Introduction to Large Combustion

Plant (LCP) Directive and

Compliance Issues.
ECENA Training Workshop
Bristol, March 2008
1

Introduction

This presentation, Session 1, will address:

The history and goals behind the LCP directive.
Its interface with IPPC and the E-PRTR.
How other Member States have implemented the LCP
Directive.
New developments in LCP legislation.

Historical Basis

Pollution levels in European cities in 18th and 19th

century over a 100 times current limit values, e.g.
famous London smog.
20th Century led to development of large centralised
power plants with tall stacks, dilution was the solution.
This led to transboundary pollution, acidification and
dying forests.

Moneypoint Coal Fired Power Station

Ireland (large stacks)

Estimated Source of Air Releases

(as % of Total UK Emissions)
Pollutant

Source
Industry Transport
Sulphur Dioxide (SO2)
89%
2%
Nitrogen Oxides (NOx)
37%
46%
Carbon Monoxide
12%
75%
Fine Particulates (PM10s) 59%
26%
Lead
18%
78%
Benzene
20%
67%
1,3-Butadiene
13%
77%
Volatile Organic Compounds53%
29%
Source: National Air Quality Strategy, DETR

Other
9%
17%
13%
15%
4%
13%
10%
18%

Pollution from LCPs

LCPs accounted for about 75% of SO2 and 21% of NOx of UK

totals in 1998.
Widespread use of coal in power generation throughout Europe
led to similar values.
Expected that these values will fall sharply over 2000 2010 by:
SO2: 1,000 kilotonnes
NOx: 4,000 kilotonnes
Particulates: 100 kilotonnes
Savings in less material damage, morbidity and mortality alone
estimated by EU at 38,444 million.

Historical Basis (First Step)

1983 Germany
implemented Federal
Imissions Control Act
(BImSchG), leads in ten
years to a 89% reduction
of SO2, driven by high
awareness of
environmental damage to
forests.

Control of Air Pollution from Industry

By the early eighties it was obvious that air pollution

from industry needed to be controlled on an EU level,
although some countries had already implemented
comprehensive national legislation.
Air Framework Directive 84/360/EEC established system
of permitting

Use of Best Available Technology Not Entailing Excessive Cost

(BATNEEC).
Plant must not cause significant air pollution, i.e. applicable
emission limit values and air quality values must be met.

German Control Measures for Pollution

from LCPs

Public outcry over the death of forests (Waldsterben) led

to the 13 BImSchV of 1983.
With a command and control approach a general SO2
limit of 400 mg/m3 was adopted which LCPs had to meet
by 1993 or close down.
By 1988 W.Germany had retrofitted flue gas
desulphurisation to 70 LCPs, roughly 75% of
the total capacity.
Final cost of desulphurisation: 14.3 Billion DM.

Implementation of Desulphurisation in
Germany

With regard to achieving a dramatic

reduction in SO2 discharges the
legislation was a major success.
However, its implementation was
rushed; processes were not optimised,
contractors were overloaded, estimated
that nowadays it would cost 30% less.
However, it did lead to the 1988 LCP
directive.

EU Control of Pollution from LCPs

Obvious that LCP sector required particular regulation as

a major source of SO2 and NOx emissions.
Long drawn out highly politicised and contested process
with first proposal of LCP directive presented in 1983 as a
daughter directive to the Air Framework Directive.
Finalised in 1988 as Directive 88/609/EEC,which set
Emission Limit Values (ELVs) for new plant and gave a
national bubble of emissions for existing plants.

New Plant licence granted after July 1987.

Existing Plant licence granted before July 1987.

First LCP Directive 88/609/EEC

Scope of Directive 88/609/EEC limited to:

Rated thermal input 50 MW.

Combustion plants for the production of energy.
Direct use of the products of combustion in manufacturing
process

Does not include:

Combustion of waste or combustion for air emissions control.

Situations where products of combustion used for direct
heating or drying, e.g. furnaces.
Diesel, petrol or gas engines or gas turbines.

