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DRAFT 21.5.2008 BACKGROUND PAPER ON REVISION OF TECHNICAL ANNEXES

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DRAFT 21.5.2008 BACKGROUND PAPER ON REVISION OF TECHNICAL ANNEXES Powered By Docstoc
					DRAFT 21.5.2008




BACKGROUND PAPER

ON REVISION OF TECHNICAL ANNEXES OF THE UNECE CLRTAP
GOTHENBURG PROTOCOL - ANNEX V, TABLE 4




STATIONARY ENGINES SUB-GROUP UNDER THE EGTEI
FOREWORD


This report focuses on documenting information for the work on exploring options to review
emission limit values presented in the annexes of the 1999 Gothenburg Protocol. The revi-
sion of the Gothenburg protocol has been started and will be finalized in December 2009.

The driving force to start the work was that some Parties to the UNECE Convention on Long-
Range Transboundary Air Pollution have drawn particular attention to the Annexes of the
1999 Gothenburg Protocol and have expressed their view to focus attention of immediate
action on these annexes. For example, table IV of Annex V, which specifies emission limit
values for NOx emissions for new stationary engines, has created difficulties for several
countries in their ratification process.

Finland acted as lead country on exploring options and developing a proposal for considera-
tion of Parties and for a possible revision of the limits values in table IV. The work is carried
out in cooperation with representatives from the parties and industry experts with sharing
country specific information and collecting technical data.




                                                                                               2
CONTENTS OF THE REPORT

Glossary


Chapter 1    Introduction

Chapter 2    Identification of the problems

Chapter 3    Overview of information

             3.1 Current legislation
             3.2 Applicable NOx reduction measures and achievable emissions
             3.3 Contribution of stationary engines of total NOx emissions
             3.4 Technical challenges

Chapter 4    Views of Parties and Industry

             4.1 Country-specific concerns
             4.2 Concerns of industry

Chapter 5    Options for revision of the current ELVs

             5.1 Possible approaches
             5.2 Guide values, emission limit values and BAT

Chapter 6    Impact of the proposed options

Chapter 7    Conclusions and recommendations



References

Annexes

   1 Questionnaire
   2 Summary on replies received to the questionnaire on stationary engines




                                                                              3
GLOSSARY



BAT     Best available technology

BREF    EU IPPC BAT Reference Document

CHP     Combined power and heat

CI      Compression ignition

CO      Carbon monoxide

CO2     Carbon dioxide

DF      Dual fuel

ELV     Emission limit value

HFO     Heavy fuel oil

IPPC    Integrated pollution prevention technology

LPG     Liquefied petroleum gas

MWe     Electrical output in megawatts

MWth    Thermal output in megawatts

NG      Natural gas

NMVOC   Non-methane volatile organic compounds

NOx     Nitrogen oxides

PM      Particulate matter

RPM     Revolutions per minute

SCR     Selective catalytic reduction

SI      Spark ignition

SO2     Sulphur dioxide




                                                     4
1 Introduction
The aim behind preparing such a note on Stationary Engines is to put forward a discussion
paper for the Parties and non-Parties of the Gothenburg Protocol on possible revision of the
emission limit values for new stationary engines in the Table IV of Annex V of the Gothen-
burg Protocol. The information included in the note covers the best available information that
was possible to get through a questionnaire on technical data sheet/ details and legislative
situation of different countries and on help and based on the information of national experts
and engine manufactures.

The Stationary Engines Expert Group under the EGTEI was established in 2008 and had its
kick-off meeting hosted by EUROMOT in Frankfurt on 27th February 2008. The driving force
to start the work was that some Parties to the UNECE Convention on Long-Range Trans-
boundary Air Pollution had drawn particular attention to the Annexes of the 1999 Gothenburg
Protocol and especially to Table IV of Annex V, which specifies emission limit values for NOx
emissions for new stationary engines in addition to other emission limit values for combustion
plants. Several countries have expressed their views in having problems in their ratification
process for the Gothenburg Protocol due to this stationary engines limits values. These
countries have expressed their view to focus attention of immediate action on this particular
issue.

To enable correct and easy interpretation of emission limit values and specific emissions,
these are presented in 15% oxygen content in this report. The 15% oxygen content is chosen
on basis of the fact that values should be presented in a reference condition near the actual
conditions (EUROMOT Position paper, 2004: Stationary engines emission legislation – diesel
and gas). A diesel flue-gas typically contains about 13 to 15 vol-% O2, and therefore, the
emission levels associated with the use of BAT are based on an O2 level of 15 % vol-%, as
the reference point. (LCP BAT BREF Document).

1.1 The EU legislation on reducing NOx emissions

The National Emission Ceilings Directive 2000/81/EC (NECD) was adopted under EU in
2001. NECD issues total emission ceilings for emissions of sulphur dioxide (SO2), nitrogen
oxide (NOx) non-methane volatile organic compounds (NMVOC) ammonium (NH3) to be
achieved by the year 2010. NECD does not include any specific measures to reduce emis-
sions covered by the Directive.

European Union legislation specifies emissions limit values of SO2, NOx and particulate
emissions for large combustion plants (LCPs) (The Large Combustion Plants Directive
2001/80/EC). Emission limit values are issued for combustion plants with rated thermal effect
of at least 50 MW. Emission limit values are expressed as mg/m3 (n) in reference oxygen
content of 3 (liquid fuels), 6 (solid fuels) or 15 % (gas turbines). The LCP Directive does not
apply to diesel, gas or petrol fuelled stationary engines.

The EU Directive on Integrated Pollution Prevention and Control (EC/96/61) is a framework
directive for integrated environmental permitting procedures for certain industrial activities. It
includes requirements for permit conditions and for reducing emissions in an integrated way
taking into consideration all environmental effects of an activity. The permit conditions and
emission reduction requirements have to be based on application of best available tech-
niques (BAT). All activities covered by the IPPC Directive had to be permitted by the end of
year 2007.

The EU directives on non-road mobile machinery set emission limit values for NOx and hydro
carbon (HC) emissions for engines with the thermal input of less than 560 kW.

The EU legislation does not so far include emission limits values for NOx emissions for sta-
tionary engines.

                                                                                                5
The EU Directive on Ambient Air Quality and … (2007/ /EC) is a new directive including
obligations of the three existing Daughter Directives and issuing new air quality limit and tar-
get values for PM2.5 to be applied from 2015/2020.


