An overview of Directive (EU) 2015/2193 from the Power Generation business perspective

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1 Our energy working for you. TM Power topic #EMERPT-6194-EN Technical information from Cummins Power Generation Medium Combustion Plants Directive White Paper By Pedro Ponte, Project Application Engineer the past decade, raised awareness and concern over the effect of engine exhaust emissions has led to the introduction of more and more stringent regulatory limits around the world, leading to a significant reduction of pollutant emissions. Despite this, the level of air pollution in many places is still problematic. Even though the impact of current legislation has been significant, there are still gaps and not all applications are regulated. With this in mind, on 25 November 2015 the European Parliament signed a new directive that regulates emission limits from medium combustion plants. An overview of Directive (EU) 2015/2193 from the Power Generation business perspective The focus of this directive is on the reduction of sulphur dioxides (SO 2 ), nitrogen oxides (NO x ) and dust, as agreed under the Gothenburg Protocol. It also covers the issue of possible future regulation of the CO emissions and minimum energy efficiency requirements. Other directives, like the 97/68/EC, regulate the emissions for Non-Road Mobile Machinery (NRMM) and place specific requirements on the product, demanding engines under certain applications to be certified according to specific limits. This new directive, however, focuses the attention on the application itself and it addresses the responsibility of the customer, and not the equipment, in achieving and maintaining the emission levels of air pollutants at all times. The purpose of this document is to summarize the new European Medium Combustion Plants Directive (MCPD) from the power generation perspective and to examine its applicability to diesel and natural gas generator sets.

2 Definitions MCPD Timeline Directive - legislative act that sets out a goal that all EU countries must achieve. However, it is up to the individual countries to transpose this into their own laws in order to meet that goal. Nitrogen Oxides (NO x ) - nitric oxide and nitrogen dioxide, expressed as NO and NO 2. Dust - particles, of any shape, structure or density, dispersed in the gas (PM). Rated thermal input (E in ) - thermal energy input expressed in MW. Combustion Plant - any technical apparatus in which fuels are oxidized in order to use the heat generated (e.g. diesel or natural gas generator set). Medium Combustion Plant (MCP) - combustion plant with 1 MW E in < 50 MW. For generator sets this is equivalent to a power output roughly between 330 kwand 17 MW. New combustion plant - combustion plant other than an existing combustion plant. Existing combustion plant - combustion plant put into operation before 20 December 2018 or for which a permit was granted before 19 December 2017 provided that the plant is put into operation no later than 20 December Operating hours - time, in hours, during which a combustion plant is operating and discharging emissions into the air, excluding start-up and shutdown periods. Operator - any natural or legal person who operates, controls or has decisive economic power delegated over the combustion plant. Gas Oil - any petroleum-derived liquid fuel falling within CN codes , , , , or ; or any petroleum-derived liquid fuel of which less than 65% by volume (including losses) distils at 250 C and of which at least 85% by volume (including losses) distils at 350 C by the ASTM D86 method. Legend YEAR November Directive (EU) 2015/2193 is signed 15 December 18 Entry into force December 6(7) New MCP s must comply with emission limit values 18 December 14(2) End of the 5 year period that allows the European Commission to adopt delegated acts. 11(2) Member States must submit a report with estimate CO annual emissions and information on CO concentration values > 5MW (2) Existing MCP s with E in > 5 MW must have a permit or be registered October 11(1) Member states must submit a report with qualitative and quantitative information with the implementation of the Directive (estimated annual emissions on SO 2, NO x and PM included) November Directive is published in the Official Journal of the European Union 19 December 16; 17(1) Member States Transposition deadline (laws, regulations, administrative provisions and penalties) (1) European Commission shall assess the benefits of setting minimum efficiency standards in line with best available techniques (2) European Commission shall assess the need to regulate CO emissions > 5MW 6(2) Existing MCP s with E in > 5 MW must comply with emission limits 5MW DATE 20 December (7) New MCP s must comply with emission limit values New Medium Combustion Plants ARTICLE (PARAGRAPH) Existing Medium Combustion Plants 5MW 6(2) Existing MCP s with E in 5 MW must comply with emission limits (2) Existing MCP s with E in 5 MW must have a permit or be registered October 11(1) Member states must submit a report with qualitative and quantitative information with the implementation of the Directive 02 Power Topic #EMERPT-6194-EN

