Medium Combustion Plant Directive, Are You Ready?
2018 signalled an important year for many combustion plant operators. 2018 was the year that the Medium Combustion Plant Directive (MCPD) [Directive (EU) 2015/2193] began to roll out across the UK and Europe casting its net across previously unregulated installations.
Up until last year, operators of Medium combustion plants (MCPs) have not had to worry about the regulatory side of their operation; quite simply, legislation has not applied until now.
The purpose of the Medium Combustion Plant Directive is to bridge a gap in legislation that currently ‘misses’ MCPs (specifically combustion plant in the range 1-50MWth).
MCPD will require plant operators across Europe to permit their installation(s) through a competent body. Furthermore it will impose emission limit controls on combustion plant for specified pollutants in an attempt to improve air quality on a local, national and European scale. The European Commission states:
‘The Medium Combustion Plant Directive addresses the potential need for Member States to apply stricter emission limit values in areas where this can improve local air quality in a cost-effective way. The Commission will help Member States dealing with such hot-spots by providing information on the lowest emissions achievable with the most advanced techniques.’
The Medium Combustion Plant Directive will apply to all European Member States and will affect an estimated 145,000 plants (it is believed that around 20,000 of those exist in the UK).
Introduced in 2015, The Medium Combustion Plant Directive was transposed into UK legislation on 19th December 2017. The existing Environment Agency Environmental Permitting (England & Wales) Regulations, Pollution Prevention and Control (Scotland) Regulations and Pollution Prevention Control (Industrial Emissions) Regulations (Northern Ireland) have all been amended to allow for the MCPD provisions.
Sites that are permitted before 19th December 2017 and fully operational before 17th December 2018 will be classified as ‘existing’ installations and will benefit from derogations including the postponement (until January 2025 or January 2030) of the date at which Emission Limit Values (ELVs) will apply.
Plant that are not operational until after 17th December 2018 will be classified as ‘new’ installations and would be expected to be permitted with immediate effect; ELVs applying from the 20th December 2018.
Emission Limit Values
ELVs will apply for Oxides of Nitrogen (NOx), Sulphur Dioxide (SO2) & Total Particulate Matter (dust) [the latter two will only apply for solid and liquid fuel plant]. In addition, operators will be obliged to monitor the emissions of Carbon Monoxide (CO) although no ELV will apply.
ELVs will apply to all new installations under the Medium Combustion Plant Directive from 20th December 2018. Existing plant [>5MWth] will have until January 2025 before ELVs apply and existing plant [1-5MWth] until January 2030.
Exemptions to ELVs will apply under certain circumstances, for example where supply to ‘normal’ fuel is interrupted. Likewise, exemption apply to both new and existing plant that operate for less than 500 hours each year. A summary of ELVs that will apply can be seen below.
ELVs that will apply (expressed in mg/Nm3 at 273K; 101.3kPa; corrected for water vapour and standardised at 3% O2 (gaseous & liquid fuels), 6% O2 (solid fuels) or 15% O2 (engines & turbines)
Existing Plant 1-5MWth (other than Engines & Turbines)
Existing Plant 5-50MWth (other than Engines & Turbines)
Existing Engines & Turbines
New Plant (other than Engines & Turbines)
New Engines & Turbines
Monitoring of Emissions
Monitoring of emissions to atmosphere under the Medium Combustion Plant Directive will apply to all permitted installations. Monitoring will be undertaken periodically and the results of the monitoring exercise compared against the relevant ELVs in order to determine compliance.
For plant in the range 1-20MWth, monitoring will only need to be undertaken once every three years. Plant in the range 20-50MWth will require annual monitoring being undertaken.
The first round of monitoring is required within 4 months of the date of permitting for existing plant and immediately prior to operation for new plant; from there the annual / 3 year cycle will commence.
It is advocated that monitoring should be undertaken by a competent authority and that ‘Sampling and analysis … shall be based on methods enabling reliable, representative and comparable results … EN standards shall be presumed to satisfy this requirement ….the plant shall be operating under stable conditions at a representative even load … start-up and shut-down periods shall be excluded’.
Whilst not mandatory, we strongly recommend that measurements should be undertaken to CEN standards and by an ISO 17025 accredited test house to ensure the accuracy and credibility of the data.
Experts In The Medium Combustion Plant Directive
Whether you need assistance with applying for a permit, monitoring of emissions from your Medium Combustion Plant or simply a chat to learn some more, ECL are here to help. Our multi-disciplinary team of permitting experts and monitoring technicians can provide a complete service to help you through the processes of complying with the Medium Combustion Plant Directive.
Contact ECL via our Enquiry Form or call us on 01443 841 760 for any queries regarding the Medium Combustion Plant Directive, our wide range of Stack Emissions Monitoring, occupational hygiene, planning, permitting, noise monitoring and support services.