Approach of First LCP Directive

Goal was to reduce emissions of SO2, NOx and

particulates.
Classic command and control approach for new
plants setting uniform Emission Limit Values (ELVs)
based on plant size and fuel type.
More flexible approach for existing plants; staged
reduction (national emissions ceilings) for SO2 and
NOx for 1993, 1998 and 2003.

Additional Requirements of LCP Directive

Member States to determine total annual emissions for

both new and existing plants.
National emission reduction targets to be agreed with
EU. Compliance programmes to achieve targets to be
developed with the operators.
Options include fuel switching, energy saving measures,
pollution abatement technologies.
Licences need to consider measurement methods and
measures in event of failure of control devices, etc.

LCP Reduction Targets

Updating of LCP Directive

By 2001 the LCP directive was updated (2001/80/EC)

reflecting the progress in technology and EU
environmental legislation and the need to include gas
turbines, promote combined heat and power and tighten
up monitoring.
Updated ELVs for modern LCPs operational after
27/11/2003.
ELVs set for gas turbines, which were becoming
increasingly common, in addition to those set for solid
fuel and liquid fuel fired LCPs.
Diesel, petrol and gas engines still excluded.

End of Life Exemption

Directive 2001/80/EC included the following important

exception:

An existing plant may be exempted from compliance with the

ELVs and from inclusion in the national plan if the operator
declares by 30 June 2004 that the plant will not be operated for
more than 20,000 hours beyond 1 January 2008 and up to 31
December 2015; end of life.

LCP Directive 2001/80/EC

Member States have two options for controlling

emissions from existing plants:
(a) applying the new plant ELVs in the original
Directive to existing plant by 1 January 2008, or
(b) by 1 January 2008, reducing emissions from
existing plant under a national plan to the same levels
which would have been achieved by the application of
the new plant ELVs to existing plant in operation in
the year 2000.

Interface with IPPC Directive

Recital 8 of LCP directive: Compliance with the

Emission Limit Values laid down by the LCP
directive should be regarded as necessary but
not sufficient for compliance with the
requirements of directive 96/61/EC (IPPC)
regarding the use of Best Available Techniques.
Such compliance may involve more stringent
ELVs, ELVs for other substances and other
media, and other appropriate conditions.

Conclusions on LCP / IPPC Interface

In all cases an IPPC permit is required.
This is a more complex issues than the ELVs
specified in the LCP directive.
The IPPC permit must contain BAT based ELVs,
for which there is flexibility for existing plants.
Where BAT based ELVs are less demanding than
LCP directives ELVs possible to use national
plan option.

European Pollution Emissions Register

(EPER)

Gives access on
pollution emissions of 50
pollutants from approx.
12,000 IPPC facilities in
the EU. Updated every 3
years.
http://www.eper.cec.eu.int
/eper/

European Release and Transfer Register

(E-PRTR)

European Release and Transfer Register (E-PRTR) will

replace EPER for 2007. Number of pollutants is
expanded to 91.
E-PRTR and LCP directive include combustion plants
with a heat input of > 50 MW.
Relevant pollutants for LCPs among the 91 include:
CO2, CO
NOx, SO2, PM10
Heavy Metals

European Release and Transfer Register

(E-PRTR)

Thresholds set for pollutants above which reporting

required.
Consider 50 MWt Combine Cycle Gas Turbine (cleanest
power generation), running for 8,200 h/a, i.e.
continuous load, with low emissions (NOx 50 mg/m3,
CO 25 mg/m3 and PM10 2 mg/m3).
Does this require reporting??

50 MWt CCGT Plant E-PRTR

Parameter

Threshold
(1,000 kg/a)

Release
(1,000 kg/a)

CO2

100,000

108,000

CO

500

31

NOx

100

47

PM10

50

SO2

150

Trace

Interface between LCP and E-PRTR

Appears likely that even the smallest LCPs will
have some reporting requirements under the EPRTR each year!
More on reporting in Session 3!

How have other Member States

implemented the LCP Directive?

The cost of upgrading every LCP would be prohibitive.

