revised best available techniques (bat) reference ......combustion plant. fr 1: introduce in the...

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)



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



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



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




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




Multi-fuel combustion

Solid multi-fuel combustion

Combustion of liquid and gaseous process fuels

from the chemical industry

Co-incineration of waste

6



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



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



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



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



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



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



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



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



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



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



Degree of consensus

High degree of consensus on most BAT conclusions

89 split views assessed as valid and recorded in

Chapter 12

17



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



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



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



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)



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



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



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




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




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



Issues proposed for discussion (1-3)


Issue to discuss (Comment no.)


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



Issues proposed for discussion (4-5)

Issue to discuss (Comment no.)



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



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.



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



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


Gas turbine 36–41.5 33–41.5 No BAT-AEEL 36.5–41 33.5–41

31




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




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


Gas turbine

Combined-cycle gas turbine (CCGT)

CCGT, 50– < 600 MWth

CCGT, ≥ 600 MWth

CHP CCGT, 50– < 600 MWth

CHP CCGT, ≥ 600 MWth

33



NOX for coal plants <1987 operated <1500h/yr [# 170 - 173] (1/4)

Consolidated final meeting conclusions and Pre-Final Draft:


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




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




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




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



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


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




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).




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




41

Proposal:

Table 10.20: BAT-AELs for NOX from the combustion of HFO and/or gas oil

in reciprocating engines


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



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




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




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



Thank you for your attention

The LCP BREF review team

Thierry, Felix, Fred, Thomas

45

revised best available techniques (bat) reference ......combustion plant. fr 1: introduce in the...

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