The European Commission has made a proposal on the revision on the IPPC Directive in
December 2007. The new proposal combines seven different Directives into a single direc-
tive. These directives the IPPC Directive, the LCP directive (2001/80/EC), the Waste Incin-
eration Directive, WID (2000/76/EC), on the VOC Solvents Directive (1999/13/EC) and three
directives for TiO2 production. The proposal includes requirements permitting procedure and
application of BAT and other technical measures. The emission limit values defined in the
permit have to be derived from the BAT associated emission levels as described in the BAT
BREF Documents for different activities. And only in very special cases the emissions limit
values can deviate from the BAT based values and then at least the ELVs for different activi-
ties like for large combustion plants as defined in the LCP annex have to complied with. The
proposed ELVs for LCP, WID and VOC activities have to be applied as minimum require-
ments.

The IPPC proposal includes different transition periods for new and existing activities, for
new plants the emission limits values have to comply with in 1.5 years after entry into force of
the Directive and for existing plants 3 or 4.5 years after entry into force of the Directive.

Section II and Annex V of the IPPC Proposal focuses on LCP plants. The scope has been
broadened compare to the Directive in force. The LCP part applies now to all gas turbines
and also to diesel, petrol and gas fired stationary engines, which were not included in the
scope in the directive 2001/80/EC. In the Annex V ELVs values are proposed for gas fired
stationary engines with rated thermal input of at least 50 MWs.

Proposed ELVs

Stationary gas engines     NOx as mg/m3(n)             CO as mg/m3(n)
                           in 15 % O2                  in 15 % O2

Existing                   100                         100
New                        75                          100




Contribution of stationary engines to total NOx emissions

According to information received from the countries, the share of NOx emissions from sta-
tionary engines in the European countries can be at the maximum 4.6% (see Section 3.3).
However, the contribution of stationary engines to national NOx emissions may be increasing
due to installation of new stationary engines according the to national programmes for abat-
ing climate change.




                                                                                              6
Short Introduction to Stationary Engines

The main engine types are diesel dual fuel and spark ignited engines. The main principles
are shown in Figures 1A, B and C below. More detailed information on the reciprocating
engines is provided in reference /4/.

In the diesel process fuel and air are injected separately (not mixed) into the cylinder: air is
injected and compressed by the piston and then in the end of the compression stroke the fuel
is injected and ignited by the hot air.

The lean-burn gas engine is functioning according to the otto principle (fuel and burning air
are premixed before injection to the cylinder). The spark ignited lean burn engine is a “pure”
gas engine and the gas fuel is ignited by e.g. a spark plug.

The dual fuel engine operates in liquid mode according the diesel process. In gas mode the
dual engine functions according to the otto process, ignition of the gaseous fuel is done in
the end of the compression stroke by injecting a small amount pilot liquid fuel.




                       Figure 1A: Diesel Process (source Wärtsilä)




          Figure 1B. Spark ignition (by a spark plug) engine (source Wärtsilä)




               Figure 1C. Dual fuel engine (gas mode), (source Wärtsilä).

                                                                                              7
2 Identification of the problems
The Gothenburg Protocol includes nearly the same emission ceilings for SO2, NOx, NMVOC
and NH3 emissions for EU member States as in the NEC Directive but it covers also ceilings
for other UNECE Parties. In addition to the emission ceilings the Protocol includes annexes
on emission limit values (ELVs) for different stationary and mobile sources (LCPs, VOC,
passenger cars, light and heavy-duty vehicles, off-road mobile machinery) and guiding
documents on with descriptions of BAT.

The emission limit values in the annexes are mainly based on the EU legislation that was
adopted in 1999 with the extended time frame for application to existing sources and to coun-
tries in transition .

31 Parties have signed the Gothenburg Protocol but so far 23 Parties have ratified the Proto-
col (September 2007). Some of EU Member States and Parties from the Eastern Europe
have not made ratification so far. The problem of not ratifying the protocol seems to be the
transposition of the technical annexes into their national legislation. The problems in general
are mainly related to lack of information on technical details and need of assistance in adop-
tion the emission reduction measures described in the annexes in some EU Member States
and in countries in eastern Europe as well.

One of the major problems for Parties that have already ratified the Protocol has been trans-
position of the ELVs for NOx emissions for new stationary engines (Table 1). It has been pos-
sible to use the alternative approach instead of ELVs but some Parties that have used the
alternative approach have faced problems of showing the equivalent reductions achievable
by the used approach.

 Table 1. Limit values for NOx emissions released from new stationary engines pre-
 sented in Table 4 of Annex V in the Gothenburg Protocol in 5% and 15% oxygen con-
 tents

  Capacity, technique, fuel specification                                     Limit value (mg/m3(n)   Limit value (mg/m3(n)
                                                                              in 5% O2 *              converted into 15% O2
  Spark ignition (=Otto) engines, 4-stroke, > 1MWth
                                                - Lean-burn engines                   250                      94
                                                   - All other engines                500                     187
  Compression ignition (=Diesel) engines. > 5 MWth
                            - Fuel: natural gas (jet ignition engines)                500                     190
                                                - Fuel: heavy fuel oil                600                     225
                                          - Fuel: diesel oil or gas oil               500                     190
 * These values do not apply to engines running less than 500 hours a year.

However, the NOx emission limit values in Table 4 of Annex V of the Gothenburg protocol,
given for gas engines, seem to be in opposite order than in the German TA-Luft, where they
are 500 mg/Nm3 for lean burn gas engines and 250 mg/Nm3 for all other gas engines in 5%
oxygen content (Table 1).




                                                                                                                              8
Stationary engines versus alternative technologies

In the Annex V for the Gothenburg Protocol emission limit values for large combustion plants
and gas turbines are defined for the plants with rated thermal input of at least 50 MWs. In
Table IV of the Annex V ELVs for NOx emissions for new stationary engines have been de-
fined for engines with rated thermal input more than 1 MW (“otto engines”) or 5 MW (“diesel
engines”).

The differences in the emission limit values for larger boilers ( 50 MW) and stationary en-
gines lead to situations where competing technologies are nor treated equally e.g. oil fired
boilers of 10 MWs are not regulated but diesel engines of 10 MWs have to comply with an
emission limit of 600 mg NO2/m3 (n) in 5 % O2 (corresponding to 225 NO2/m3 (n) in 15 % O2).

According to the European Union Directive on IPPC 96/61/EC, integrated approach and ap-
plication of BAT (Best Available Technique) should be considered and used for combustion
installations larger than 50 MW th. In the IPPC directive no specific measures are described
for stationary engines.

New stationary engines below 1 or 5 MW th are at the moment regulated in the Gothenburg
Protocol, and, these emission limit values are beyond the BAT range values presented in the
EU BAT BREF and other BREF documents. In the BREF LCP document mentioned in con-
                                           3
text with BAT NOx levels of 20 -75 mg/Nm (15 % O2) with new gas engines and BAT options
with lean burn concept low-NOx tuned (and oxidation catalyst for CO) or SCR (and oxidation
catalyst for CO). The industry has stated this not to be BAT rather LAER and therefore pro-
posed 190 mg/Nm3 NOx as BAT (overall emission optimum, lowest CO2 and unburned spe-
cies).

