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Jaan Hellat

European Integrated Pollution Prevention Control directive – what is it, impact on emission regulations – status and future trends. Jaan Hellat. 13/06/2007. 1st topic Frame work of emission regulations. Page 1. 2nd topic IPPC . Page 1. 3rd topic LCP and the related BAT Reference doc .

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Jaan Hellat

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  1. European Integrated Pollution Prevention Control directive – what is it, impact on emission regulations – status and future trends Jaan Hellat 13/06/2007

  2. 1st topic Frame work of emission regulations Page 1 2nd topic IPPC Page 1 3rd topic LCP and the related BAT Reference doc Page 1 4th topic IPPC hearing – IPPC review Page 1 Agenda Presentation title - 01/01/2007 - P 2

  3. trigger Emission Regulation Task Force  CAFE CAFE - Clean Air For Europe Umbrella for the impact of legislative measures on the environmental quality based on complex scenarios Action: Monitor/control EU energy scenarios (data from field) and analyse input data 2. AAQ (IMISSION) Ambient Air Quality Absolute limits for imissions for each member state Action: Collect information on PM PM-limit draft position paper 1a. TSAP (HEALTH) Thematic Strategy Air Pollution General targets for air quality e.g. PM10, NOx, SOx Action: Next steps concern PM2.5, NOx 15-25ppm Break down to country specific level 3. LCPD (EMISSION) Large Combustion Plant Directive Limits value & trading allowance Action: Ended. Now IPPC 1b. NEC - National Emission Ceilings (HEALTH) Absolute limits for emissions for each member state Action: Monitor ceiling, lobbying Cooperation with EURELECTRIC Indirect influence on plant design Direct influence on plant design Presentation title - 01/01/2007 - P 3

  4. Emission Regulation Task Force  IPPC IPPC - Integrated Pollution Prevention Control (triggered from TSAP/NEC) Directive to regulate the permitting procedure for industrial and agricultural activities Action: Currently main discussion chapter. Monitor review. Draft position paper to be made Current Review:  Inclusion of installation 20-50 MWth (offshore)  Inclusion of emission trading scheme for NOx, SOx  Definition of standard permit  Art. 10 Right of continuance BREF LCP – BAT (Best Available Technology) Reference Documents Documents that defines best available technology in the power sector. BREF often cited/asked by customers Action: Most decisive document. Draft position paper to be made so that we do not reach our real BAT Presentation title - 01/01/2007 - P 4

  5. Industrial Emissions Marianne Wenning Integrated Pollution Prevention and Control (IPPC) Directive Large Combustion Plants Directive (LCP) Solvents Directive (SE) Waste IncinerationDirective (WI) Titanium Dioxide Directive (TiO2) European Pollutant Emission Register (EPER)European Pollutant Release and Transfer Register (E-PRTR) Presentation title - 01/01/2007 - P 5

  6. 1st topic Frame work of emission regulations Page 1 2nd topic IPPC Page 1 3rd topic LCP and the related BAT Reference doc Page 1 4th topic IPPC hearing – IPPC review Page 1 Agenda Presentation title - 01/01/2007 - P 6

  7. What is the IPPC Directivefrom P J Goodsell, BP: „IPPC an Update“ Presentation title - 01/01/2007 - P 7

  8. Details on IPPC Permitsfrom P J Goodsell, BP: „IPPC an Update“ Presentation title - 01/01/2007 - P 8

  9. 1st topic Frame work of emission regulations Page 1 2nd topic IPPC Page 1 3rd topic LCP and the related BAT Reference doc Page 1 4th topic IPPC hearing – IPPC review Page 1 Agenda Presentation title - 01/01/2007 - P 9

  10. What is a BREF from P J Goodsell, BP: „IPPC an Update“ Presentation title - 01/01/2007 - P 10

  11. Legal status of ELVs, BAT and BREFfrom PM Presentation: „Best Avaialble Techniques for Large Combustion Plants“ Presentation title - 01/01/2007 - P 11

  12. What is a BAT – how is it determined?from PM Presentation: „Best Avaialble Techniques for Large Combustion Plants“ Presentation title - 01/01/2007 - P 12

