The Medium Combustion Plants Regulations E: info@era.org.mt W: era.org.mt Air Quality and Waste Unit Permitting Unit
Contents of Presentation • What are the Medium Combustion Plants (MCP) Regulations? • Objectives of the MCP Regulations • Scope of the MCP Regulations • Legislative Requirements and Timeframes • Application & Permitting Structure • Exemptions & Derogations • Compliance & Reporting • Regulatory Impact
What are the Medium Combustion Plants Regulations? • Regulations transpose the Medium Combustion Plants Directive which came into effect 25 November 2015. • Transposition of the MCP Directive into national laws is required. • It introduces minimum requirements to regulate emissions of NOx, SO 2 and PM from small power plants and industrial installations . • It places controls on combustion plants of rated thermal input between 1MW and 50MW.
What is Rated Thermal input (RTI) ? • Terms you may be familiar with: – Power output – Fuel type and – Thermal efficiency The rate at which fuel can be burnt at the maximum continuous rating of the combustion plant multiplied by the net heat value of the fuel expressed as Megawatts Thermal.
Examples of Rated Thermal input • The regulation of (MCPs) combustion plants of between 1 and 50MW th – equating to electrical output broadly between 330kW and 17MW. Source: Global Sources Source: Cummins Source: Wärtsilä
Objectives of the MCP Regulations The EU aims to “achieve levels of air quality that do not result in unacceptable impacts on and risks to, human health and the environment’’. The purpose of this Directive, and the Regulations, is to regulate, and ultimately reduce: – Sulphur dioxide (SO 2 ) – Nitrogen oxides (NOx) – Dust emissions • The Regulations also lay down rules to monitor but not regulate emissions of carbon monoxide (CO). • No deterioration of air quality through the use of MCPs is allowed. Source: UNEP GRID-Adrenal
Scope of the MCP Regulations • Various manufacturing and industrial processes are specifically excluded from the requirements of the Directive, however stationary combustion plants are included. • Regulations will mainly impact installations who operate – combustion plants to power or heat their facilities. Source: Johnston Boiler Company – Energy-from-waste plants
Scope of the MCP Regulations The impact will also not be limited to industrial facilities. Operators of large back-up generators or boiler plants could also be effected by the provisions. Source: Rolls-Royce Operators will need to keep the deadlines in mind in view of applicability of various provisions. Source: Siemens
New and Existing MCPs A distinction is made between new and existing installations. • Existing combustion plant - combustion plant put into operation before 20 December 2018 or for which a permit was granted before 19 December 2017 . • New combustion plant - combustion plant other than an existing combustion plant.
Legislative requirements and Timeframes Permitting requirements Each operator of a MCP must be subject to a permit issued by ERA. For New MCPs the obligation to obtain a permit applies immediately. For Existing MCPs , the requirements are being phased: • RTI > 5MW must be permitted by 1 January 2024; and • RTI≤ 5MW the deadline is 1 January 2029.
Application Structure • A simple application form shall be implemented. • An application for a permit with ERA shall be carried out using the application form published by the Authority on its website. • Application shall at least include information listed in Schedule I. Details to be included: – rated thermal input of the medium combustion plant, – type of the plant , – type and share of fuel, – date of the start of the operation, – sector of activity, – the expected number of operating hours.
Permit Structure • In cases where a permit is required under some other piece of legislation, the obligations under these regulations shall be incorporated into one permit. • Permit will include various operating conditions, ELVs and reporting requirements. • ERA may request a bank guarantee to ensure compliance with the conditions laid down in a permit.
Legislative requirements and Timeframes Emission Limit Values MCPs will have to comply with emission limit values for SO 2 , NO x and Dust. For New MCPs obligation to obtain a permit applies immediately. The strictest limits are placed on new MCPs as from 20 December 2018 Existing MCPs are subject to less strict limits, with a phased approach: • RTI > 5MW are subject to emission limits from 1 January 2025 ; and • RTI≤ 5MW will have to comply with emission limits (generally the least strict limits of all) from 1 January 2030.
