- and gas-oil-fired engines [# 273, 276, 278, 280] (4/4)
41
Proposal:
Table 10.20: BAT-AELs for NOX from the combustion of HFO and/or gas oil
in reciprocating engines
Combustion plant total
rated thermal
input (MWth)
BAT-AELs (mg/Nm3)
NOX
Yearly average Daily average or average over the sampling period
New plant Existing
plant (2)(4) New plant
Existing plant
(3)(5)(6)
≥ 50 115–
225190(7) 125–625
145–225300
150–750
(7) For individual engines of < 20 MWth firing HFO, the higher end of the range is 225 mg/Nm3
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Measurement uncertainties / BAT-AELs (1/3)
42
CEWEP, ESWET, FEAD, Cefic, FuelsEurope, EURELECTRIC,
Euroheat&Power, ETN, and EUTurbines presented a number of
comments for (in synthesis):
Asking CEN to comment on the availability of equipment,
systems and methods to adequately measure emissions within
the range of the BAT-AELs
Inserting recommendations for a feasibility assessment before
setting ELVs based on these BAT conclusions
Referencing a July 2016 INERIS study report as a source of
information for the feasibility of the ELVs
Assessing the lower ends of BAT-AEL ranges in view of EN
standards
Increasing the lower ends of BAT-AEL ranges
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Measurement uncertainties / BAT-AELs (2/3)
43
The TWG set BAT-AELs based on the achieved emission levels
reported by a large number of combustion plants across the EU,
without subtraction of uncertainty
The feasibility of ELVs at low emission levels for some pollutants
was brought to the attention of the TWG as a new issue only at
the stage of the final TWG meeting and later, by ESWET, CEWEP,
CEFIC, EURELECTRIC, FuelsEurope, Euroheat&Power, EUTurbines
None of the data submitted through the questionnaires was ever
challenged by these organisations during the period of exchange
of information
The BREF Guidance (Section 3.2.3) states that it is acceptable to
use expressions such as ‘< X to Y’ (i.e. ‘< X’ for the lower end of
the range, Y for the upper end), where the lower end of the BAT-
AEL range cannot be accurately defined, e.g. when the data
reported in the information exchange is close to the detection
limit
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Measurement uncertainties / BAT-AELs (3/3)
44
The use of BAT-AELs for setting ELVs and the consideration of
measurement uncertainties are implementation and compliance
issues
Member States routinely take account of measurement
uncertainties when monitoring compliance
LCP BREF review – IED Art.13 Forum Meeting
Brussels, CCAB, 20 October 2016
Thank you for your attention
The LCP BREF review team
Thierry, Felix, Fred, Thomas
45