3 Scope This directive is applicable to Medium Combustion Plants irrespective of the type of fuel they use and also aggregated combustion plants (if using a common exhaust stack) including those where E in 50 MW (unless the combination forms a combustion plant covered by Chapter III of Directive 2010/75/EU). Amongst other situations, this directive does not apply to: Combustion plants covered by Chapter III or Chapter IV of Directive 2010/75/EU; Combustion plants covered by Directive 97/68/EC (Non-Road Mobile Machinery); Any technical apparatus used in the propulsion of a vehicle, ship or aircraft; Gas turbines and gas and diesel engines, when used on offshore platforms; Research, development or testing activities relating to medium combustion plants (subject to specific conditions from Member States). Emission Limit Values Graph 1 below summarizes the legislated emission limit values applicable to new and existing MCP s for diesel and natural gas generating sets. Emission values are defined at normalized conditions: temperature of K (0ºC), pressure kpa (1 atm), and corrected for water vapor content (dry gas) with an oxygen dilution of 15%. Monitoring of Emission Limit Values It is the responsibility of the operator to monitor and register the emission of pollutants to the air and to take the necessary measures to ensure the compliance, at all times, with the directive emission limit values (Article 7). Table 1 below summarizes the periods for monitoring of emissions by the operator, according to the Directive. GRAPH 1 Emission Limit Values for New MCP s (left side) and Existing MCP s (right side) T = K, p = kpa, dry gas, O 2 = 15% >5MW 5MW 5MW 250 5MW 5MW 5MW 20MW 20MW 20MW 20MW 225 mg/nm3 120 mg/nm NO (1) x SO 2 NO (1) x PM NO (1) x Gas oil Liquid fuels other than gas oil Natural Gas (1) Engines running between 500 and 1500 hours per year may be exempted from compliance with this NO x limits. In this case diesel engines must meet 750 mg/nm 3. TABLE 1 Monitoring of Emission Limit Values NO (2) x SO 2 NO (2) x PM Gas oil Liquid fuels other than gas oil (2)1850 mg/nm 3 of NO x for existing diesel engines the construction of which commenced before 18 May NO x Natural Gas Thermal Input 1 MW E in 20 Mw First measurements Within 4 months (1) MCP s under the scope Every 3 years Periodic measurements (2) Exempted MCP s (500 h/yr) Every 1500 hours E in > 20 Mw Every year Every 500 hours Exempted MCP s (1000 h/yr) Every 3000 hours Every 1000 hours Pollutants to be measured (3) Applicable limited pollutants + CO 1. Date from for the grant of permit, registration or start date of operation, whichever is the latest (Annex III, Part 1, paragraphs 1 and 2) 2. Member States may require continuous monitoring as an alternative to periodic measurements (Annex III, Part 1, paragraph 6) 3. Although CO emissions are not currently being limited it must, nevertheless, be measured along with the regulated pollutants (Annex III, Part 1, paragraph 3) 03 Power Topic #EMERPT-6194-EN

4 Additional Considerations This is a Directive As defined on page 2, the document in question is a directive and therefore it is a guideline on the minimum requirements that must be achieved by the Member States. This means that, until this is translated (transposed) into laws and penalties by each Member State, there isn t a clear definition of the requirements across the Member States, only an idea of the minimum. Stricter limits approach Although it is expected that the directive is to be followed in most of the Member States, as per the requirements discussed before, it is equally expected that stricter limits may be applicable in locations where the air quality is still problematic or in countries that are traditionally leading and pushing forward on lower emissions (Article 6, paragraph 9). Exemption from compliance with emission limit values The MCP s may be exempted from complying with the emission limit values if operating less than 500 hours per year, average over 5 year period. For MCP s providing backup power in connected islands or MCP s used for heat production in cold weathers this limit may be extended to 1000 hours. The exemption from compliance will be a decision from each Member State (Article 6, paragraph 3). MCP s located in the Canary Islands, French seas Departments, Madeira and Azores are not required to comply with the emission limit values defined before. These limits should be defined by the concerned Member States (Article 6, paragraph 1). Carbon Monoxide limits and minimum energy efficiency requirements The current version of the Directive was written to be flexible and allow the inclusion of future requirements. Examples of this are the CO emissions and minimum energy efficiency. Sulphur Dioxide Emissions Sulphur Dioxide emissions are mainly a consequence of the quantity of sulphur in the fuel and can be safely estimated without testing. This fact does not exonerate the operator from keeping SO 2 emissions within the legislated limits. In the event of a shortcoming on low sulphur diesel supply, a derogation for a maximum period of six months may be granted. A diesel fuel with less than 2000 PPM sulphur content would meet the requirements (Article 6, paragraph 11). Conclusions The new Directive (EU) 2015/2193, applicable to medium combustion plants (from 1MW to 50 MW thermal input), has closed a legislative gap in the field of emissions legislation. Unlike the Directive 97/68/ EC, for non-road mobile machinery, the focus and responsibility of compliance is placed on the operator and application rather than on the equipment. It is a comply-at-all-times directive that requires the customer to continuously monitor and report the emissions, leaving an open door for future regulation on carbon monoxide emissions and minimum energy efficiency. The strict limits imposed by the directive on NO x and dust emissions mean that for diesel generator sets under this scope, some form of after-treatment solution must be implemented. In order to meet the SO 2 requirements, low sulphur or ultra low sulphur diesel (ULSD) must be used. Finally, it should also be noted that both new and existing medium combustion plants, as defined above, are impacted by this directive. Although existing MCP s will have more time to adapt to these changes, eventually all will have to comply with the requirements as defined in the above timeline. The document signed on the 25th of November 2015 does not restrict maximum carbon monoxide emissions. However, it clearly states that measurements must also be made by the operator on CO emissions for all MCP s (Annex III, Part 1, paragraph 3). Aligned with this approach is also the fact that by 2020 the European Commission will assess the benefits of setting minimum energy efficiency requirements, and that by 2023 the need to regulate CO emissions will also be reviewed (Article 12, paragraph 1 and 2). 04 Power Topic #EMERPT-6194-EN

5 About the author Pedro Ponte is a Project Application Engineer in the Sales Application Engineering team. He joined Cummins Power Generation in April 2014 and provides technical support to distributors and consultants across Europe and Russia. Pedro graduated from the Portuguese Military Academy with a B.Sc. in Military Mechanical Engineering and from the Instituto Superior Técnico (Lisboa, Portugal) with an M.Sc. In Mechanical Engineering Applied Thermodynamics. References Directive (EU) 2015/2193 of the European Parliament and of the Council of 25 November 2015 on the limitations of certain air pollutants from medium combustion plants. Inc. All rights reserved. Cummins Power Generation and Cummins are registered trademarks of Cummins Inc. Our energy working for you. is a trademark of Cummins Power Generation. EMERPT-6194-EN (05/16) 05 Power Topic #EMERPT-6194-EN