In the EU LCP BREF document an example was given from a gas-fired engine plant with 20
gas engines operating in the US with the total capacity of 111 MW. The NOx emissions with-
out SCR of that plant were 159 mg/nm3 in 15% O2 and with SCR the NOx emissions were
5.19 mg/nm3 in 15% O2.

Detailed descriptions of the technical challenges are presented in Chapter 3.4.




3 Overview of information

This chapter collects information of the contribution of stationary engines to total NOx emis-
sions as well as on related legislation, applicable reduction measures and achievable emis-
sions with technical challenges to be overcome. A questionnaire (attached as Annex 1) was
sent out to get information from countries on their current environmental legislation of sta-
tionary engines and from engine manufactures on technical details of stationary engines.


 3.1 Current EU and non-EU legislation on nitrogen oxide emissions from
     stationary engines

Guide values by international organisations

NOx guide values for stationary engines below 50 MW given by international organizations
are presented in Table 2. These organizations, like the World Bank, use these guide values
when they e.g. give funding for certain projects in the developing countries.


                                                                                            9
Table 2. NOx emission limit /guide values in EU and non-EU legislation for sta-
tionary engines

                                                                                                NOx in mg/m3(n) in
  Organization                  Technology
                                                                                                     15 % O2
                                Existing stationary engines (gas turbines and diesel, petrol,
  EU Commission, Draft IPPC                                                                            100
                                gas fired engines)
  proposal on LCP plants*
                                New stationary engines                                                 75
  UNECE                         Gas fired > 1 MWth                                                     94
                                Stationary engines 3-50 MWth , gas fired, spark ignition               200
                                Stationary engines 3-50 MWth , gas fired, dual fuel                    400
                                Stationary engines 3-50 MWth , gas fired, compression igni-
                                                                                                      1600
  World Bank General Envi-      tion
  ronmental Health and Safety   Stationary engines 3-50 MWth , liquid fuel, bore diameter <
  (EHS) Guidelines              400 mm or up to 1600 if justified to maintain high energy             1460
                                efficiency
                                Stationary engines 3-50 MWth , liquid fuel, bore diameter
                                                                                                      1850
                                400


Country-specific ELVs

Based on the information collected from the countries through the questionnaire, national
legislation specific to stationary engines exist at least in Belgium, the Czech Republic, Den-
mark, Greece, Germany, Hungary, the Netherlands, and the UK. A compilation of the results
for NOx ELVs is presented in Table 3 and a summary on replies received to the questionnaire
on stationary engines in Annex 2.

Based on information received to the questionnaire the currently applied emission
limit values have large variations. Examples of national emission limit values for stationary
engines using liquid fuels are presented in Figure 2 and for gaseous fuels in Figure 3.

Comparison between the ELVs shows that the values are generally higher for
   • old engines
   • engines with small capacity
   • engines with small operation hours

Specific for the liquid fuel engines it seems to be that ELVs for spark ignition are
higher than for compression ignition techniques. For gaseous fuels ELVs are higher
for engines using biogas and engines used for combined heat and power (CHP).

Based on these data it is also hard to estimate, if the emission limit values given in
the Gothenburg Protocol have been met.




                                                                                                                     10
                                                                                                                                                          0
                                                                                                                                                       1000
                                                                                                                                                       1200
                                                                                                                                                       1400
                                                                                                                                                       1600
                                                                                                                                                       1800
                                                                                                                                                       2000




                                                                                                                                                        200
                                                                                                                                                        400
                                                                                                                                                        600
                                                                                                                                                        800
                                                                                                                                                                                                                  mg/Nm³


                                                                                                                                             A l l > 0 .0 5
                                                                                                                                                                                                Oil & bio-oil
                                                                                                                                                                                                                  (15 % O2)


                                                                                                                                          S C R > 0 .0 5
                                                                                                                                                                         Oil & bio-oil
                                                                                                                                 E n g in e s > 0 .1 2 0
                                                                                                                                                                 Gas oil, diesel
                                                                                                                 S p a r k i g n i ti o n (O tto ) 0 .2 -1
                                                                                                                                                                Liquid fuel
                                                                                                 C o m p re s s io n ig n itio n (D ie s e l) 0 .2 -1                                               Liquid fuel
                                                                                                                            D ie s e l e n g in e 0 .3
                                                                                                                                                                                                            Diesel oil
                                                                                                                              D ie s e l e n g in e < 3
                                                                                                                                                                                                   Diesel oil
                                                                                                                         D ie s e l e n g in e 0 .3 -5                Diesel oil
                                                                                                                                         E n g in e s > 1
                                                                                                                                                               HFO
                                                                                                     C o m p re s s io n & S p a rl ig n itio n 1
                                                                                                                                                               Liquid fuel
                                                                                                                     S p a r k i g n i ti o n (O tto ) > 1      Liquid fuel
                                                                                                    C o m p re s s io n ig n itio n (D ie s e l) > 1                 Heavy gasoil
                                                                                                   C o m p re s s io n ig n itio n (D ie s e l) 1 -5                                                Liquid fuel
                                                                                                                                     D u a l fu e l 2 -2 0                 Domestic/other fuel
                                                                                                                                      < 5 0 0 h /a 2 -2 0                       Domestic/other fuel
                                                                                                 D u a l fu e l , r o ta ti o n > 1 2 0 0 t/m i n , 2 -2 0                               Domestic/other fuel
                                                                                                  D u a l fu e l, ro ta tio n < 1 2 0 0 t/m in 2 -2 0                               Domestic/other fuel
                                                                                                                               D ie s e l e n g in e < 3
                                                                                                                                                                                                                              STATIONARY ENGINES – ELVs FOR LIQUID FUELS




                                                                                                                                                                                                    Diesel oil
                                                                                                                               D ie s e l e n g in e > 3                        Diesel oil
                                                                                                                           D ie s e l e n g in e 3 -5                           Diesel oil
                                                                                                                              D ie s e l e n g in e 5           Diesel oil
                                                                                                                     S p a r k i g n i ti o n (O tto ) > 5       Liquid fuel
                                                                                                    C o m p re s s io n ig n itio n (D ie s e l) > 5                            Liquid fuel
                                                                                                             C o m p re s s io n ig n itio n 2 0 -5 0                                          Gasoil
                                                                                                                         N e w < 5 0 0 h /a 2 0 -1 0 0                                Domestic/residential fuel
                                                                                                                          N e w > 5 0 0 h /a 2 0 -1 0 0                Domestic/residential fuel
                                                                                                                          O ld < 5 0 0 h /a 2 0 -1 0 0                                              Domestic/residential fuel
                                                                                                                          O ld > 5 0 0 h /a 2 0 -1 0 0
Figure 2. Examples of national emission limit values for stationary engines using liquid fuels



