CHP Pollution Control
For CHP plants, the regulatory system takes no account of whether heat is recovered from a prime mover, or whether steam from a boiler is used to drive a turbine; it is the fuel-burning components, i.e. the gas turbines, the engines and the boilers, that are regulated as combustion processes. The only aspect of CHP that may be treated as a different case is that of supplementary firing.
The degree of environmental regulation that applies to CHP plants depends on the size and type of the plant. Within the Pollution Prevention and Control (PPC) Regulations, a thermal input capacity of 50MW was retained as the threshold above which a combustion process or installation will be regulated as a ‘Part A’ plant under either IPPC or IPC. These plants are regulated by the EA in England and Wales, and by SEPA in Scotland.
In addition, a CHP plant that is part of any industrial installation regulated under IPPC is considered as being part of that installation, since it is a directly associated activity that is technically connected to the main installation. The CHP plant must therefore be included in the operator’s IPPC application; if the CHP plant is under the control of a separate operator, then that operator must submit a separate IPPC application in conjunction with the one submitted by the operator of the main installation. Combustion plant that is rated at 20-50MW thermal input is regulated as ‘Part B’ plant in terms of emissions. In England and Wales, Part B regulation is the responsibility of the Local Authority, and is known as Local Authority Pollution Prevention and Control (LAPPC). In Scotland, SEPA are responsible for Part B plants.
All CHP plants, including plants that do not fall into either of the above two categories, are required to comply with any general legislation on pollution control (and in particular the Clean Air Acts), and the remaining sections of the EPA which cover nuisance to neighbours and the public.
The Environmental Permitting (EP) Regulations came into force on 6 April 2008. These new regulations will make existing legislation more efficient by combining Pollution Prevention and Control (PPC) and Waste Management Licensing (WML) regulations.
Since the introduction of Part A processes/ installations and Part B processes/installations under the EPA in 1990, a series of Process Guidance Notes has been produced to give information and guidance on the operation of combustion plant to both the regulatory organisations and to the operators of regulated sites. These have been produced and updated since 1990, and are now the responsibility of the EA/SEPA.
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