Prepare for new directive

The MCPD is being launched by the European Commission to limit the emissions of certain pollutants into the air from medium combustion plants, and will apply to all combustion plants with a thermal input between 1 and 50MW. In particular, the directive will apply to all steam boilers generating above about 1.5t of steam per hour and any diesel or gas engine generators rated above 400kVA. 

The new directive plugs the legislative gap between larger plants covered by the Industrial Emissions Directive (IED) and smaller appliances covered by the Eco-Design Directive, ensuring that energy and resource consumption is reduced from all areas. Each individual plant will have to meet Emission Limit Values (ELVs) for the production of Nitrogen Oxide (NOx), Sulphur Oxide (SOx) and dust, all of which are common air pollutants associated with combustion plants. The ELVs have now been set by the European Commission and differ for new and existing plants, as well as for different combinations of plant size, plant type, and fuel type.

NOx and SOx are formed during the combustion of hydrocarbon fuels and are key contributors to the production of acid rain. Nitrogen Oxides in particular, are formed due to the presence of nitrogen within the combustion air as well as that which is organically bound within the fuel itself. It is therefore important to consider the properties of the fuel being used, as the amount of natural nitrogen in fuel can vary from virtually zero in natural gas to large amounts in coal, impacting the overall amount of NOx produced. 

It is not yet clear who will be managing the process and collating emissions data for plants and equipment under the MCPD, but once the directive has been adopted by the UK, all equipment used by medium plants must comply. 

Obligations 

The main obligations for operators will be to register or obtain a permit for their plant as required, and to ensure their plant meets the ELVs set out and to monitor this regularly. The plant operator should also take measures to ensure that non-compliance is kept to a minimum, and keep a record of information regarding the operation of the plant including any upgrades which could affect the applicable ELVs.

Trialling the directive

The directive also raises several questions that may only be answered once the directive is in full force, including whether the ELVs set out are realistic or impractical for medium plants to achieve. Other elements to consider are how exemptions can be applied in a pragmatic way, how data will be managed and reported to the European Commission, and what penalties will be enforced for non-compliance. In terms of monitoring, a robust methodology will be essential in generating reliable, representative and comparable results to demonstrate compliance with ELVs.

It is important that managers and operators familiarise themselves with the directive’s ELVs as the directive is expected to affect around 17,000 plants in the UK. At Bosch, our entire range of industrial boilers is already compliant with the directive and though existing plants may have more time to comply, depending on their MW rating, consultants and engineers should make sure they are aware of the requirements in order to design plants which will stand the test of time. The leeway offered for existing plants means managers and operators can gradually ensure that their equipment is compliant over time, to avoid unanticipated upgrade costs and possible penalties.

While the management of the directive may still be unclear, the fact that its Emission Limit Values are set in stone should be used as a benchmark for plant operators planning for the future.