For older plants it is essential to consider:

What is the residual lifespan of older plants?

Are these base load stations or used to match peak loadings?
Which is cheaper? Upgrade or replace with new plant?
Consider applying for end of life reduced hours exemption?
(20,000 hrs over 8 years)

Economic Considerations
Need to carefully consider economic
considerations before initiating upgrade projects.
Dash for Gas adopted by UK and Ireland:

Combine Cycle Gas Turbines (CCGTs) have the best

environmental performance of all LCPslow stacks!
CCGTs have very high efficiencies; typically 55%
versus about 35% for older LCPs good Kyoto!
CCGT are low cost; typically 0.8 million / MW
good economics!

New CCGT Power Station (small stacks)

Is Gas the Answer?

Energy policy must consider security of supply:

Fuel costs:

1970s oil shocks showed the folly of dependency on a single

energy source. France takes the nuclear route!
Gas is a premium fuel and will cost more than coal. Western
European gas supplies exhausted in 25 years!!
Investment in gas infrastructure is required; pipelines,
compressors, etc.

Socio-economic factors:

Is there an indigenous fuel supply worth developing? German

reliance on coal, while political hostility in UK to coal industry.

Is Gas the Answer ?

Efficiency of CCGTs drop rapidly when load is < 80%

base load technology.
New peaking open cycle gas turbines have efficiencies
of 45% and hold this down to 50% load with rapid
response to load changes variable load technology.
Day / night time load demand is inherently variable but
variability increasing due to renewable sources such as
wind being connected to the grid!
Unless considerable hydro resources available peaking
gas turbines will need to be considered!

What is Ireland doing?

Older plants on End of Life exemptions restricted to

peak load duty. Use of low sulphur fuels and low NOx
burners.
Moneypoint Power Station; Largest in Ireland at 915 MWe
supplies 25% of countrys power. Coal fired plant
undergoing 264 million environmental upgrade to meet
LCP directives emission limit values; deNOx and flue
gas desulphurisation
National Emissions Reduction Plan seeks emission
reductions of up to 73% for SO2, and 66% for NOx from
the levels emitted in 2002.

What is Ireland doing?

Emission reductions in Moneypoint to offset NOx emissions in

other plants under National Emissions Reduction Plan.
New gas fired CCGT plants under construction, gas turbine
peaking plants under consideration.
Older Heavy Fuel Oil plant at Tarbet (595 MWe) closed.

Meeting the NOx requirements remains the greatest

challenge!!!

Newer CCGT power stations will help but state owned power
supplier ESB is protesting about the costs that could occur.
Over 650 MW of wind generation installed on Irish grid, average
output for April 07 was 132 MW we need our LCPs!!!!

What is UK doing?
History of opposition to the LCP Directive as
extensive Flue Gas Desulphurisation (FGD) would
be required to existing coal plants supplying 65%
of electricity in 1989.
Liberalisation of electricity market with resultant
fuel switching; construction of CCGTs and
increase in nuclear power. Currently:

Gas: 39%

Coal 33% Nuclear: 21%

New Developments

Report for the EEA using

data from 2004 would
indicate that there is still
progress to be made by
Large Combustion Plants
(LCP), particularly those
coal and lignite fired.
Note BAT associated
emission limit values are
lower than those in LCP
Directive.

Summary
Justification is strong for the considerable
investment required to upgrade or replace LCPs.
Approach taken by Member States has differed,
from going nuclear (France), going gas (UK and
Ireland), or major retrofitting to existing coal fired
generation (Germany).
Future trend is that even tighter controls are
technically feasible and will be sought by EU.

New Developments

Need for further industrial emission reductions to meet

Thematic Strategy 2020 targets:

-30% for SO2

-35% for NOx

-24% for PM2.5 (<2.5 micron particulate matter)

-17% for Volatile Organic Compounds

Recent proposal from EU Commission (21/12/2007) for a

new Directive on industrial emissions will incorporate
the above targets for licensing of LCPs.

Dont be shy Question time!