The Medium Combustion Plant Directive (MCPD) is legislation to improve air quality and was introduced because of EU targets to monitor combustion plants between 1MW and 50MW. This bridges the gap that currently exists at EU level between smaller appliances (less than 1MW) and large combustion plants (over 50MW).
The MCPD stipulates that there must be a register, which will be managed by the Environment Agency, with information on each MCP, detailing the fuel variety used and the expected number of operating hours per annum.
“the limit values which are set out in the MCPD apply from December 20, 2018 for new plants and by 2025 or 2030 depending on their size for existing plants”
Emission limit values are set out by fuel category, distinguishing also between new and existing plants. The limit values which are set out in the MCPD apply from December 20, 2018 for new plants and by 2025 or 2030 depending on their size for existing plants.
The legal requirements and deadlines are as follows.
All new energy plants:
- Must be registered and comply with Emissions Limit Values (ELV) by December 20, 2018
Existing plants (rated thermal input above 5MW):
- Must be registered/obtain a permit to operate by January 2024
- Must comply with the proposed ELVs by January 1, 2025
Existing plants (between 1MW and 5MW):
- Must be registered or obtained a permit to operate by January 1, 2029
- Comply with the proposed ELV’s and full implementation of the MCPD will be achieved by 2030
Emission limit values referred to in MCPD
All emission limit values set out are defined at a temperature of 273.15K, a pressure of 101.3kPa and after correction for the water vapour content of the waste gases and at a standardised O2 content of 6% for medium combustion plants using solid fuels, 3% for medium combustion plants, other than engines and gas turbines, using liquid and gaseous fuels and 15% for engines and gas turbines.
“directive (EU) 2015/2193 regulates pollutant emissions from the combustion of fuels in plants with a rated thermal input equal to or greater than one megawatt (MWth) and less than 50MWth”
Directive (EU) 2015/2193 of the European Parliament and the Council of November 25, 2015 on the limitation of emissions of certain pollutants into the air from medium combustion plants regulates pollutant emissions from the combustion of fuels in plants with a rated thermal input equal to or greater than one megawatt (MWth) and less than 50MWth. Medium combustion plants are used for a wide variety of applications (electricity generation, domestic/residential heating and cooling, providing heat/steam for industrial processes, etc.) and are an important source of emissions of sulphur dioxide (SO2), nitrogen oxides (NOx) and dust. The estimated number of MCPs in the EU is around 143,000 with an estimated 25,000 in England and Wales.
“the estimated number of MCPs in the EU is around 143,000 with an estimated 25,000 in England and Wales”
- This Directive shall apply to combustion plants with a rated thermal input equal to or greater than 1MW and less than 50MW (‘medium combustion plants’), irrespective of the type of fuel they use.
- This Directive shall also apply to a combination formed by new medium combustion plants pursuant to Article 4, including a combination where the total rated thermal input is equal to or greater than 50MW, unless the combination forms a combustion plant covered by Chapter III of Directive 2010/75/EU.
- This Directive shall not apply to: (a) Combustion plants covered by Chapter III or Chapter IV of Directive 2010/75/EU (b) Combustion plants covered by Directive 97/68/EC of the European Parliament and of the Council (c) On-farm combustion plants with a total rated thermal input less than or equal to five MW, that exclusively use unprocessed poultry manure, as referred to in Article 9(a) of Regulation (EC) No 1069/2009 of the European Parliament and of the Council, as a fuel (d) Combustion plants in which the gaseous products of combustion are used for the direct heating, drying or any other treatment of objects or materials (e) Combustion plants in which the gaseous products of combustion are used for direct gas-fired heating used to heat indoor spaces for the purpose of improving workplace conditions (f) Post-combustion plants designed to purify the waste gases from industrial processes by combustion, and which are not operated as independent combustion plants (g) Any technical apparatus used in the propulsion of a vehicle, ship or aircraft (h) Gas turbines and gas and diesel engines, when used on offshore platforms (i) Facilities for the regeneration of catalytic cracking catalysts (j) Facilities for the conversion of hydrogen sulphide into sulphur (k) Reactors used in the chemical industry (l) Coke battery furnaces (m) Cowpers (n) Crematoria (o) Combustion plants firing refinery fuels alone or with other fuels for the production of energy within mineral oil and gas refineries (p) Recovery boilers within installations for the production of pulp
- This Directive shall not apply to research activities, development activities or testing activities relating to medium combustion plants. Member States may establish specific conditions for the application of this paragraph.
“this directive shall not apply to research activities, development activities or testing activities relating to medium combustion plants”
Periodic monitoring of the pollutants for which ELVs are defined is required every three years for MCPs ≥ one to ≤ 20 MWth and every year for MCPs > 20 MWth. Monitoring is always required for carbon monoxide (CO) even though this is not subject to an Emission Limit Value. Plants that operate for less than 500 hours per annum with an ELV exemption are not exempted from the monitoring requirements, but the frequency at which monitoring is required, which is based on cumulative operating hours, is not entirely clear.
First monitoring is required within four months of the plant being permitted/registered, for existing plants, or prior to starting operation, for new plants. If early registration is not allowed then all of the required monitoring for existing plants would be limited to a four month window and would need to be repeated in the same time frame either one or three years later. This is clearly unworkable, given the likely number of MCPs within Europe reaching into the hundreds of thousands. Early registration/permitting should therefore be encouraged.
With regards to test methods: ‘Sampling and analysis … shall be based on methods enabling reliable, representative and comparable results … EN standards shall be presumed to satisfy this requirement… the plant shall be operating under stable conditions at a representative even load … start-up and shut-down periods shall be excluded.’
There is therefore not an absolute requirement to use ISO 17025 accredited test laboratories or CEN standards (the Standard Reference Methods for NOx, SO2, CO and dust are defined by individual CEN standards). However, if these are employed they will automatically satisfy the MCPD monitoring requirements. In any case, the equipment specified for manual dust measurement, and some of the detailed test procedures within the relevant CEN standard, are not suitable for application on plants that are smaller than 20 MWth and further guidance is required. In the UK, MCERTS accredited monitoring is required for plants that are deemed to pose a significant environmental risk.
In many EU Member States, boiler emissions are already measured during annual or six-monthly service visits using equipment that is certified to appropriate CEN standards that apply to boiler testing. Provided the procedures, staff training and quality systems that underpin these measurements are robust and can satisfy the MCPD requirements, it may be possible to use such an approach, at least for plants ≤ 20 MWth. This would also share the burden with regards to the scheduling of test work. In the UK, a simplified monitoring approach for MCPs that are considered to pose a low environmental risk is defined in the Environment Agency’s Technical Guidance Note M5 (2018).
This is just a snapshot in to the MCPD. The Source Testing Association has been working closely with regulators and industry, offering technical advice and guidance for companies affected by the MCDP and this will continue during and after the implementation period.