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Power topic #EMERPT-6194-EN | Technical information from Cummins Power Generation
Medium Combustion Plants
Directive
White Paper
By Pedro Ponte, Project Application Engineer
Over 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 (SO2), nitrogen oxides
(NOx) 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.
MCPD Timeline
Definitions
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 (NOx) - nitric oxide and nitrogen
dioxide, expressed as NO and NO2.
Dust - particles, of any shape, structure or density,
dispersed in the gas (PM).
Rated thermal input (Ein) - 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 ≤ Ein < 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 2018.
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 2710 19 25, 2710 19 29, 2710 19
47, 2710 19 48, 2710 20 17 or 2710 20 19; 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.
2015
25 November
Directive (EU)
2015/2193 is signed
15 December
28 November
Directive is published in the Official
Journal of the European Union
18
Entry into force
2017
19 December
16; 17(1)
Member States Transposition deadline (laws,
regulations, administrative provisions and penalties)
2018
20 December
6(7)
New MCP’s must comply with
emission limit values
2020
1 January
18 December
14(2)
End of the 5 year period that allows
the European Commission to adopt
delegated acts.
12(1)
European Commission shall assess the benefits
of setting minimum efficiency standards in line
with best available techniques
2021
1 January
11(2)
Member States must submit a report
with estimate CO annual emissions and
information on CO concentration values
2023
1 January
12(2)
European Commission shall assess
the need to regulate CO emissions
> 5MW
2024
1 January
5(2)
Existing MCP’s with Ein > 5 MW must have
a permit or be registered
> 5MW
2025
1 January
6(2)
Existing MCP’s with Ein > 5 MW must
comply with emission limits
Legend
2026
1 October
YEAR
2018
20 December
6(7)
≤ 5MW
2029
1 January
ARTICLE (PARAGRAPH)
New MCP’s must comply with
emission limit values
5(2)
Existing MCP’s with Ein ≤ 5 MW must have a
permit or be registered
≤ 5MW
2030
1 January
New Medium Combustion
Plants
6(2)
Existing MCP’s with Ein ≤ 5 MW must
comply with emission limits
2031
Existing Medium Combustion
Plants
1 October
11(1)
Member states must submit a report with
qualitative and quantitative information with
the implementation of the Directive
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©2016 Cummins Power Generation
02 Power Topic #EMERPT-6194-EN
DATE
11(1)
Member states must submit a report with
qualitative and quantitative information with the
implementation of the Directive (estimated annual
emissions on SO2, NOx and PM included)
Scope
Emission Limit Values
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 Ein ≥
50 MW (unless the combination forms a combustion
plant covered by Chapter III of Directive 2010/75/EU).
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 273.15 K (0ºC), p
ressure 101.3 kPa
(1 atm), and corrected for water vapor content (dry
gas) with an oxygen dilution of 15%.
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).
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 c
ompliance, 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 = 273.15 K, p = 101.3 kPa, dry gas, O2 = 15%
≥1MW
≤5MW
Over
5MW
250
≥1MW
Over
≥1MW
≤5MW
5MW
≤5MW ≤20MW 20MW
>5MW
≥1MW
Over
Over
≤20MW 20MW
225
190
190
mg/Nm3
mg/Nm3
190
120
120
95
20
10
20
10
NOx (1)
Gas oil
SO2
NOx(1)
PM
NOx(1)
NOx(2)
Liquid fuels other
than gas oil
Natural
Gas
Gas oil
SO2
NOx(2)
PM
Liquid fuels other
than gas oil
NOx
Natural
Gas
(2)1850 mg/Nm3 of NOx for existing diesel engines the
construction of which commenced before 18 May 2006.
(1) Engines running between 500 and 1500 hours per year
may be exempted from compliance with this NOx limits. In this
case diesel engines must meet 750 mg/Nm3.
TABLE 1
Monitoring of Emission Limit Values
Periodic measurements (2)
First
measurements
1 MW ≤ Ein ≤ 20 Mw
MCP’s under
the scope
Exempted MCP’s
(500 h/yr)
Exempted MCP’s
(1000 h/yr)
Every 3 years
Every 1500 hours
or 5 years
Every 3000 hours
or 5 years
Applicable limited
Within 4 months (1)
Ein > 20 Mw
Pollutants to be
measured (3)
pollutants + CO
Every year
Every 500 hours
or 5 years
Every 1000 hours
or 5 years
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)
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03 Power Topic #EMERPT-6194-EN
Thermal Input
Additional Considerations
This is a Directive
Sulphur Dioxide Emissions
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.
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 SO2 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).
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
Overseas 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.
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 NOx
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
SO2 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.
04 Power Topic #EMERPT-6194-EN
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).
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©2016 Cummins Power Generation
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
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EMERPT-6194-EN (05/16)
05 Power Topic #EMERPT-6194-EN
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.