                                                                                                                                                                        Domestic/residential fuel
                                                                                                            N e w , S C R /h ig h e ffic ie n t S C R           Oil & bio-oil
                                                                                                             O ld , S C R /h ig h e ffic ie n t S C R                    Oil & bio-oil
                                                                                                           IS O n e t b a s e e ffic ie n c y > 4 0 %                                    HFO
                                                                                                                                        F o u r-s tro k e       Petrol
                                                                                                    All capacities
                                                                                                                                                                                                    UK




                                                                                                                                           T w o -s to k e            Petrol
                                                                                                                                                                                                    France
                                                                                                                                                                                                    Belgium




                                                                                                                                                                                                    Hungary
                                                                                                                                                                                                    Denmark

                                                                                                                                                                                                    Germany




                                                                                                                                                    (MW)
                                                                                                                                                                                                    Netherlands




                                                                                                                                                    Capacity
                                                                                                                                                                                                    Czech Republic
                                                                                                                                            0
                                                                                                                                                       200
                                                                                                                                                                400
                                                                                                                                                                        600
                                                                                                                                                                               800
                                                                                                                                                                                      1000
                                                                                                                                                                                               1200
                                                                                                                                                                                                      1400
                                                                                                                                                                                                             1600
                                                                                                                                                                                                                    mg/Nm³


                                                                                                           Motor management >0.050
                                                                                                                                                                                                                    (15 % O2)


                                                                                                      Motor manag. lean burn > 0.050                                       Gas+bio
                                                                                                                                                       Locally decided, Gas&biogas
                                                                                                                    Lean burn > 0.050
                                                                                                                       Engines > 0.120                   Gas+bio
                                                                                                                                                             NG, LPG, gasification gas
                                                                                                                       Engines > 0.120
                                                                                                              Spark ignition (Otto) < 1                           Biogas
                                                                                                                                                                  Biogas
                                                                                                    Compression ignition (Diesel) < 1
                                                                                                                                                                                                             NG
                                                                                                                 spark/jet ignition 1
                                                                                                                                                       All except bio-, sewage- & mine gas
                                                                                                     ISO net base efficiency >40% , >1
                                                                                                                                                            Mine gas
                                                                                                   Compression (DI) + Spark (Otto) > 1
                                                                                                                                                         Biogas, NG
                                                                                                           Compression ignition, 1-3
                                                                                                                                                              Biogas. sewage gas
                                                                                                                    Pilot injection, 1-3
                                                                                                                                                                                Biogas. sewage gas
                                                                                                                               All, 2-20
                                                                                                                                                        LPG+NG
                                                                                                                        Dual fuel, 2-20
                                                                                                                                                           LPG+NG
                                                                                                                         < 500 h/a, 2-20
                                                                                                                                                         LPG+NG
                                                                                                                               All, 2-20
                                                                                                                                                         LPG+NG
                                                                                                                        Dual fuel, 2-20
                                                                                                                                                              LPG+NG
                                                                                                            Spark+ pilot ignition, 3
                                                                                                                                                          Biogas. sewage gas
                                                                                                                               All, > 20
                                                                                                                       <500 h/a, 20-100         Other gases: Defined at local
                                                                                                                                                                                                                                STATIONARY ENGINES – ELVs FOR GASEOUS FUELS




                                                                                                                                                level     NG
                                                                                                                  CHP, <500 h/a, 2-100
                                                                                                                                                                  NG
                                                                                                            Dual fuel, <500 h/a, 20-100
                                                                                                       CH,P dual fue, <500 h/a, 20-100                                                    NG
                                                                                                                       >500 h/a, 20-100                                                   NG
                                                                                                                                                        NG
                                                                                                                CHP, > 500 h/a, 20-100
                                                                                                                                                        NG
                                                                                                                       >500 h/a, 20-100
                                                                                                                 CHP, > 500 h/a,20-100                            NG
                                                                                                                                                                   NG
                                                                                                                           Four-stroke
 Figure 3. Examples of national emission limit values for stationary engines using gaseous fuels



                                                                                                                                                         NG
                                                                                                                            Two-stroke
                                                                                                                     Lean-burn + SCR                            NG

                                                                                                        ISO net base efficiency >40%
                                                                                                                                                   Gas+bio
                                                                                                                                                                        Gas (dual fuel)
                                                                                                             New, Motor management
                                                                                                              Old, Motor management                             Gas+bio
                                                                                                                                                                                                             UK




                                                                                                               ELV capacity adjusted                                                      Gas+bio
                   All capacities
                                                                                                                                                                                                             France
                                                                                                                                                                                                             Belgium




                                                                                                                                                                       Gas
                                                                                                                                                                                                             Hungary
                                                                                                                                                                                                             Denmark

                                                                                                                                                                                                             Germany




                                                                                                         93-00 ELV capacity adjusted
                                                                                                                                                                                                             Netherlands




                                                                                                                                                                                          Biogas
                                                                                                         >2000 ELV capacity adjusted
                                                                                                                                                                                                             Czech Republic




                                                                                                                                                         Gas
                                                                                                                                     (MW)
                                                                                                                                            Capacity




12
Table 3. Country specific NOx emission limit values for stationary in the EU

Country                                                                                                                          Date for ELV applied
                                      Technology       Capacity
                                                                  Fuel         ELV for NOx        Unit of ELV         New         Old
                                                       (MWth)

Belgium
                                                                  Gas          487 x /30 (974 x   mg/Nm³ (at 15 % O2) 1.1.2008
licensed between 1.1.1993 and 1.1.2000 Gas engine                               /30 in case of
                                                                               biogas)
                                                                  Gas          187 x /30          mg/Nm³ (at 15 % O2) 1.1.2000
licensed between 1.1.2000 and 1.1.2005 Gas engine

Licensed > 1.1.2005                   Gas engine        1         Gas          187 x /30          mg/Nm³ (at 15 % O2) 1.1.2005
                                      Gas engine       >1         Gas          187 x /30          mg/Nm³ (at 15 % O2) 1.1.2005
Licensed < 1.1.1993                   Diesel engine     0.3       Diesel oil   1873               mg/Nm³ (at 15 % O2) 1.1.2008
Licensed between 1.1.2000 and 1.1.2005 Diesel engine    0.3       Diesel oil   1498               mg/Nm³ (at 15 % O2) 1.6.1995/ 1.1.2008
                                                                  Diesel oil                      mg/Nm³ (at 15 % O2) 1.1.2000    1.1.2008
Licenced between 1.1.2000 and 1.1.2005 Diesel engine 0.3-3                     1498

