Large Combustion Plant (LCP) Directive Flexibility Mechanisms

Transkript

This project is co-financed by the European Union and
the Republic of Turkey
Bu Proje Avrupa Birliği ve Türkiye Cumhuriyeti
tarafından finanse edilmektedir
Technical Assistance for Better Air Quality by
Transposing the Large Combustion Plants
Directive (TR2010/0327.04-01/001)
Large Combustion Plant (LCP)
Directive Flexibility Mechanisms
By Pat Swords
Oct 2014
Directive (TR2010/0327.04-01/001)
• Content of the Presentation
– What are the Flexibility Mechanisms for
existing LCPs
– What advantages have been found by the
Member States
– The potential for the Turkish implementation
of the LCP Directive and next steps
Directive (TR2010/0327.04-01/001)
• What is an Existing Plant?
– LCP Directive 2001/80/EC defined existing plants as those
for which an operating license was granted before 1987,
i.e. 15 years before the Directive entered force.
• Existing plants had two options:
– ‘Opt out’ with operation for no more than 20,000 hours by
end of December 2015
– ‘Opt in’ and ensure compliance, either by meeting the
Emission Limit Values (ELVs) or being part of a National
Emission Reduction Plan (NERP) - the flexibility
mechanism.
Directive (TR2010/0327.04-01/001)
Options for Existing LCPs
Directive (TR2010/0327.04-01/001)
• NERP "shall reduce the total annual emissions of NOx, SO2 and
particulates from existing plants to the levels that would have
been achieved by applying the emission limit values ... to the
existing plants in operation in the year 2000, ... on the basis of:
– each plant's actual annual operating time,
– fuel used and,
– thermal input, averaged over the last five years of operation
up to and including 2000”.
• The closure of a plant included in the NERP shall not result in
an increase in the total annual emissions from the remaining
plants covered by the plan.
Directive (TR2010/0327.04-01/001)
EU Guidance on NERP clarifies:
• Compliance with the plan can be achieved by fuel
switching, combustion modifications, abatement
techniques, load factor management, etc.
• The process of determining the actual compliance
measures will be a matter for individual Member States,
taking into account, for example, cost-effectiveness,
practicability, impact on security and diversity of their
energy supplies, obligations under other Community
legislation and other relevant constraints.
Directive (TR2010/0327.04-01/001)
• A Member State can also use a combination of a National
Emission Reduction Plan for some plants and direct
compliance with the LCP Directive for others.
• "The National Emission Reduction Plan may under no
circumstances exempt a plant from the provisions laid
down in relevant Community legislation, inter alia
Directive 96/61/EC” (IPPC Directive).
• But Best Available Techniques based on ‘local
environmental conditions’ may lead to Emission Limit
Values less strict that those in LCP Directive.
Directive (TR2010/0327.04-01/001)
A form of emissions trading ensues:
• NERP is limited to a defined number of LCPs within a country;
• The total emissions under a NERP are calculated as a
’bubble’
for each pollutant. The size of the bubble for each pollutant is
the sum of what the emissions would have been if the ELVs
that would apply to new plants had applied to each existing
plant over the 5 year period 1996-2000;
• LCPs with higher costs of control could be expected to
purchase allowances from those with lower costs;
• A form of emissions trading arises – financial arrangements
are not part of the NERP and rest with participants.
Directive (TR2010/0327.04-01/001)
Advantage of NERP
• Plants individually do not have to comply with the ELVs
specified in the LCP Directive. Although they will nevertheless
have to comply with conditions set in their Pollution Control
permits.
• All plants taken together must keep their total emissions
equal to or below the level of the bubble. The bubble sets an
upper limit to emissions.
• More flexible than the LCP ELV approach because some plants
could emit more than the ELVs in balance with other plants
emitting less.
Directive (TR2010/0327.04-01/001)
The cost advantage?
• UK LCP Directive Regulatory Impact Assessment of 2002
Directive (TR2010/0327.04-01/001)
Submission of Irish semi-state Electricity Supply
Board (ESB) on cost of NOx control
• Moneypoint: 900 MWe coal fired LCP commissioned mid-80s;
€250 million desulphurisation and DeNox upgrade by 2008.
• CCGT- Combined Cycle Gas Turbine
• LNB – Low NOx burners
• SCR – Selective Catalytic Reduction
• Graph overleaf shows options for ESB to reduce NOx emissions
from 38,000 tpa and cost per tonne which results at each LCP.
Directive (TR2010/0327.04-01/001)
Directive (TR2010/0327.04-01/001)
• Base Load Plants – which run nearly continuous, such as
relatively modern coal plants like Moneypoint with their lower
operational costs
• Mid Merit Plants – which fill the gap between the peak load
and base load. In some cases the Mid Merit power plants are
older and less efficient base-load plants, not effective and
cheap enough to run full time.
• Peaker Plants – Plant which can ramp up fast for Peak Loads,
but have high operational cost.
Directive (TR2010/0327.04-01/001)
Bottom Line with ESB:
• Implementing the same ELVs to existing plants can result in
widely different cost basis expressed as tonne of pollutant
removed.
• For ESB difference was a factor of six from €3,000 per tonne
of NOx removed to €18,000 per tonne.
• Particularly acute for mid-merit plants, which have a limited
remaining lifespan and operate for reduced hours – difficult to
recuperate capital investment.
• ‘One size fits all’ of identical ELV to each existing LCP is capital
inefficient.
Directive (TR2010/0327.04-01/001)
Experience with Finnish peat fired Circulating
Fluidised Bed (CFB) LCPs and NOx control
• Report prepared as part of Submission to on-going update of
EU’s LCP Best Available Techniques Reference (BREF)
document.
• Cost basis strongly dependent not only on annual operating
hours, but lifespan of investment.
• With NOx controls, the final incremental step associated with
SCR to achieve low NOx ELVs comes with a large cost penalty.
Directive (TR2010/0327.04-01/001)
Valid Conclusion of Finnish Submission to LCP
Best Available Techniques Reference Document
• In existing boiler plants with less operation time left, it’s not
feasible to invest in emission reduction techniques with high
investment costs, like SCR. In that case, the cost for reduced
emissions would be high.
• Also at boilers with only a few years of operation left in the
future, impacts on the environment of little higher emission
level is less significant than at boilers to operate for several
decades in the future.
Directive (TR2010/0327.04-01/001)
Member States which used an NERP
approach
• UK, Finland, Ireland, Czech Republic, Hungry, Greece,
France, Spain, Netherlands and Romania.
• New Directive on Industrial Emissions (2010/75EC)
continues this approach with Transitional National Plan
(TNP) defined in Article 32.
Directive (TR2010/0327.04-01/001)
Potential for Turkey
• LCP flexibility mechanisms not transposed into 2010
by-law, but willingness to consider future
transposition.
• Existing lignite LCPs present a financial challenge with
respect to a ‘one size fits all’ approach of applying LCP
ELVs.
• Financial benefits of flexibility mechanisms proven
elsewhere, especially with respect to older LCPs with
limited run hours and remaining lifespan.
• Environmental Protection at optimised cost!
Directive (TR2010/0327.04-01/001)
Next Steps
• Regulatory Impact Assessment for LCP Implementation being
prepared.
• Operators would need to express an interest in the option of
flexibility mechanisms and as to which of their LCPs it would
apply.
• Operators would need to assist this project team in assessing
the potential cost savings between applying fixed ELVs to
these LCPs or developing an NERP approach for the Turkish
implementation.
Questions?
Directive (TR2010/0327.04-01/001)

Large Combustion Plant (LCP) Directive Flexibility Mechanisms

Transkript

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