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ARE YOU READY FOR THE NEW LARGE COMBUSTION PLANT BEST AVAILABLE TECHNIQUES (BAT) CONCLUSIONS?

If you operate a combustion plant over 50 MWth input, you are likely to be affected by these new BAT conclusions.

 

The Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control) requires that:

Within four years of publication of decisions on BAT conclusions in accordance with Article 13(5) relating to the main activity of an installation, the competent authority shall ensure that:

(a) All  the  permit  conditions  for  the  installation  concerned  are reconsidered and, if necessary, updated to ensure compliance with  this  Directive,  in  particular,  with  Article  15(3)  and  (4), where applicable;

(b) The installation complies with those permit conditions.

This means that the Environment Agency will be required to implement these BAT conclusions within four years from July 31, 2017.

The key changes within the Large Combustion Plant Best Available Techniques Reference Document (BREF) that operators of Large Combustion Plant need to be aware of are:

  • Changes to emission limit values (including setting of daily and yearly averages)
  • Changes to emission limit values based on size of plant (for example coal fired plant <100MW 100-300 MW & >300MW for NOx)
  • Additional pollutants to be considered dependent on fuel such as carbon monoxide and mercury
  • Focus on set limits for conversion efficiency by fuel and technology based on net electrical efficiency and net total fuel utilisation

In addition, operational profiles have changed significantly from when the previous version of the Large Combustion Plant BREF was issued in 2006. The electricity market is more split into baseload, peaking and mid-range plant and the new BREF reflects this with derogations that apply to plants dependent on their operational hours.

WSP recommends that anyone likely to be affected by the newly adopted BAT conclusions starts to plan accordingly given the likely need for significant capital investment as well as variations to environmental permits in order to meet the new criteria.

Keep an eye out for further news on when and how the Environment Agency will implement the conclusions, but don’t let this delay your preparation.  Why not undertake a preliminary gap analysis to see what the new BREF means for you?  Contact WSP with any questions or support required in this area.