1. Introduction to Large Combustion Plant (LCP) Directive and Compliance Issues. ECENA Training Workshop
Bristol, March 2008

2. 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.

3. 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.

4. Moneypoint Coal Fired Power Station Ireland (large stacks)

5. Estimated Source of Air Releases (as % of Total UK Emissions)
It is important that we know the sources of the various air pollutants so that appropriate control measures can be introduced.
For some Agency controlled sources are the major contributors whereas for others transport or other activities may be the major sources
Effective air quality management plans are dependent on accurate attribution of sources
Knowledge of the local situation is also vital because although at the national level a substance industry may not be a major contributor at the local level it may be the predominant source
Source: National Air Quality Strategy, DETR

6. 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.

7. 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.

8. 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.

9. 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.

10. 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.

11. 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.

12. 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.

13. 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.

14. 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.

15. LCP Reduction Targets

16. 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.

17. ‘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”.

18. 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.

19. 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.

20. 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 directive’s ELVs possible to use national plan option.

21. 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.

22. European Release and Transfer Register (E-PRTR)
European Release and Transfer Register (E-PRTR) will replace EPER for 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

23. 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??

24. 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 2
SO2
150
Trace

25. Interface between LCP and E-PRTR
Appears likely that even the smallest LCPs will have some reporting requirements under the E-PRTR each year!
More on reporting in Session 3!

26. 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)

27. 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 LCPslow 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!

28. New CCGT Power Station (small stacks)

29. Is Gas the Answer? Energy policy must consider ‘security of supply’:
1970s oil shocks showed the folly of dependency on a single energy source. France takes the nuclear route!
Fuel costs:
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.

30. 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!

31. 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 country’s power. Coal fired plant undergoing €264 million environmental upgrade to meet LCP directive’s 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.

32. 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!!!!

33. 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%

34. 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.

35. 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.

36. 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.

37. Don’t be shy – Question time!