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Steam boiler exceeds MCPD requirements

06 August 2018

Carl Knight looks at the implications for the food and beverage processing sector of the Medium Combustion Plant Directive (MCPD). 

From the pasteurisation of milk, dairy and juice products, to jet cooking and the cleaning of brewery kegs, the list of applications for high quality, dry steam is long. However, while many steam boilers are robust, they are based on ageing technology and are often inefficient. In an effort to make them more efficient, many manufacturers have simply fitted modulating burners and bolt on economisers in an attempt to improve both steam output and efficiency.

In December 2017, the Medium Combustion Plant Directive (MCPD) was introduced to improve air quality by controlling emissions to air on all types of generators. It becomes effective on new installations from December 2018 and, depending on size, existing plant in 2025 and 2030. The MCPD applies to all combustion plant with a rated thermal input equal to or greater than 1MW but less than 50MW irrespective of the fuel used; and complements the Large Combustion Plant legislation covering plant above 50MW. However, it is worth noting that an aggregate input of all combustion plant is applied to new installations, so the MCPD can encapsulate smaller individual items of plant if the total exceeds the 1MW thermal input threshold.

Medium combustion plant such as gas- and oil-fired steam boilers are not currently regulated in the UK; and the government’s main aim for action on air quality is the impact it can have on both people’s health and the wider environment.

Imposing limits
Limits are being imposed on Nitrogen Oxides (NOx), Sulphur Oxides (SOx) and particulate emissions, with different fuels (natural gas and gas oil) attracting different limits. Carbon Monoxide (CO) must also be monitored and reported but, as yet, there are no legal limits set.

An estimated 15,000 to 30,000 manufacturing sites in the UK will eventually need to comply with the MCPD legislation; with emission limit values (ELVs) being less onerous for existing plant and depending on their input rating and fuel used. However, if food processors install new plant before 20th December 2018, life within the requirements of the MCDP will be less of a burden and less expensive because new plant commissioned before this date will not be aggregated.

This is all quite transparent if you’re installing new plant, but what if you want to upgrade existing plant? At the moment, this hasn’t been clearly defined, but the Environment Agency in England is set to publish further guidance over the summer.

As a plant owner/operator, regardless of whether you are installing new or upgrading existing plant, your obligations under MCPD legislation will include registering and/or obtaining a permit for plant; ensuring plant is regularly monitored and meets ELVs; taking measures to ensure non-compliance is minimised; recording plant operation information; keeping records proving continuous and effective operation of secondary abatement; reporting upgrades to plant that affect ELVs; assisting with MCPD-compliance inspections; and ensuring periods of plant start-up and/or shut-down are minimised.

Rather than improve existing products like its J Series to achieve these goals; and realising the implications the MCPD will have on its fuel-fired steam boiler portfolio, Fulton went back to the drawing board and, by adopting a new ‘PURE Technology’ initiative, the VSRT – it developed a vertical spiral ribbed tubeless steam boiler which offers higher efficiencies and reduces NOx emissions to levels that exceed MCPD requirements.

NOx emissions for the new boiler range are just 20ppm, which means they will not only meet the 100mg/m3 NOx requirement of the MCPD, but will also meet the planning requirement for new commercial developments from the City of London 2015-2020 air quality strategy, which states outputs of less than 40mgNOx/kWh.

Carl Knight is managing director at Fulton.

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