Licensed between 1.1.2000 and 1.1.2005 Diesel engine    3-5       Diesel oil   749                mg/Nm³ (at 15 % O2) 1.1.2000    1.1.2008
Licensed between 1.1.2000 and 1.1.2005 Diesel engine    5         Diesel oil   187                mg/Nm³ (at 15 % O2) 1.1.2000    1.1.2008
Licensed > 1.1.2005                   Diesel engine     0.3-5     Diesel oil   375                mg/Nm³ (at 15 % O2) 1.1.2005    1.1.2008
Licensed > 1.1.2005                   Diesel engine     5         Diesel oil   187                mg/Nm³ (at 15 % O2) 1.1.2005    1.1.2008




                                                                                                                                                        13
Country                                                                                                         Date for ELV applied
                 Technology                      Capacity
                                                            Fuel          ELV for NOx   Unit of ELV           New         Old
                                                 (MWth)
Check Republic
                 Spark ignition (Otto)           0,2-1 MW   Liquid fuel   190           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           1-5 MW     Liquid fuel   190           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           > 5 MW     Liquid fuel   190           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           0,2-1 MW   NG            190           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           1-5 MW     NG            190           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           > 5 MW     NG            190           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           0,2-1 MW   biogas        380           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           1-5 MW     biogas        380           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           > 5 MW     biogas        190           mg/Nm³ (at 15 % O2)              17.5.2006
                 Compression ignition (Diesel)   0,2-1 MW   Liquid fuel   1520          mg/Nm³ (at 15 % O2)              17.5.2006
                 Compression ignition (Diesel)   1-5 MW     Liquid fuel   1520          mg/Nm³ (at 15 % O2)              17.5.2006
                 Compression ignition (Diesel)   > 5 MW     Liquid fuel   760           mg/Nm³ (at 15 % O2)              17.5.2006
                 Compression ignition (Diesel)   0,2-1 MW   NG            1520          mg/Nm³ (at 15 % O2)              17.5.2006
                 Compression ignition (Diesel)   1-5 MW     NG            1520          mg/Nm³ (at 15 % O2)              17.5.2006
                 Compression ignition (Diesel)   > 5 MW     NG            760           mg/Nm³ (at 15 % O2)              17.5.2006
                 Spark ignition (Otto)           0,2-1 MW   Liquid fuel   190           mg/Nm³ (at 15 % O2) 17.5.2006
                 Spark ignition (Otto)           1-5 MW     Liquid fuel   190           mg/Nm³ (at 15 % O2) 17.5.2006
                 Spark ignition (Otto)           > 5 MW     Liquid fuel   190           mg/Nm³ (at 15 % O2) 17.5.2006

                 Spark ignition (Otto)           0,2-1 MW   NG            190           mg/Nm³ (at 15 % O2) 17.5.2006




                                                                                                                                       14
Country                                                                                                                  Date for ELV applied
                           Technology                      Capacity
                                                                      Fuel         ELV for NOx   Unit of ELV         New           Old
                                                           (MWth)
… Check Republic (cont.)
                           Spark ignition (Otto)           1-5 MW     NG           190           mg/Nm³ (at 15 % O2) 17.5.2006
                           Spark ignition (Otto)           > 5 MW     NG           190           mg/Nm³ (at 15 % O2) 17.5.2006
                           Spark ignition (Otto)           0,2-1 MW   biogas       380           mg/Nm³ (at 15 % O2) 17.5.2006
                           Spark ignition (Otto)           1-5 MW     biogas       190           mg/Nm³ (at 15 % O2) 17.5.2006
                           Spark ignition (Otto)           > 5 MW     biogas       190           mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   0,2-1 MW   Heavy gas oil 1520         mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   1-5 MW     Heavy gas oil 228          mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   > 5 MW     Heavy gas oil 288          mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   0,2-1 MW   Gas oil      1520          mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   1-5 MW     Gas oil      190           mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   > 5 MW     Gas oil      190           mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   0,2-1 MW   NG           1520          mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   1-5 MW     NG           190           mg/Nm³ (at 15 % O2) 17.5.2006
                           Compression ignition (Diesel)   > 5 MW     NG           190           mg/Nm³ (at 15 % O2) 17.5.2006




                                                                                                                                                15
Country                                                                                                                                    Date for ELV applied
            Technology                                               Capacity
                                                                                  Fuel           ELV for NOx   Unit of ELV           New             Old
                                                                     (MWth)
Denmark
            Engines                                                  >120 kW      NG and LPG 209               mg/Nm³ (at 15 % O2) 17.10.2006
                                                                                  Gasification                 mg/Nm³ (at 15 % O2) 17.10.2006
            Engines                                                  >120 kW                     209
                                                                                  gas
            Engines                                                  >120 kW      Biogas         380           mg/Nm³ (at 15 % O2) 6.11.2005
                                                                                  Gas oil, diesel
            Engines                                                  >120 kW      oil, vegetable 209           mg/Nm³ (at 15 % O2) 6.11.2005
                                                                                  oil
            Engines                                                  >1 MW        HF             76            mg/Nm³ (at 15 % O2) 6.11.2005


Country                                                                                                                                    Date for ELV applied
          Technology                                                 Capacity
                                                                                  Fuel           ELV for NOx   Unit of ELV           New             Old
                                                                     (MWth)
France
          All dual fuel engines in combustion installations (new,    2< Pi < 20                                mg/Nm³ (at 15 % O2)
                                                                                  LPG            133                                 1.1.2000
          declared after 1.1.1998)                                   MW
          All except dual fuel engines in combustion installations   2< Pi < 20                                mg/Nm³ (at 15 % O2)
                                                                                  NG             133                                 1.1.2000
          (new declared after 1.1.1998)                              MW
                                                                                  Other fuels                  mg/Nm³ (at 15 % O2)
          All except dual fuel engines in combustion installations 2< Pi < 20
                                                                                  than LPG and 570                                   1.1.2000
          (new, declared after 1.1.98)                             MW
                                                                                  NG
          Dual fuel engines in combustion installations (new,        2< Pi < 20                                mg/Nm³ (at 15 % O2)
                                                                                  LPG            266                                 1.1.2000
          declared after 1.1.1998)                                   MW
          Dual fuel engines in combustion installations (new,        2< Pi < 20                                mg/Nm³ (at 15 % O2)
                                                                                  NG             266                                 1.1.2000
          declared after 1.1.1998)                                   MW
          Dual fuel engines in combustion installations (new,        2< Pi < 20                                mg/Nm³ (at 15 % O2)
                                                                                  Domestic fuel 570                                  1.1.2000
          declared after 1.1.1998)                                   MW



