Impact of the IED on Large Combustion Plants
As reported here a number of months ago the Industrial Emissions Directive will revise and merge seven existing Directives, one of which is the Large Combustion Plants (LCP) Directive (2001/80/EC). LCP are those combustion plants with a rated thermal input ≥ 50 MW. Below is a summary of the main implications of the IED for LCP.
- New LCP must meet stricter emission limit values (ELVs) for nitrogen, sulphur oxides and particulates from 7 January 2013;
- Existing LCP do not become subject to any of the requirements until 1 January 2016;
- Up to June 2020, Member States may define transitional plans with declining annual caps for nitrogen oxides, sulphur dioxide and dust particles (Article 32);
- Industrial installations that are scheduled to close by the end of 2023 do not need to upgrade.
A number of derogations can be applied by Competent Authorities as follows;
- A derogation for a maximum of 6 months from the obligation to comply with the ELVs provided for sulphur dioxide where the operator is unable to comply with ELVs because of an interruption in the supply of low-sulphur fuel resulting from a serious shortage.
- a derogation from the obligation to comply with ELVs provided for in Article 30(2) and (3) where a combustion plant using only gaseous fuel has to resort to the use of other fuels because of a sudden interruption in the supply of gas. The period for which such a derogation is granted shall not exceed 10 days except where there is an overriding need to maintain energy supplies.
- The IED provides that for combustion plants firing indigenous solid fuel, which cannot comply with the ELVs for sulphur dioxide set down in the Directive, Member States may instead apply minimum desulphurisation rates as set out in Annex V;
- It is proposed that plants undertaking to close by 2023 can operate for a maximum of 17,500 hours between 1 January 2016 and ending no later than 31 December 2023 without complying with revised ELVs.
Article 32 of the IED provides that Member States may draw up and implement a transitional national plan (TNP) for existing plants (i.e. granted the first permit before 27 November 2002 or submitted an application for a permit before that date provided the plant was put into operation no later than 27 November 2003), to allow some flexibility in the period 1 January 2016 to 30 June 2020. The TNP proposed under the IED is similar to the National Emissions Reduction Plan (NERP) defined in the current LCP Directive and currently operational in Ireland.