Regional State Administrative Agency for Southern Finland, Jaakko Kuisma1 Best Available Techniques (BAT) for LCPs, self-monitoring and monitoring Jaakko Kuisma

 BAT and preparation of the BAT reference documents (BREF’s)  BAT in the LCP BREF (2006)  Review of the LCP BREF (2011-) and Finnish LCP BAT shadow group for the review  Current status with BAT implementation in Finnish LCP’s  Self-monitoring and monitoring for LCPs Regional State Administrative Agency for Southern Finland, Jaakko Kuisma2 Content

Regional State Administrative Agency for Southern Finland, Jaakko Kuisma3 Definition of BAT Best Most effective in achieving a high general level of protection of the environment as a whole; AvailableDeveloped on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions; TechniquesBoth the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned. Determining BAT, special consideration should be given to the criteria listed in Annex III of IED

Criteria for determining best available techniques: 1. the use of low-waste technology; 2. the use of less hazardous substances; 3. the furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate; 4. comparable processes, facilities or methods of operation which have been tried with success on an industrial scale; 5. technological advances and changes in scientific knowledge and understanding; 6. the nature, effects and volume of the emissions concerned; IED Annex III Regional State Administrative Agency for Southern Finland, Jaakko Kuisma4

Regional State Administrative Agency for Southern Finland, Jaakko Kuisma5 ‘BAT reference documents’ (BREFs)  Provide ‘BAT conclusions’ which shall be the reference for setting permit conditions  Structured and prepared on the basis of established guidelines  Based on an intensive exchange of information on: the performance of installations and techniques in terms of emissions and consumptions, etc. the techniques used, associated monitoring, economic and technical viability, etc. best available techniques and emerging techniques identified after considering all the issues concerned

Regional State Administrative Agency for Southern Finland, Jaakko Kuisma6 Preparation of the BREF documents

Regional State Administrative Agency for Southern Finland, Jaakko Kuisma7  Current LCP BAT reference document was published in July 2006 and drafted between 1999 and  600-page document on combustion and environmental protection techniques, and in particular achievable emission levels by using BAT (BAT-AELs / BAT ranges)  Covers combustion plant with rated thermal input over 50 MW  BAT-AELs mainly on conventional fuel basis (coal and lignite, biomass and peat, liquid fuels and gaseous fuels)  BAT-AELs are given separately for new and existing plants  Includes co-combustion of solid waste and secondary fuels  Current LCP BREF does not consider different load modes (emergency, peak load, mid-merit, base load) LCP BREF

Fuel storage and pretreatment and CO emissions  BAT process descriptions are given for unloading, storage and handling of fuel and additives  BAT for fuel pretreatment is to consider blending and mixing in order to ensure stable combustion conditions and to reduce peak emissions  BAT for biomass and peat combustion is to consider drying to reduce the amount of water in peat and biomass, drying of fuel is also considered to be part of BAT  For liquid fuels BAT is to consider various pretreatment devices depending on fuel and proces  BAT to reduce CO emissions it to ensure complete combustion, along with furnace design, monitoring and process control and maintanence, BAT-AELs are given for gas combustion Regional State Administrative Agency for Southern Finland, Jaakko Kuisma8

Thermal efficiency

Thermal efficiency (2)  No Specific BAT values for liquid fuels in boilers and engines Regional State Administrative Agency for Southern Finland, Jaakko Kuisma10

Particles  Emissions from natural gas combustion are normally below 5 mg/m 3 without any abatement  BAT to reduce heavy metals is to use ESP or fabric filter Regional State Administrative Agency for Southern Finland, Jaakko Kuisma11

SO 2 emissions

NO X emissions (coal and lignite)

NO x emissions (biomass and peat) Regional State Administrative Agency for Southern Finland, Jaakko Kuisma14

NO x emissions (biomass, peat and gas)

NO x emissions (gas continuing) Regional State Administrative Agency for Southern Finland, Jaakko Kuisma16

Waste water, waste and co-combustion  BAT is to collect and treat all surface run-off waters before discharge  BAT is to apply oil separation wells to prevent emissions  BAT is to treat flue gas cleaning waste waters by adjusting the pH level, precipitate heavy metals and remove the solid matter  For by-products utilization and re-use is the best available option depending on waste quality  Generally the same BAT apply for co-combustion of secondary fuels (waste) as for conventional LCPs. The need for adjusting the flue gas cleaning, limitations on secondary fuel input and changes in combustion residue quality need to be addressed in case by case Regional State Administrative Agency for Southern Finland, Jaakko Kuisma17

 All permits for Finnish LCP’s were reconsidered because of the LCP- and IPPC-Directives  Majority of the large combustion plants have currently emission limit values based on LCP Directive  LCPD based ELV’s for new (>2003) plants are often sufficient to ensure operation within BAT-AEL’s  Some more recent permits for existing (<2003) plants have lower ELV’s than LCPD, based in current BAT-AEL’s in the LCP BREF (2006)  BAT-based permitting for 5-50 MW plants from 2005 to 2010 and currently legislated minimum ELVs Regional State Administrative Agency for Southern Finland, Jaakko Kuisma18 Current situation in LCP’s and BAT

