Industrial Emissions Directive –

Implementation in the UK
RMC Brandwood & DP Graham - Uniper Technologies
Contents

 Introduction to Uniper

 UK Energy Market

 Industrial Emissions Directive & BAT in the UK

 Comparison with Elsewhere

 Summary
Acronyms and Abbreviations

AEL – Associated Emission Level LLD – Low Load Derogations

BAT – Best Available Techniques LNB – Low NOx Burners
BREF – BAT Reference MCPD – Medium Combustion Plant
CEMS – Continuous Emissions Monitoring Directive
System MSUL - Minimum Start-Up Load
CO – Carbon Monoxide NECD – National Emissions Ceiling
D1 – Draft 1 Directive
DLN – Dry Low NOx NERP - National Emissions Reduction
EIPPCB – European Integrated Pollution
Plan
Prevention & Control Bureau “The Bureau” NOx – Nitrogen Oxide
ELV – Emission Limit Value NG – Natural Gas
E-NGO – Environmental Non- O/CCGT – Open/Combined Cycle Gas
Governmental Organisation Turbine
IED – Industrial Emissions Directive TNP – Transitional National Plan
LCP – Large Combustion Plant TWG – Technical Working Group
Uniper – a new name for energy

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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.

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From gasfields and power stations to
customers: Uniper helps keep energy reliable

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Power Generation

 With approximately 40 gigawatts of

installed generating capacity, we rank
among the large international power
producers.
 With a high proportion of hydro and
gas-fired capacity, our generation fleet
is particularly climate friendly. Our highly
flexible capacity can be fine-tuned at all
times to deliver the right amount of
electricity.
 More than a century of real-world
experience in power generation
 Extensive experience managing large, complex portfolios of generation assets and
continually optimizing these assets
 Passion for innovation and continuous efficiency improvement
 Systematic knowledge management

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Engineering Services Portfolio

Asset Services Engineering Asset Projects Lenders Innovations

Services Engineering

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UK Generation Scene

Coal Plant – Traditional Mainstay, diminishing in numbers.

17GWe.

CC/GT Plant – Relatively large installed base, some early units

near end of life, but also new large units. >30GWe

Biomass – Small dedicated units and large conversions

Renewables – Increasing capacity, especially offshore. 31GWe

inc biomass

Nuclear – Aging fleet due for replacement. 9GWe.

Comment – a traditionally balanced portfolio is

shifting with less large central generation, more
intermittency and planned lower carbon intensity.
Source: UK Department of Energy & Climate Change
Driving Forces for Operators

Environment – IED implementation, Carbon Price Support,

CfD for new plant, DECC coal announcement, NECD

Security of Supply – Capacity auction, proliferation of

reciprocating engines (2GWe in two years), TSO using a range of
means to ensure supply

Biomass – large conversions awarded or awaiting contracts.

Drax 4GWe coal plant, now 3 units biomass and 3 of coal

Renewables – Increasing capacity and swings on the system,

north to south imbalance

Nuclear – Hinkley Point C (3.2GWe)? Horizon (5.4GWe)?

NuGen (3.8GWe)?

Comment – There are many driving forces

influencing the decisions of Operators, not all
environmental, but also around security.
Source: UK Department of Energy & Climate Change
Introduction - Industrial Emissions Directive

 The IED Represents a bundling of a

number of former directives, most Opt in
notably the LCP and IPPC Directives. Annex
Opt in
 Applies some form of regulation V*
Annex
regarding emissions to most LCPs. V*
(existing)

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

*Less onerous ELVs are provided for plant operating <1500

11
hpa on a rolling average basis, compared to plant with
potential to operate base load.
Timeline for IED & LCP BREF Determination
IED New Plant BREF New Plant

IED starts IED regime for all plant

IED & Associated
Flexibilities Transitional National Decreasing bubble
Plan
Limited life opt out 17,500 hours

Informal TWG* Meeting

Final TWG* Meeting

Draft Document for Forum

LCP BREF Art 13. Forum
Review & Opinion
Implementation Art 75. Committee
Implementing Decision in Official Journal

Permit review & Implementation 4 yrs to complete

*Technical Working Group 2014 2016 2018 2020 2022

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

 Mass emission = stack flow * concentration Compliance

 Stack flow calculated from fuel consumption
Protocols-
 Flow must therefore to verified by stack testing developed
 Back-up ELVs still apply. May be as monthly ELV and 95th between the
percentile of daily averages. Industry and the
Competent
 Both exclude SU-SD, as per EU Implementing Decision. Authorities.
Transitional National Plan (TNP)

