Medium Combustion Plant Directive (MCPD), Are You Ready?
2018 signalled an important year for many combustion plant operators. This 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 this time, operators of Medium combustion plants (MCPs) didn’t have to worry about the regulatory side of their operation; quite simply, legislation did not apply until then.
What Is The Medium Combustion Plant Directive?
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 requires plant operators across the UK and Europe to permit their installation(s) through a competent body. Furthermore it will impose emission limit values and 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 the UK, affecting an estimated 145,000+ plants (it is believed that around 20,000 of those exist in the UK).
Do I Require An MCPD Permit?
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 were permitted before 19th December 2017 and fully operational before 17th December 2018 are classified as ‘existing’ installations and will benefit from derogation’s including the postponement (until 1st January 2024 for MCP between 5-50 MWth or 1st January 2029 for MCP between 1-5 MWth) of the date at which Medium Combustion Plant Permits will be required, with compliance within the required MCPD Emission Limit Values (ELVs) applying one year later.
Plant that were not operational until after 17th December 2018 are classified as ‘new’ installations and are expected to be both permitted and complying with ELVs with immediate effect.
| Type of MCP | MCP Permit Date | MCP ELV Compliance Date |
|---|---|---|
| New MCP | On your commissioned date | On your commissioned date |
| Existing MCP Between 5-50 MWth |
1st January 2024 | 1st January 2025 |
| Existing MCP Between 1-5 MWth |
1st January 2029 | 1st January 2030 |
MCPD Emission Limit Values
Emission Limit Values 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.
These values are the measurement of total emissions to atmosphere with ELV’s being the standard measurement for Medium Combustion Plants to limit their emissions, to attempt reducing the potential pollution to the atmosphere.
ELVs apply to all new installations under the Medium Combustion Plant Directive from 20th December 2018.
Existing plant (>5MWth) will have until 1st January 2025 before ELVs apply and existing plant (1-5MWth) until 1st 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) ELV’s
| Pollutant | Solid Biomass | Other Solid Fuel | Gas Oil | Other Liquid Fuel | Natural Gas | Other Gas Fuel |
|---|---|---|---|---|---|---|
| SO2 | 200 | 1100 | – | 350 | – | 200 |
| NOx | 650 | 650 | 200 | 650 | 250 | 250 |
| Dust | 50 | 50 | – | 50 | – | – |
Existing Plant 5-50MWth (other than Engines & Turbines) ELV’s
| Pollutant | Solid Biomass | Other Solid Fuel | Gas Oil | Other Liquid Fuel | Natural Gas | Other Gas Fuel |
|---|---|---|---|---|---|---|
| SO2 | 200 | 400 | – | 350 | – | 35 |
| NOx | 650 | 650 | 200 | 650 | 200 | 250 |
| Dust | 50 | 50 | – | 50 | – | – |
Existing Engines & Turbines ELV’s
| Pollutant | Plant Type | Gas Oil | Other Liquid Fuel | Natural Gas | Other Gas Fuel |
|---|---|---|---|---|---|
| SO2 | Engines & Turbines | – | 120 | – | 15 |
| NOx | Engines
Turbines |
190
200 |
190
200 |
190
150 |
190
200 |
| Dust | Engines & Turbines | – | 10 | – | – |
New Plant (other than Engines & Turbines) ELV’s
| Pollutant | Solid Biomass | Other Solid Fuel | Gas Oil | Other Liquid Fuel | Natural Gas | Other Gas Fuel |
|---|---|---|---|---|---|---|
| SO2 | 200 | 400 | – | 350 | – | 35 |
| NOx | 300 | 300 | 200 | 300 | 100 | 200 |
| Dust | 20 | 20 | – | 20 | – | – |
New Engines & Turbines ELV’s
| Pollutant | Plant Type | Gas Oil | Other Liquid Fuel | Natural Gas | Other Gas Fuel |
|---|---|---|---|---|---|
| SO2 | Engines & Turbines | – | 120 | – | 15 |
| NOx | Engines
Turbines |
190
– |
190
– |
95
– |
190
– |
| Dust | Engines & Turbines | – | 10 | – | – |
Medium Combustion Plant Emissions Monitoring
Monitoring of emissions to atmosphere under the Medium Combustion Plant Directive will apply to all permitted installations. Emissions 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, emissions monitoring will only need to be undertaken once every three years.
Plant in the range 20-50MWth will require annual emissions 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 MCPD Emissions 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.
How To Comply With The MCPD Regulations
In order to comply with all new required Medium Combustion Plant Directive regulations and legislation, operators need to:
- Have an MCPD Permit before the relevant deadline for your operational plants
- Be compliant with all of your permit conditions
- Pay your annual subsistence charge
- Demonstrate compliance with the ELVs in your permit by monitoring emissions at the prescribed frequency
- Demonstrate compliance by keeping a record of your plants operations for at least six years
Your Medium Combustion Plant Directive Experts
Whether you need assistance with an Environmental Permit Application, the monitoring of emissions from your Medium Combustion Plant or simply require a chat to learn more, ECL are here to help.
Our multi-disciplinary team of environmental permitting experts and emission monitoring technicians can provide a complete service to help you through the processes of complying with the Medium Combustion Plant Directive regulations.
Contact ECL via our Enquiry Form or call us on 01443 801215 for any queries regarding the MCPD, our wide range of Stack Emissions Monitoring, planning, permitting, occupational hygiene, noise monitoring, environmental monitoring or support services.