 LCP BAT group is an expert group under environmental administration preparing the Finnish input to LCP BREF review process  Members from industry, technology suppliers, environmental authorities (ministry, permit writers and surveillance) and environmental NGO  Two TWG members from environmental authority and VTT  Re-established two years before the start of the LCP BREF review  Work based on voluntary contributions, which are partly supported by projects Regional State Administrative Agency for Southern Finland, Jaakko Kuisma19 Finnish LCP BAT group

 Peak and reserve combustion plants  Co-incineration and multi-firing combustion plants  Biomass and Peat  District heat production  Combined heat and power production  Fluidised bed combustion  Gasification  Engines Regional State Administrative Agency for Southern Finland, Jaakko Kuisma20 Key areas for input to the BREF review

 Finland was relatively active MS at the wish list -stage, in total 124 wishes, 50 biomass and peat wishes, 40 engine wishes  Two background studies, NOx in fluidized bed boilers (Industry funding) and BAT of the biofuel processing, production and handling (public funding)  Approximately 20 Finnish reference plants for the data collection  BREF authors visit to Finland/Estonia in February 2012, including seminars and 10 visits to combustion plants in Finland Regional State Administrative Agency for Southern Finland, Jaakko Kuisma21 Input so far to LCP BREF review

 Usually monitoring of the permit conditions is made by the operator (self-monitoring) and partly by a third-party monitoring organisation  the operator presents a monitoring plan in the permit application  The monitoring plan is reviewed by authority and accepted as a part of the permit or in a separate acceptance process  Legislation enables joint monitoring by several operators  Monitoring data cannot be declared secret  The authority does a periodical checking of the monitoring results, regional authority does very little monitoring (water emissions, noise) Monitoring and control Regional State Administrative Agency for Southern Finland, Jaakko Kuisma22

 Legislation sets some overall requirements for monitoring and control  Measurements, tests and investigations shall be done in a qualified, reliable and appropriate way  Data from EMAS and ISO could be utilised  Third-party monitoring/analyses are utilised in almost all industrial sites  On the site inspections the inspector makes and documents the observations on the reliability and accuracy of monitoring Monitoring and control (2) Regional State Administrative Agency for Southern Finland, Jaakko Kuisma23

 Self-monitoring is typically the ‘every-day’ monitoring of the industry  Typically self-monitoring is reported on annual basis, for LCPs air emission data is reported in some case monthly  The scope of self-monitoring can vary between operations and locations  Some large industry have accredited laboratories for environmental monitoring. Even in these cases there has been requirement for third-party monitoring Self-monitoring by an operator Regional State Administrative Agency for Southern Finland, Jaakko Kuisma24

A case study of LCP monitoring  Power plant has a 325 MW th peat-fired CFB boiler with 10 % biomass fuel input and 20 MW th auxiliary boiler. Plant operates on CHP mode and can produce up 100 MW district heat to close by city. Started operating  The site contains boiler, fuel receiving and processing and biomass fuel storage area (4 hectares)  The site is situated next to an artificial lake  The annual SO 2 emissions are 1200 ton, NO x emissions 800 ton and particle emissions 30 ton per year  Permit allows operation as a LCP-plant and as a waste co- incineration plant depending on fuels used Regional State Administrative Agency for Southern Finland, Jaakko Kuisma25

Self-monitoring: Operational monitoring  Self-monitoring: - Operational parameters (temperature, pressure, flows etc.) for boilers - Weighting of the solid fuels and moisture analysis from every fuel load, storage levels of liquid fuels  Third-party monitoring: - Detailed fuel quality analyses from suppliers Regional State Administrative Agency for Southern Finland, Jaakko Kuisma26

Self-monitoring: air emissions  Self-monitoring: - CFB: Continuous emission monitoring (NO, SO 2, particles and CO) and supplementary parameters (flue gas flow, O 2, H 2 O, pressure and temperature) - Aux boiler: Flue gas temperature and O 2  Third-party monitoring: - CFB: Annual quality assurance (AST/QAL2) based on EN CFB: Periodical measurements (N 2 O, HCl) - Aux boiler: Periodical emission measurements (NO x and particles)  Monthly reporting to authority for the main emissions  Other emissions reported annually (heavy metals, etc.) based mainly on emission coefficients Regional State Administrative Agency for Southern Finland, Jaakko Kuisma27

Self-monitoring: water emissions  Self-monitoring: - Cooling water flow and temperature at inlet and outlet - pH of the sewage water - Regular inspections of the oil separation wells - Other wastewater flows from daily samples  Third-party monitoring: - Surface run-off of water from fuel handling: Full range of parameters (heavy metals, nutrients, etc.) - Same parameters from ground water monitoring wells under the fuel storage areas - In this case the company take care of the sampling Regional State Administrative Agency for Southern Finland, Jaakko Kuisma28

Other monitoring activities  Self-monitoring: - Noise level biannually from 15 points around the plant  Third-party monitoring: - water temperature measurements and inspections of ice thickness on the artificial lake four times a year - Water quality analyses on the artificial lake three times a year, full range of parameters, fish stock and bottom quality analyses every two/three years - Requirement to participate on the air quality measurements done in the close-by city - Requirement to participate on regional bioindicator studies every 5 years together with other operators  Authority verifies the data on annual basis and conducts an annual site visit including a visual inspection Regional State Administrative Agency for Southern Finland, Jaakko Kuisma29