  13. Aspects of BATfrom P J Goodsell, BP: „IPPC an Update“ Presentation title - 01/01/2007 - P 13

  14. Large Combustion Plant directiveGas Turbineshttp://eur-lex.europa.eu/LexUriServ/site/en/consleg/2001/L/02001L0080-20011127-en.pdf Presentation title - 01/01/2007 - P 14

  15. Large Combustion Plant directiveGas Turbineshttp://eur-lex.europa.eu/LexUriServ/site/en/consleg/2001/L/02001L0080-20011127-en.pdf Presentation title - 01/01/2007 - P 15

  16. The BAT Reference doc for Large Combustion PlantsGas Turbines Table 9: BAT for the reduction of NOX and CO emissions from gas-fired combustion plants Presentation title - 01/01/2007 - P 16

  17. The BAT Reference doc for Large Combustion PlantsGas Turbines Table 9: BAT for the reduction of NOX and CO emissions from gas-fired combustion plants Presentation title - 01/01/2007 - P 17

  18. The BAT Reference doc for Large Combustion PlantsGas Turbines Table 4: Efficiency of gas-fired combustion plants associated to the use of BAT Presentation title - 01/01/2007 - P 18

  19. For new gas turbines, dry low NOX premix burners (DLN) are BAT. For existing gas turbines, water and steam injection or conversion to the DLN technique is BAT. For gas-fired stationary engine plants, the lean-burn approach is BAT analogous to the dry low NOX technique used in gas turbines. • For most gas turbines and gas engines, SCR is also considered to be BAT. Retrofitting of an SCR system to a CCGT is technically feasible but is not economically justified for existing plants. This is because the required space in the HRSG was not foreseen in the project and is, therefore, not available. Presentation title - 01/01/2007 - P 19

  20. 1st topic Frame work of emission regulations Page 1 2nd topic IPPC Page 1 3rd topic LCP and the related BAT Reference doc Page 1 4th topic IPPC hearing – IPPC review Page 1 Agenda Presentation title - 01/01/2007 - P 20

  21. Presentation title - 01/01/2007 - P 21

  22. IPPC: important tool to achieve air pollution targets Marianne Wenning Contribution of industrial activities (mainly IPPC) to total EU emissions in 2005: 55% CO2, 88% SO2, 36% NOx, 50% particulate matter, 55% VOC Compared to Member States' projected implementationof current legislation in 2020, need for further industrial emission reductions to meet Thematic Strategy 2020 targets: - 30% for SO2 - 35% for NOx - 24% for PM2.5 - 17% for VOC (source: IIASA, cost-optimized NEC emissions, work in context of NEC revision) Presentation title - 01/01/2007 - P 22

  23. Shortcomings in implementation and enforcement Marianne Wenning Problems: Complexities in current legal framework Insufficient reduction of emissions due to lack of progress towards BAT Lack of transparency on the application of the criteria related to flexibility (technical characteristics, geographical location and local environmental conditions) Effects: Incorrect implementation (e.g. sectoral Directives used as default) or difficulties in interpretation (e.g. scope, definitions) Lower level of environmental protection Possible distortion of competition Presentation title - 01/01/2007 - P 23

  24. Main options to address current shortcomings Marianne Wenning BAT-based permitting, role of the BREFs, effectiveness of legislation (panel 1) BREFs: more prominent or binding role Possible deviation from BAT/BREFs: more transparent justification according to criteria set in the Directive (technical characteristics of installation concerned, geographical location, local environmental conditions) EU-wide minimum standards: if insufficient progress towards BAT/BREFs, new or updated standards at EU-level Inspection, permit review: more specific provisions in legislation Presentation title - 01/01/2007 - P 24

  25. Theoretical potential of BAT implementation in LCP sector Eva Goossens European Environment Agency (EEA) Wilfred Appelman & Tinus Pulles European Topic Centre for Air and Climate Change (ETC ACC / TNO)

  26. Completeness of EPER reporting NOx and SO2 reporting seems to be almost complete (>95%) NMVOC, PM10, CO reports might be missing (?) (<50%) Presentation title - 01/01/2007 - P 26

  27. Estimated BAT potential - EU 25 total Countries differ in BAT implementation. Germany, Austria, Sweden are well on the way Presentation title - 01/01/2007 - P 27

