Medium-sized combustion plant (with a thermal input of 1-50 MW) are widely used in the energy supply market and other industrial and commercial applications for steam raising and space heating. The polluting gases emitted by combustion plant, including oxides of nitrogen (NOx), particulates and sulphur dioxide (SO2) have serious effects on air quality and has led to new regulatory controls.
The EU developed the Medium Combustion Plant Directive (MCPD) to bring this plant under legislative control, improve air quality, help achieve national emissions ceilings and address non-compliance with existing ambient air quality standards.
In England and Wales, the MCPD was transposed into UK legislation through a 2018 amendment to the environmental permitting regulations (England and Wales) 2016 (EPR), which inserted schedule 25A, concerning medium combustion plant, and schedule 25B, concerning additional generator controls. The directive was transposed through the pollution prevention and control (PPC) regulations in Scotland and Northern Ireland, with similar requirements. However, in Scotland, the additional generator controls were not included.
The detailed requirements of the directive and amended regulations are complex, and the regulators are producing application forms and guidance soon. The first deadlines for holding permits are in December 2018 for new combustion plant, so operators of medium combustion plant and generators should ensure they understand the implications of the regulations and plan compliance measures, if they have not done so already.
Operators should take steps to:
- Develop an inventory of combustion plant (type, size and operating hours)
- Determine what applies to their operation, and when it applies
- Determine when they need to apply for a permit, and secure the resources to do so
- Check emissions from current plant, and identify whether upgrades are required
- Develop systems to address the requirements for monitoring and reporting and incorporate them into their environmental management system.
Which type of plant does the regulation cover?
Medium combustion plant with thermal input between 1 and 50 MW and specific controls on generators (which can include generators below 1 MWth in some instances) are within the scope of the amended regulations. Operators must obtain a permit (or in some cases, register plant), which will control emissions and require monitoring, reporting and records to be kept.
There is uncertainty about some detailed requirements and exemptions that may apply, but it is hoped that these will be clarified in the guidance.
In England and Wales, it was anticipated that most facilities will regulated by a simple ‘standard rules’ permitting approach. However, based on the draft screening criteria that regulators have produced, many operators are likely to need to secure a bespoke permit through the more complex regulatory approach, which may require them to produce an air quality impact assessment.
Please contact Adrian at Expirea if you would like some assistance on reviewing your permitting requirements for your combustion plant and for assistance in applying for the permits if necessary.