Is your diesel generator compliant?

28 October 2018

UK-based diesel generator specialist, Dieselec Thistle Generators, is partnering with reciprocating engine emissions control company, NOxProtekt, to tackle the challenges operators are facing in relation to the new Medium Combustion Plant Directive (MCPD) and associated updates of the UK’s Environmental Permitting Regulations. Paul Moore, Dieselec Thistle Generators and Jonathan Rodgers, NOxProtekt

The Medium Combustion Plant Directive (MCPD) is a good example of better regulation. It regulates pollutant emissions from the combustion of fuels in plants with a rated thermal input equal to or greater than 1 MWt and less than 50 MWt, and has been designed to be affordable for SMEs (small and medium-sized enterprises), and aims to provide long-term certainty for all plant operators concerned while minimising the administrative burden for both industry and EU member states. In addition, beyond being environmentally beneficial, the MCPD will encourage continued innovation and help EU industry gain an increased share of the rapidly growing global market for pollution control technology.

The MCPD regulates emissions of SO2, NOx and dust into the air with the aim of reducing those emissions and lowering the risks to human health and the environment they may cause. It also lays down rules to monitor emissions of carbon monoxide.

The MCPD entered into force on 18 December 2015 and was required to be transposed by member states into national legislation by 19 December 2017. The emission limit values set out in the MCPD have to be applied from 20 December 2018 for new plants, and by 2025 or 2030 for existing plants, depending on their size. The European Union and the MCPD have provided estimates suggesting that the number of medium combustion plants (MCPs) in the EU is approximately 143 000, however we estimate the actual number of MCPs within member states to be significantly higher.

In the context of the UK we would suggest that fixed MCPs and mobile/ rental MCPs that come under MCPD but are outside of the scope of previous EU emissions regulations could be in excess of 80 000 units in the UK alone.

It has been reported by DEFRA and the Environment Agency in the UK that a rapid rise in the number of non-regulated diesel generating sets due to demand created by the balancing services market – which enables the electrical grid to remain stable – has led to concerns about UK local air quality and the using up of National Emission Ceilings (NEC) Directive NOx allowances. This means the new legislation is particularly pertinent to many UK-based operators of diesel generators.

In the UK, following consultation during 2016/17 relating to national derogations, amendments to the Environmental Permitting Regulations came into force on 30 January 2018 that transposed the MCPD into UK law, and included additional provisions for specified generators. The Environment Agency (EA) is the competent authority for the purposes of the MCPD, and is defined as the regulator within the UK.

As an operator, if your generating equipment is within the scope of the MCPD then you are obliged to apply for a permit, monitor emissions outputs as per the advised schedule, keep a log of running hours, log evidence of fuel types used, maintain a deviation log, and keep records for six years.

If abatement is required to achieve levels, you must be able to demonstrate that this was in continuous operation.

The process is intended to be user-friendly, with accompanying guidance to enable owners and operators to submit information via an online register. The guidance for the revised Environmental Permitting Regulations and compliance with the MCPD is currently under consultation and due to be published shortly.

The main point of focus of the MCPD and associated Environmental Permitting Regulations is the limiting of emissions by combustion plant sites, with the responsibility for compliance resting with the owners/operators of medium combustion plants. This differs from other emissions regulations relating to engines, which historically have placed the burden of responsibility for compliance on the manufacturer of the combustion plant, without consideration of how the engines are used on an operator’s site. This enables the MCPD to introduce a new approach to improving air quality within the EU.

Dieselec Thistle Generators and NOxProtekt have already started to successfully retrofit selective catalytic reduction (SCR) systems to existing plant that will ensure operators meet their obligations in respect of MCPD.

If your plant is within the scope of the new Directive, it is recommended you take steps now to ensure compliance ahead of the deadline on 20 December 2018. 

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