                                                                                                                                                                  16
Country                                                                                                                                  Date for ELV applied
           Technology                                                Capacity
                                                                                  Fuel          ELV for NOx      Unit of ELV          New          Old
                                                                     (MWth)
… France (cont.)
Rotation
regime     Dual fuel engines in combustion installations (new,       2< Pi < 20                                 mg/Nm³ (at 15 % O2) 1.1.2000
                                                                                  Other fuels   570
1200       declared after 1.1.1998)                                  MW
t/min
           Engines working less than 500 h/a in combustion instal-   2< Pi < 20                                 mg/Nm³ (at 15 % O2) 1.1.2000
                                                                                  LPG           190
           lations (new, declared after 1.1.1998)                    MW
           Engines working less than 500 h/a in combustion instal-   2< Pi < 20                                 mg/Nm³ (at 15 % O2) 1.1.2000
                                                                                  NG            190
           lations (new, declared after 1.1.1998)                    MW
           Engines working less than 500 h/a in combustion instal-   2< Pi < 20                                 mg/Nm³ (at 15 % O2) 1.1.2000
                                                                                  Domestic fuel 722
           lations (new, declared after 1.1.1998)                    MW
           Engines working less than 500 h/a in combustion instal-   2< Pi < 20                                 mg/Nm³ (at 15 % O2) 1.1.2000
                                                                                  Other fuels   722
           lations (new, declared after 1.1.1998)                    MW
           All except dual fuel engines in existing combustion       2< Pi < 20                                 mg/Nm³ (at 15 % O2) 1.1.2005
                                                                                  LPG           200
           installations, declared before 1.1.1998                   MW
           All except dual fuel engines in existing combustion       2< Pi < 20                                 mg/Nm³ (at 15 % O2) 1.1.2005
                                                                                  NG            200
           installations, declared before 1.1.1998                   MW
                                                                                                855 ( 1200
           All except dual fuel engines in existing combustion       2< Pi < 20                                   mg/Nm³ (at 15 % O2) 1.1.2005
                                                                                  Domestic fuel t/min)
           installations, declared before 1.1.1998                   MW
                                                                                                7500< 1200 t/min)
                                                                                                855 ( 1200
           All except dual fuel engines in existing combustion       2< Pi < 20                                   mg/Nm³ (at 15 % O2) 1.1.2005
                                                                                  Domestic fuel t/min)
           installations, declared before 1.1.1998                   MW
                                                                                                7500< 1200 t/min)
                                                                                                855 ( 1200
           All except dual fuel engines in existing combustion       2< Pi < 20                                   mg/Nm³ (at 15 % O2) 1.1.2005
                                                                                  Other fuels   t/min)
           installations, declared before 1.1.1998                   MW
                                                                                                7500< 1200 t/min)
           Dual fuel engines in existing combustion installations, 2< Pi < 20                                   mg/Nm³ (at 15 % O2 1.1.2005
                                                                                  LPG           399
           declared before 1.1.1998                                MW




                                                                                                                                                                17
Country                                                                                                                                   Date for ELV applied
             Technology                                             Capacity
                                                                                  Fuel          ELV for NOx      Unit of ELV          New           Old
                                                                    (MWth)
… France
(cont.)
             Dual fuel engines in existing combustion installations, 2< Pi < 20                                 mg/Nm³ (at 15 % O2 1.1.2005
                                                                                  NG            399
             declared before 1.1.1998                                MW
                                                                                                855 ( 1200
             Dual fuel engines in existing combustion installations, 2< Pi < 20                                   mg/Nm³ (at 15 % O2) 1.1.2005
                                                                                  Domestic fuel t/min)
             declared before 1.1.1998                                MW
                                                                                                7500< 1200 t/min)
                                                                                                855 ( 1200
             Dual fuel engines in existing combustion installations, 2< Pi < 20                                   mg/Nm³ (at 15 % O2) 1.1.2005
                                                                                  Other fuels   t/min)
             declared before 1.1.1998                                MW
                                                                                                7500< 1200 t/min)
             All working less than 500 h/a, new authorized after                                                mg/Nm³ (at 15 % O2) 12.4.2000
*) for CHP                                                          20-100        Domestic fuel 950/979**
             4.12.00
*) for CHP   All working more than 500 h/a, new authorized after                                                mg/Nm³ (at 15 % O2) 12.4.2000
                                                                    20-100        Domestic fuel 380/391*
             4.12.00All working more than 500 h/a
*) for CHP   All working less than 500 h/a, new authorized after                                                mg/Nm³ (at 15 % O2) 12.4.2000
                                                                    >100          Domestic fuel 570/599*
             4.12.00
*) for CHP   All working more than 500 h/a, new authorized after                                                mg/Nm³ (at 15 % O2) 12.4.2000
                                                                    >100          Domestic fuel 228/239*
             4.12.00
*) for CHP   All working less than 500 h/a, new authorized after                                                mg/Nm³ (at 15 % O2) 12.4.2000
                                                                    20-100        Residual fuel 950/979*
             4.12.00
*) for CHP   All working more than 500 h/a, new authorized after                                                mg/Nm³ (at 15 % O2) 12.4.2000
                                                                    20-100        Residual fuel 380/391*
             4.12.00All working more than 500 h/a
*) for CHP   All working less than 500 h/a, new authorized after                                                mg/Nm³ (at 15 % O2) 12.4.2000
                                                                    >100          Residual fuel 570/599*
             4.12.00
*) for CHP   All working more than 500 h/a, new authorized after
                                                                    >100          Residual fuel 599/630*        mg/Nm³ (at 15 % O2) 12.4.2000
             4.12.00




