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L 15 Brandwood Uniper1
L 15 Brandwood Uniper1
Implementation in the UK
RMC Brandwood & DP Graham - Uniper Technologies
Contents
Introduction to Uniper
UK Energy Market
Summary
Acronyms and Abbreviations
4
We are an experienced international energy
company with a new name
We are Uniper: An international energy
company with about 14,000 employees
and active in more than 40 countries.
Headquartered in Düsseldorf, Germany,
Uniper ranks among large generation and
trading companies in Europe, which is one
of the world’s most important energy
markets. Through our commodity-trading
and technology-services businesses, we
are also active in energy markets from the
Americas to Asia.
Our core markets are Germany,
the United Kingdom, Sweden,
France, the Benelux countries
and Russia.
5
From gasfields and power stations to
customers: Uniper helps keep energy reliable
6
Power Generation
7
Engineering Services Portfolio
8
UK Generation Scene
BAT Conclusions
LCPs are defined as single units On-
>50MWth, or of aggregated units Shore, Transitional
National
Power,
>15MWth totalling >50MWth. All Plan
Gas
“Simplified” depiction of coverage is Plant Close
given here Opt in
There are a number of categories, some Limited Annex V
life Opt (new)
time bounded, others restricted to
Out
certain plant types placing performance Close
restrictions on assets.
The IED sets “back-stop” emissions. Off-Shore
There have been extensive delays during the review, and currently it
appears the conclusions may be published late 2016 or early 2017.
Large Combustion Plant – basis of
compliance
Regulators- there
Same for new and existing plant. are four
ELV Compliance Competent
Authorities in the
No monthly validated averages are higher than the ELV
UK:
No daily validated averages are higher than 110% ELV Environment Agency (EA)
95 % of the validated hourly average values over the year Scottish Environment
Protection Agency (SEPA)
do not exceed 200% of the ELV Natural Resources Wales
Department of
Environment Northern
TNP Compliance Ireland
Page 14
How the TNP Regulations Work
Page 15
Selected TNP Allocations
NOx SO2 PM
Coal or Coal & Biomass
Peterhead 2602 0 0
Biomass
250
200
CO (mg/m3)
150 CO
CO emission
emission
0
40% 50% 60% 70% 80% 90% 100%
MSUL
Relative Gas Turbine Load (%)
Part Load Operation of GTs
250
Example A: Continuous Part Load
Loa
200
Example B: Night-time - Day-time
CO (mg/m3)
150 CO emission
0
40% 50% 60% 70% 80% 90% 100%
MSUL
Relative Gas Turbine Load (%)
24h to restore
normal
operation or low
S fuel (0.4%)
48h to notify
10d to report
excluded data
& AQ RA
Chosen Technologies – NOx Focus
Coal Plant – Interim BAT decision does not mandate SCR, TNP and overall uncertainty in the market
incentivises low capex techniques. Therefore great movement towards advanced LNB technologies, with
some potentially seeking to achieve IED compliance/lower tonnage release using SNCR as well. In
longer term LCP BREF may force hand of Operators to either opt for <1500hpa, or request for 15(4)
derogations. Only 1 UK coal plant with SCR.
CC/GT Plant – Newer CCGT plant are not eligible for TNP. Many plant have upgraded their DLN
systems to meet Annex V limits (as these are often already in permits) and to offer better part load CO
performance. Many plant have tighter permit conditions than in IED, with some having tighter daily
averages in particular.
Biomass – For dedicated plant typically primary measures - some with SNCR. For those coal to
biomass conversions EA view is that primary measures are BAT, SCR is not, and SNCR may have
applicability restrictions. This always requires a site specific assessment to determine BAT.
Strong driver for low capex solutions due to uncertainty around opportunity to
achieve payback and extremely competitive capacity auctions. Flexibility
important, but not really rewarded in the market.
Comparison with Elsewhere (Today)
United Germany IED/LCP
Kingdom BREF
No Yes Y/N
SCR for large coal plant
No Yes Indicative
CO limits for coal plant
Key Points
There are many driving forces influencing the decisions of Operators, not all environmental, but
also around security of supply.
A traditionally balanced portfolio is shifting with less large central generation, more intermittency
and planned lower carbon intensity.
TNP offers flexibility in compliance approach but also undermines (along with BAT rules) some
previous investment decisions for large Operators.
Ability to set part load ELVs for GTs, applying below 70%, important for future flexibility
M&B excluded from compliance reporting but reported separately along with AQ risk
assessment
Implementation approach based on national priorities, such as AAQ.
The Future
BAT AEL implementation may be problematic – although final numbers, rules and implementation are
still to be finalised and the delay in doing so represents a risk to Operators.
The driver for low capex solutions is expected to continue due to uncertainty around opportunity to
achieve payback and extremely competitive capacity auctions.
Flexibility will be important, but is not really rewarded in the market.
Large, environmentally low impact, plant likely to continue to be disrupted by numerous, small, higher
emitters due to capacity market.
23
Roger Brandwood
Senior Engineer
Up & Midstream Technologies