 Similar to National Emissions Reduction Plan (NERP) under the

LCPD – UK one of a minority of nations employing this option.
 Compliance based on mass emissions allowances for NOx, SO2,
Dust (NOx only for CCGT) rather than IED Annex V ELVs but…
 Subject to compliance with ELVs specified on 31/12/2015
 Mass allowances based on LCPD ELVs in 2016 with linear
decrease to IED ELVs in mid 2020.
 Allows greater flexibility since: i) allowances based on operation in
2001-2010 (generally higher than 2016-2020); ii) allowances are
based on ELVs – actual performance may be better; iii) surplus
allowances can be transferred (potentially traded) with other plant;
iv) compliance can be achieved by limiting running rather than
limiting emission concentration.
TNP offers flexibility in compliance approach, but also undermines some
previous investment decisions of large Operators.

Page 14
How the TNP Regulations Work

 Reg. 4 EA must establish and maintain an electronic Register that

contains: plant data; allowances; actual mass emissions; transfers, EOI to
transfer; plant closures; plant change of status; national bubble.
 Reg. 5 Duties of regulators: issue permits that contain TNP provisions;
prevent exceedances; ensure notification of closure change of status.
 Reg. 6 Reporting. Quarterly reporting of mass emission. Other regulators
to inform EA within 1 month. Other regulators to inform EA of annual
totals by 28/2 . Regulator to make adjustments if ‘appropriate’.
 Reg. 7 Transfers. Allowed in-year and in the following quarter. Operators
taking part in a transfer to inform EA within 5 days of transfer date. EA
must enter into Register within 10 days of notification. Cannot carry
allowances forward. A transfer can’t result in an allowance ≤ 0.
 Reg. 8 Plant closure or plant variation. The regulator must determine
reduction of annual allowance, inform the EA (if applicable) within 10 days;
vary the permit. The EA must update the Register within 10 days of
notification.

Page 15
Selected TNP Allocations

NOx SO2 PM
Coal or Coal & Biomass

Drax Power Ltd 16605 33035 4129

Aberthaw 27843* 9444 1180

Ratcliffe 7145 14208 1776

West Burton 3221/3171 6336/6240 792/780

CCGT

Connah’s Quay 978/1010/1010/1025 0/0/0/0 0/0/0/0

King’s Lynn 513 0 0

Peterhead 2602 0 0
Biomass

Lynemouth 2165 4319 539

*UK is subject to infraction proceedings in relation to the permit granted for this plant – this could impact on the allocation received
Part Load Operation of GTs

 IED defines limits for normal operation (> 70% load)

 (Defined as Net ISO Base Load condition in the UK)
 BAT can be applied at a site specific level to set part load ELV….
 Allowing for GT flexibility with regards to low load and over-night
operation
 Full compliance regime applies above 70% load
(Monthly/Daily/Hourly)
 UK simplified compliance regime ≤ 70% load (Daily average only)
 Two Daily averages are reported incorporating:
i) Operation above 70% load
ii) Operation above minimum start-up load (MSUL)
Part Load Operation of GTs

250

200
CO (mg/m3)

150 CO
CO emission
emission

100 Part load ELV (110 mg/m3)

50 Base load ELV (55 mg/m3)

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

100 Part load ELV (110 mg/m3)

50 Base load ELV (55 mg/m3)

0
40% 50% 60% 70% 80% 90% 100%
MSUL
Relative Gas Turbine Load (%)

Comment - Ability to set part load ELVs in line with BAT

determination by Competent Authority critical for GT operations.
 Malfunction and Breakdown of Equipment
 Breakdown = LCP > Daily ELV AND All Units > Daily ELV
 Malfunction = LCP > Daily ELV AND Not all Units > Daily ELV
 120h annual cap applies to M&B separately with each instance notified
 Applies separately for SO2, NOx, Dust
Emissions excluded from compliance reporting but must be reported separately
along with AQ risk assessment (pro-forma)

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

Yes – JEP Site Specific BREF?

GT ELVs <70% load Protocol
During TNP No TNP
NOx Trading/Transfer

Y/N Y/Y Monitoring/

Mercury monitoring/ELVs ELV

4 years Perhaps 4 years

Time to implement revised LCP BREF <<4yrs

UK and Germany at opposite ends of the spectrum with respect to

implementation – largely arising from the nature of plant, their pre-existing FGC
equipment, as well as national priorities on emissions & AQ.
Closing Points

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.

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Roger Brandwood
Senior Engineer
Up & Midstream Technologies

Uniper Technologies Limited

Technology Centre
Ratcliffe on Soar, NG11 0EE
Nottingham
United Kingdom

mobile +44 (0) 7841 057 608

[email protected]