  28. Key objectives Beyond Regulatory Compliance … illustrate scope for environmental performance beyond regulatory compliance (BRC) inform EC about what are measures and levels of success to promote BRC indicate IPPC supports/barriers on promoting BRC Outline of possible changes IPPC directive Presentation title - 01/01/2007 - P 28

  29. Usefull links • IPPC Review: • http://ec.europa.eu/environment/ippc/ • http://ec.europa.eu/environment/ippc/index.htm • Executive Summary of the BREF for LCP • http://eippcb.jrc.es/pages/FAbout.htm • Preparation of the review relating to the Large Combustion Plant Directive by ENTEC • http://ec.europa.eu/environment/air/pdf/final_report_05225.pdf • TP Clean Power Concept • http://www.eunitedturbines.org/home/files/Technology_Platform_Clean_Power_Presentation_2005-03-17.pdf Presentation title - 01/01/2007 - P 29

  30. Backup Slides Presentation title - 01/01/2007 - P 30

  31. What is the relation between the IPPC Directive and the Directives listed in Annex II? • In general, the Directives listed in Annex II contain two types of provisions in relation to specific substances and/or industrial sectors: • provisions of a procedural nature setting up authorisation systems; • provisions of a more substantial nature such as emission limit values or specific technical requirements. • The procedural provisions setting up authorisation systems will be superseded by the permitting procedure set out in IPPC once this is fully implemented - not later than 30 October 1999 for new installations and 30 October 2007 for existing installations. • In contrast, substantial provisions implying specific technical obligations will remain in force until such time as they are explicitly superseded by future legislation. Operators of industrial installations will thus be required to satisfy these technical obligations as well as the more general obligations set out in IPPC. Note that, according to Article 18(2), these technical requirements constitute minimum obligations. Therefore, stricter or additional permit conditions may need to be imposed in order to implement the IPPC Directive. The same applies to the requirements of other Community legislation, including that superseding the measures listed in Annex II or otherwise adopted after the IPPC Directive, such as the Waste Incineration Directive 2000/76/EC, the Large Combustion Plants Directive 2001/80/EC and the Solvent Emissions Directive 1999/13/EC. From: http://ec.europa.eu/environment/ippc/index.htm Presentation title - 01/01/2007 - P 31

  32. "Towards a future policy on industrial emissions: Review of the IPPC Directive and related legislation" Stakeholder HearingSummary of the work: Data gathering and impact assessment for a possible technical review of the IPPC Directive Patrick ten Brink, Senior Fellow & Head of Brussels Office, IEEP ptenbrink@ieep.eu www.ieep.eu On behalf of the project team: IEEP, VITO, and Bio Friday 4 May 2007, Centre de Conference Borschette (Rue Froissart 36, Brussels)

  33. Small combustion installations Issue Possible Lowering of the threshold for combustion installations in energy industries from 50 to 20 MW (or an appropriate value) thermal input Problem definition • Presently, installations > 50 MW controlled by LCP and IPPC Directives: While LCP sets ELVs, the IPPC Directive uses permit conditions based on BAT. • Reducing the threshold from 50 to 20 MW would bring more installations and sectors under IPPC, & may lead to significant emissions reductions Options 1. (A) Do nothing (B) update the BREFs or guidance document to include BAT for the combustion installations less than 50 MW 2. Lowering the IPPC threshold from 50 to 20 MW 3. Lowering the threshold of the IPPC Directive to industrial installations of below 20 MW (with a threshold to be determined) Presentation title - 01/01/2007 - P 33

  34. Current Practice – Scale of the sector • About 3 000 combustion installations in the 20-50 MW capacity (i.e. one third of the total European combustion installations covered by EU-ETS Directive) • More than 65% of them are concentrated in 6 MS (Germany, UK, Poland, France, Italy, and Denmark) • Other MS having less than 150 installations each. • Some installations already under IPPC as directly associated activities, but UK example suggests about 1/2 - 2/3 are still not covered Presentation title - 01/01/2007 - P 34

  35. Environmental Impacts • For industrial small combustion installations, the emission estimates for SO2, NOx, PM2.5, and PM10 represent about 12%, 12%, 18% and 15% of total industrial combustion emissions of EU-25. • The impacts for POPs and heavy metals emissions significant Photochemical oxidation and acidification impacts significant - about 5% of the EU-25 activity impacts Environmental Impact significant and important to look at in earnest Presentation title - 01/01/2007 - P 35

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