EU Regulation of Combustion Plant - A Power Industry Perspective

Any installation that contains combustion plant with an aggregated thermal input greater than 50 MW is regulated under the Industrial Emissions Directive (IED) which requires that Best Available Techniques are applied to emissions control. Individual plant with a thermal input greater than 50 MW are regarded as Large Combustion.
Plant and additional provisions apply, including mandatory Emission Limit Values that defi ne a minimum compliance standard during normal operation. A separate EU Implementing Decision defi nes the rules that govern start-up and shut-down. However, lower mandatory emission levels are specifi ed in Best Available Techniques Reference (BREF) documents for each industrial sector. The Large Combustion BREF is nearing completion and this specifi es emission levels and monitoring requirements for additional species.

A new European Directive, the Medium Combustion Plant Directive (MCPD), specifi es Emission Limit Values (ELVs) for smaller plant that fall below the 50 MW thermal input threshold. ELVs are specifi ed for NOx, SO2 and dust for new and existing small combustion plant, gas turbines and engines.
Compliance is assessed, for the most part, by annual or triennial periodic monitoring and this presents a number of challenges for plant with small fl ues and limited access.

This paper focuses on the practical diffi culties related to the implementation of new regulatory requirements, including: regulatory overlap between directives; aggregation rules; start-up and shut-down defi nitions; low load factor plant; new continuous monitoring requirements on large plant and new periodic monitoring requirements on small plant.