Will new emissions legislation catch plant engineers unawares? 28 December 2017

The Medium Combustion Plant Directive (MCPD) is due to be incorporated into UK law in December 2017. Unfortunately, there is currently a deafening silence from the industry over what this will mean for engineers.

The MCPD aims to limit the emissions of certain pollutants that are released into the air and will apply to all combustion plants with a thermal input of between one and 50MW. In particular, the directive will apply to all steam boilers generating above approximately 1.3 tonnes of steam per hour, as well as any diesel or gas engine generators rated above about 450kVA.

The new directive plugs the legislative gap between larger plants, which are covered by the Industrial Emissions Directive, and smaller appliances, which are covered by the Eco-Design Directive. These all ensure that energy and resource consumption is reduced from all areas. In order to meet the MCPD, each individual plant will have to remain within the pre-defined 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. Carbon Monoxide (CO) will also be measured, but is not yet subject to any limits.

MCPD - what you need to know
“There’s a worrying lack of awareness about the Medium Combustion Plant Directive amongst plant managers, maintenance teams, and boiler house managers and operatives,” says Matthew Walton, contracts manager, at Bosch Commercial & Industrial. “Time and again, when we ask industry professionals if they understand or are even aware of when the MCPD comes into force, the answer is ‘no’. Not enough has been done yet to get the message out to industry and, as a result, a lot of people are going to be completely unprepared.”
Despite this, UK industry has relatively little time to get itself ready for those changes, as Paul Whitehead at the Combustion Engineering Association (CEA) explains: “The European Commission has set Emission Limit Values and the government has two years to incorporate these into UK law. It is expected that this will happen in December this year, following which there will be a period of implementation.
“This would mean that, from December 2018, any new plant must comply with the MCPD. Older plants will be given further time to adapt and upgrade equipment. What isn’t clear, however, is whether the UK will enforce stricter limits, particularly in mixed-use and residential locations, or in existing Air Quality Management Areas (AQMA).

“The main obligations for operators will be to register or obtain a permit for their plant, as required, ensure that they meet the ELVs set out by the European Commission and monitor all of this regularly. The plant operator should also take measures to avoid non-compliance and keep a record of information regarding the operation of the plant, including any upgrades that could affect the applicable ELVs,” Whitehead advises.

There are, however, a few potential teething problems with the new directive, which may only come to light once the directive has been enforced.

“The directive raises several questions, including whether the ELVs are realistic for medium plants to achieve,” Walton explains. “Other elements to consider are how exemptions can be applied in a pragmatic way, how data will be managed and reported, and what penalties will be enforced for non-compliance. In terms of monitoring, a robust methodology will be essential in order to generate reliable, representative and comparable results, and provide accurate evidence that demonstrates a company’s compliance with ELVs.”

Regulators, exemptions and fees
It is expected that existing environmental permitting fees and charges will be reviewed to ensure full cost recovery from plant operators. A consultation to this end was held between March and April this year, with a response from Defra (Department for Environment, Food & Rural Affairs) expected in the coming months.

In England, the Environment Agency has been appointed as the regulator for the new directive, while the devolved parliaments in Wales, Scotland and Northern Ireland will make their own decisions on overall responsibility.

Whitehead explains how the relationship between the Environment Agency and local authorities is expected to work: “Where the Environment Agency takes responsibility, local authorities will be considered statutory consultees, particularly in higher risk plants or sites within Air Quality Management Areas.

For low-risk plants, registration and application approval can take place through an Environment Agency web portal. For higher risk sites, however, a bespoke application will be required, but on sites where an environmental permit already exists, the permit will simply be updated to add any MCPs at the appropriate time.

“There are some exemptions to the MCPD, including existing plants that do not operate for more than 500 hours a year as a rolling average over five years and new plants that do not operate for more than 500 hours over a rolling average of three years. A further exemption of 1,000 hours is expected for plants in connected islands where an interruption of the power supply is more likely. In these cases, the ability to allow an extension of hours in exceptionally cold weather will also be granted. However, to enable effective enforcement, plants that exceed 500 hours of operation in any given year will be required to notify the regulator.”

Operators are advised to think carefully before they declare how many hours of operation they require, with overestimation being the best course of action. It is important to remember that the permit you receive as an operator will replicate the operating envelope you declare on your application. It is therefore essential to allow as much flexibility in operation as necessary. This is because any variation to operating regimes will require a permit variation, which will usually come at a cost.

Latest boiler technology
According to Walton, it is important that managers and operators familiarise themselves with the directive’s ELVs, which are expected to affect around 17,000 plants in the UK. Fortunately, steps have been taken to ensure that the latest boiler technology will help plant managers to meet them.

“Burner technology is one area that can make a big difference,” Walton says. “It can even be seen as fundamental to reducing NOx emissions. Bosch Commercial & Industrial works closely with all the leading burner companies to ensure that our products are optimised for all fuel types. However, with the burner representing just one component of a boiler system, there are a number of additional steps that can be taken to further reduce NOx levels, such as lowering the furnace heat release ratio by increasing the size of the furnace volume inside the boiler.”

Managing existing boilers
Existing plants may have more time to comply (depending on their MW rating), but consultants and engineers should make sure they are aware of the requirements, in order to design plants that 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, which will avoid unanticipated upgrade costs and possible penalties.

“Some production sites will, of course, need to replace boilers in the future, but this will always be for a more efficient and lower emissions version of what they already have in-situ, helping to offset the upfront costs with energy savings over the longer term,” Walton continues.
Environment Agency responsibility to plant operators.

Where, then, does industry go from here? Whitehead argues that a helping hand is needed: “It is the responsibility of the Environment Agency to draft and distribute sufficient guidance for operators of MCPs, which would help them to follow the application process and comply with the requirements of the directive. Having said that, the responsibility doesn’t rest entirely on the shoulders of government bodies. Plant engineers should also become more cognisant of the directive and its implications, in order to make the changes needed to comply and avoid a nasty shock in the coming months.”

Adam Offord

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