Example of ELVs 1<RTI ≤ 5MW RTI < 5MW 1 – 50MW 1 – 50MW 1 – 50MW Other than Other than Existing Other than New Engines and engines and engines and Engines engines and gas gas turbines gas turbines gas turbines and gas turbines turbines Gas oil Gas oil Gas oil Gas oil Gas oil ― ― ― ― ― SO 2 120 (E) * 190 ** (E) NO x 200 200 200 200 (GT) 75 (GT) ― ― ― ― ― Dust
Exemptions & Derogations Exemptions on the basis of Operating Hours Existing MCPs which operate for less than 500 hours per year (on a rolling average) can be exempted from the emission limits provided that such plants comply with a 200mg/NM 3 limit for particulates from solid fuel plants. New MCPs (with a 100mg/NM 3 limit for particulates from solid fuel plant). Additional derogations apply until 1 January 2030 for: • Plants over 5MW where at least 50% of useful heat produced is provided to district heating systems; • Solid biomass plant; • Plant used to drive certain gas compressor stations; and • Small and micro isolated systems. • Derogations apply in the case of low-sulphur fuel and gaseous fuel plant suffering significant interruptions to supply.
Exemptions & Derogations Exception of imposing stricter ELVs • In areas where there are exceedances of Ambient Air Quality Regulations limit values, the Authority may consider applying more stringent limits on individual MCPs in these zones, Source: Huffington Post provided that applying such limits would effectively contribute to a noticeable improvement of air quality. Source: earthtimes.org
Compliance & Reporting • Monitoring requirements – Periodic monitoring of ELV pollutants is a requirement. • 1-20 MW: every 3 years or >20 MW: annually • Reduced frequency if ≤ 500 hr/yr – Continuous monitoring may be requested by the Authority – Initial monitoring is required within four months of the plant being permitted or from the date of the start of operation whichever is the latest. – Plants applying secondary abatement equipment will require continuous monitoring of its effective operation – Alternative allowed for SO 2 monitoring based on sulphur content of fuel • Compliance Deadlines & Non-Compliances • ELVs will apply immediately to all new plants from December 2018. • Existing plants have until 2025 or 2030 to comply with Emission Limit Values depending on capacity. • Suspension of the permit and penalties may apply in the event of non-compliance.
Summary of Monitoring Requirements Periodic Measurements Thermal First Exempted MCPs 500 Input Measurement Pollutants MCPs h/year 1MW≤ RTI ≤ 20 MW Every 3 years Every 1500 hours or 5 years Within 4 As set out in Schedule months II & CO RTI>20M Every 500 hours or 5 W Annually years
Reporting requirements • The Regulations place a number of obligations on operators with respect to the retention of data. Operators will be required to maintain proof of the permit being granted by the Competent Authority; emissions monitoring results; a record of operating hours and of the fuels used; and any malfunctions or breakdown of secondary abatement equipment for at least ten years. • The Authority is also obliged to report the data to the European Commission. The first report being the submission of CO data in 2021. ‘’Member States shall submit a report to the Commission, by 1 January 2021, with an estimate of the total annual emissions of CO and any information available on the concentration of emissions of CO from medium combustion plants, grouped by fuel type and capacity class. ’’ ‘’Member States shall, by 1 October 2026 and by 1 October 2031, submit a report to the Commission with qualitative and quantitative information on the implementation of this Directive, on any action taken to verify compliance of the operation of medium combustion plants with this Directive and on any enforcement action for the purposes thereof .’’ • Review clauses are included in which the Commission can assess the need to regulate CO emissions and the possibility of setting minimum energy efficiency requirements.
Operator Obligations Operators will need to ensure: • They hold a permit for operational plant by the relevant deadlines; • Emissions are monitored and must demonstrate compliance with the applicable emission limit values; • Records of operation of the plant are kept for at least six years to demonstrate compliance. Record & Obtain Monitor Report Permit Emissions Emissions
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