                                                                                                                                                                 18
Country                                                                                                                  Date for ELV applied
                   Technology                        Capacity
                                                                Fuel            ELV for NOx      Unit of ELV           New         Old
                                                     (MWth)
… France (cont.)
*) for CHP         All working less than 500 h/a,                                                mg/Nm³ (at 15 % O2) 12.4.2000
                                                     20-100     NG              333/361*
                   new authorized after 4.12.00
*) for CHP         All working less than 500 h/a,               NG
                   dual fuel, new authorized after                                               mg/Nm³ (at 15 % O2) 12.4.2000
                                                     20-100                     950/979*
                   4.12.00All working more than
                   500 h/a
*) for CHP         All working more than 500 h/a,    20-100     NG
                   dual fuel, new authorized after                              133/144*         mg/Nm³ (at 15 % O2) 12.4.2000
                   4.12.00
*) for CHP         All working more than 500 h/a,    20-100     NG                               mg/Nm³ (at 15 % O2) 12.4.2000
                                                                                380/391*
                   new authorized after 4.12.00
*) for CHP         All working less than 500 h/a,               NG                               mg/Nm³ (at 15 % O2) 12.4.2000
                                                     >100                       238/266*
                   new authorized after 4.12.00
*) for CHP         All working less than 500 h/a,               NG
                   dual fuel new authorized after    >100                       713/741*         mg/Nm³ (at 15 % O2) 12.4.2000
                   4.12.00
*) for CHP         All working more than 500 h/a,               NG                               mg/Nm³ (at 15 % O2) 12.4.2000
                                                     >100                       95/106*
                   new authorized after 4.12.00
*) for CHP         All working more than 500 h/a,               NG
                   dual fuel new authorized after    >100                       285/296*         mg/Nm³ (at 15 % O2) 12.4.2000
                   4.12.00
*) for CHP         All new authorized after                     Other gases     Defined at the   mg/Nm³ (at 15 % O2) 12.4.2000
                                                     > 20
                   4.12.00                                                      local level
*) for CHP         All working more than 500 h/a,               Domestic fuel                                                     Defined at the
                                                     20-100                     722/733*         mg/Nm³ (at 15 % O2)
                   new authorized after 4.12.00                                                                                   local level
*) for CHP         All working less than 500 h/a,               Domestic fuel                                                     Defined at the
                                                     >100                       1805/1834*       mg/Nm³ (at 15 % O2)
                   new authorized after 4.12.00                                                                                   local level




                                                                                                                                                   19
Country                                                                                                              Date for ELV applied
                   Technology                       Capacity
                                                               Fuel            ELV for NOx   Unit of ELV           New         Old
                                                    (MWth)
… France (cont.)
*) for CHP         All working less than 500 h/a,              Domestic fuel                 mg/Nm³ (at 15 % O2)              Defined at the
                                                    20-100                     1805/1834*
                   new authorized after 4.12.00                                                                               local level
*) for CHP         All working more than 500 h/a,              Domestic fuel                 mg/Nm³ (at 15 % O2)              Defined at the
                                                    >100                       722/733*
                   new authorized after 4.12.00                                                                               local level
*) for CHP         All existing working less than              Residual fuel
                                                                                             mg/Nm³ (at 15 % O2)              Defined at the
                   500 h/a, new authorized be-      20-100                     1805/1834*
                                                                                                                              local level
                   fore 4.12.00
*) for CHP         All existing working more than              Residual fuel
                                                                                             mg/Nm³ (at 15 % O2)              Defined at the
                   500 h/a, new authorized be-      20-100                     722/733*
                                                                                                                              local level
                   fore 4.12.00
*) for CHP         All existing working less than              Residual fuel                 5 mg/Nm³ (at 15 %                Defined at the
                   500 h/a, new authorized be-      >100                       1805/1834*    O2)                              local level
                   fore 4.12.00
*) for CHP         All existing working more than              Residual fuel
                                                                                             mg/Nm³ (at 15 % O2)              Defined at the
                   500 h/a, new authorized before   >100                       722/733*
                                                                                                                              local level
                   4.12.00
*) for CHP                                                     NG                                                             Defined at the
                   All existing working less than
                                                                                             mg/Nm³ (at 15 % O2)              local level but
                   500 h/a, new authorized before 20-100                       333/361*
                                                                                                                              not later than
                   4.12.00
                                                                                                                              2005
*) for CHP                                                     NG                                                             Defined at the
                   All existing working less than
                                                                                                                              local level but
                   500 h/a, dual fuel, new author- 20-100                      950/979*      mg/Nm³ (at 15 % O2)
                                                                                                                              not later than
                   ized before 4.12.00
                                                                                                                              2005




                                                                                                                                                20
Country                                                                                                                Date for ELV applied
                   Technology                        Capacity
                                                                Fuel          ELV for NOx      Unit of ELV           New   Old
                                                     (MWth)
… France (cont.)
*) for CHP         All existing working more than               NG                                                         Defined at the local
                   500 h/a, new authorized before    20-100                   133/144*         mg/Nm³ (at 15 % O2)         level but not later
                   4.12.00                                                                                                 than 2005
*) for CHP         All existing working more than               NG                                                         Defined at the local
                   500 h/a, dual fuel, new author-   20-100                   380/391*         mg/Nm³ (at 15 % O2)         level but not later
                   ized before 4.12.00                                                                                     than 2005
*) for CHP         All existing working less than               NG                                                         Defined at the local
                   500 h/a, new authorized before    >100                     238/266*         mg/Nm³ (at 15 % O2)         level but not later
                   4.12.00                                                                                                 than 2005
*) for CHP         All existing working less than               NG                                                         Defined at the local
                   500 h/a, dual fuel, new author-   >100                     713/741*         mg/Nm³ (at 15 % O2)         level but not later
                   ized before 4.12.00                                                                                     than 2005
*) for CHP         All existing working more than               NG                                                         Defined at the local
                   500 h/a, new authorized before    >100                     95/106*          mg/Nm³ (at 15 % O2)         level but not later
                   4.12.00                                                                                                 than 2005
*) for CHP         All existing working more than               NG                                                         Defined at the local
                   500 h/a, dual fuel, new author-   >100                     285/296*         mg/Nm³ (at 15 % O2)         level but not later
                   ized before 4.12.00                                                                                     than 2005
*) for CHP                                                      Other gases                                                Defined at the local
                   All existing new authorized                                Defined at the   mg/Nm³ (at 15 % O2)
                                                     >20                                                                   level but not later
                   before 4.12.00                                             local level
                                                                                                                           than 2005




                                                                                                                                                  21
Country                                                                                                                                     Date for ELV applied
          Technology                               Capacity                                        ELV for
                                                               Fuel                                                Unit of ELV          New           Old
                                                   (MWth)                                          NOx
Germany
          compression ignition engines and spark                                                                   mg/Nm3 at 15% O2
                                                     1 MWth    liquid fuels                                  110                       24 July 2002 24 July 2002
          ignition engines
                                                               gaseous fuels except biogas, sew-                   mg/Nm3 at 15% O2
          spark ignition engines                     1                                                       110                       24 July 2002 24 July 2002
                                                               age gas, mine gas
          spark ignition engines                     3 MWth    biogas, sewage gas                            240 mg/Nm3 at 15% O2      24 July 2002 24 July 2002
                                                   1-<3 MWth   biogas, sewage gas                            375 mg/Nm3 at 15% O2      24 July 2002 24 July 2002
          jet ignition engines and Otto engines      1MWth     natural gas                                   110 mg/Nm3 at 15% O2      24 July 2002 24 July 2002
          spark ignition engines                   >1 MWth     mine gas                                      240 mg/Nm3 at 15% O2      24 July 2002 24 July 2002
          pilot injection engines                    3 MWth    biogas, sewage gas                            240 mg/Nm3 at 15% O2      24 July 2002 24 July 2002
          pilot injection engines                  1-<3 MWth   biogas, sewage gas                            750 mg/Nm3 at 15% O2      24 July 2002 24 July 2002

