Compliance with the MCPD using industrial LPG

ACCORDING TO the World Health Organisation, ambient air pollution accounts for an estimated 4.2 million deaths per year due to stroke, heart disease, lung cancer and chronic respiratory diseases. The gases and pollutants that are often put under the spotlight include those that the Medium Combustion Plant Directive (MCPD) seeks to limit – namely nitrogen oxides (NOx), sulphur dioxide (SO₂), and particulates.

The directive, which has been incorporated into the Environmental Permitting regulations in England and Wales - requires owners and users of boilers, engines and turbines with a net rated thermal input between 1MW and 50MW to comply with Emission Limit Values (ELVs), which vary according to the fuel type.

Rethinking fuel sources

For industries who are located in areas which are off the mains gas grid and rely on biomass or heavy oils to power their boilers, the regulations will prompt a rethink, as these fuel sources are unlikely to meet the limits for SO₂, NOx or particulates without secondary abatement. Complex installations which require further reduction in their emission levels need bespoke permits, which are considerably more expensive than standard ones.

Liquefied petroleum gas (LPG) already meets standards for SO₂ and NO_x and particulate emissions as well as offering reduced CO₂ output, with margin to handle some tightening of ELVs in the future. It is ideal for processes employed in a range of industries, including food and drinks production, asphalt manufacturing, waste processing for recycling and the generation of heat and electricity using combined heat and power.

A large number of industries coming under the MCPD legislation requirements are likely to use package burners as part of their heating or steam generation processes, which use either oil or gas. In most cases, to enable the boiler to use LPG, only the burner will need a modification. Understandably the whole project will involve more than just changing the burner. It also takes time to design the fuel supply system, source the equipment, have it installed, and make any modifications required to existing plant, so having a business LPG supplier with the right industry expertise on board right from the start will help to ensure that the project will run smoothly.

For example, fuel storage will need to be considered. Depending on the size of the plant, a large amount of industrial LPG may need to be stored on site. Although LPG does not need to be kept warm in storage or require secondary containment, planning permission for hazardous substance will be necessary if over 25 tonnes of LPG is specified.

Suitable location

To be able to store over 50 tonnes of LPG on site, compliance with lower tier COMAH – Control of Major Accidents and Hazards regulations – is also a must. In order to ensure maximum safety, there are also certain regulations on where bulk LPG storage is to be sited, such as separation distances, which is why it is important to identify a suitable location for it early on in the project. Furthermore, by working with the LPG supplier from the start, civil engineering works such as installation of the bulk tank underground or construction of fire walls can be planned into the project to mitigate the risk of additional costs and delays further down the line.

The design and installation of pipework between the gas supply and the burner also needs careful planning and consideration. Responsibilities are usually agreed and allocated between the various parties involved, and this is also one of the reasons why working with an LPG supplier who takes an open and honest approach with no ‘hidden’ cost matters.

For example, we can advise and support customers right from the beginning. Using our technical engineering expertise, we can work with engineering consultants or directly with customers throughout the whole process to assist with planning applications, installations and even post-implementation requirements and documentation. Our team of experts can deliver turnkey and non-turnkey solutions, and for large or complex installations, we offer project design and management services together with a bespoke industrial LPG site installation service.

Time to start planning

The deadline for registering and obtaining a permit for existing plant above 5MW is January 2024, which may seem like some way off. However, a permit cannot be obtained until the relevant ELVs are met. Considering the time it could take to change to using another fuel type before applying for and obtaining a permit, it’s not long until manufacturers will need to start making plans and budgeting for the costs involved. Non-compliance resulting in a significant degradation of local air quality could lead to suspension of the combustion plant, halting the business’ manufacturing operations until compliance is restored – something that no business would wish to risk.

There is no doubt that the MCPD is ultimately good news for the environment and public health. By encouraging manufacturers to move away from more polluting fuel sources to cleaner solutions such as LPG, not only can industries reduce their carbon footprint, but also help to improve air quality now and in the years to come. Choosing the right supplier and involving them from the start of this journey is key to making the transition easy and trouble-free.

Adrian Heath is national account manager for Industry and Transport at Calor

www.calor.co.uk