Country                                                                                                                               Date for ELV applied
          Technology                               Capacity                                        ELV for
                                                               Fuel                                                Unit of ELV New       Old
                                                   (MWth)                                          NOx

HUNGARY
          Four-stroke                              All         Natural gas                         187             mg/Nm3 at 15% O2     01.01.2007 01.01.2007
          Two-stroke                               All         Natural gas                         300             mg/Nm3 at 15% O2     01.01.2007 01.01.2007
          Four-stroke                              All         petrol                              187             mg/Nm3 at 15% O2     01.01.2007 01.01.2007
          Two-stroke                               All         Petrol                              300             mg/Nm3 at 15% O2     01.01.2007 01.01.2007
          Diesel engine                            >5          Diesel oil                          749             mg/Nm3 at 15% O2     01.01.2007 01.01.2007
          Diesel engine                            3-5         Diesel oil                          749             mg/Nm3 at 15% O2     01.01.2007 01.01.2007
          Diesel engine                            <3          Diesel oil                          749             mg/Nm3 at 15% O2     01.01.2007 01.01.2007




                                                                                                                                                                   22
Country                                                                                                                   Date for ELV applied
             Technology                   Capacity
                                                     Fuel                ELV for NOx                Unit of ELV        New         Old
                                          (MWth)

THE NETHERLANDS
             Lean-burn + SCR              All        Gas&biogas          36                         mg/Nm3 at 15% O2   1.1.2009    1.1.2015

             SCR and high efficient SCR   All        Oil%bio-oil (new)   150 (2009) ->46 (2015)     mg/Nm3 at 15% O2   1.1.2009    1.1.2015

             SCR and high efficient SCR   All        Oil%bio-oil (old)   462                        mg/Nm3 at 15% O2   1.1.2009    1.1.2015

             All                           50 kWe    Gas&biogas          None                       mg/Nm3 at 15% O2               1.8.1990
                                                                         946 (local gov. may set    mg/Nm3 at 15% O2               1.8.1990
             Motor management              50 kWe    Gas&biogas
                                                                         lower level 319)
             Motor management             >50 kWe    Gas&biogas          591                        mg/Nm3 at 15% O2               29.5.1987
                                                                                                    mg/Nm3 at 15% O2               1.8.1990 (time
                                                                         946 (local gov. may set
             Motor management             >50 kWe    Gas&biogas                                                                    range intil
                                                                         lower level 319)
                                                                                                                                   1.1.1994)
                                                                         319 (local gov. may set    mg/Nm3 at 15% O2               1.1.1994
             Motor management, lean burn >50 kWe     Gas&biogas
                                                                         lower level 118)
                                                                         166 (local gov. may set    mg/Nm3 at 15% O2               1.1.1994
             Lean burn                    >50 kWe    Gas&biogas                                                        1.1.1994
                                                                         lower level 118)
             all                          all        Oil&bio-oil         none                       mg/Nm3 at 15% O2               1.8.1990
                                                                         1386 (local gov. may set   mg/Nm3 at 15% O2               1.8.1990
             all                           50 kWe    Oil&bio-oil
                                                                         lower level 462)
                                                                         462 (local gov. may set    mg/Nm3 at 15% O2               1.8.1990
             SCR                          >50 kWe    Oil&bio-oil                                                       1.8.1990
                                                                         lower level 173)




                                                                                                                                                    23
Country                                                                                                           Date for ELV applied
                        Technology                      Capacity
                                                                   Fuel        ELV for NOx   Unit of ELV        New         Old
                                                        (MWth)

UK
                        CI                              20-50      GO          1300          mg/Nm3 at 15% O2              01.04.1998
                        ELVs relaxed for engines with
                                                                   HFO         1100          mg/Nm3 at 15% O2              01.04.1998
                        ISO net base efficiency >40%
                                                                   Gas (dual
                                                                               500           mg/Nm3 at 15% O2              01.04.1998
                                                                   fuel)
          IPPC >50 MW CI                                > 50       Liquid      150
                                                        > 50       Gas (dual
          IPPC > 50 MW CI (SCR)                                                100
                                                                   fuel)
                                                        > 50       Gas (dual
          IPPC > 50 MW CI (lean burn)                                          150
                                                                   fuel)
          IPPC > 50 MW SI (SCR)                         > 50       Gas         94
          IPPC > 50 MW SI (lean burn)                   > 50       Gas         94
          IPPC > 50 MW SI (lean burn) pre-2005          > 50       Gas         188           na




                                                                                                                                         24
 3.2 Applicable NOx reduction
    measures and achievable emis-
    sions

According to industry experts (EUROMOT,
….), it seems that for gas engines fired
with natural gas it is possible to reach NOx
emission limit values presented in the
German TA Luft (90-190 mg/nm3 at 15%
O2 ) without installing SCR, but it is very
expensive to go further. Achievable NOx
concentrations for diesel engines without
secondary measures are around 1000
ppm = 2000 mg/nm3 in 15 O2%. The cur-
rent target in the development of diesel
engines is around 750 ppm = 1500
mg/nm3 in 15 O2%.

Further reduction of NOx emissions from
90-190 mg/nm3 at 15% O2 requires instal-
lation of selective catalytic reduction
(SCR) as a secondary abatement meas-
ure for the following engine types: gas
engines, diesel engines (fired with heavy
fuel oil) and liquid fired dual fuel engines.

Details in technical challenges for reduc-
tion of NOx emissions as well as specific
engine type related challenges are dis-
cussed below.

An overview of applied capacities and
specific emissions is provided in Annex ?.




                                                25
 3.3      Contribution of stationary                       COUNTRY             Energy     Industry  Offices/        Sport/ Recrea- Ag
       engines of total NOx emissions                                          production           Residential tion/ culture         (g
                                                                                                        Share (%) of installed capacity
                                                           Belgium                49.2      19.1         0.5               0.7
In 2000, the contribution of stationary en-
                                                                                       NOx emissions from stationary engines divided by
gine plants for NOx emissions in the EU-15
                                                           Finland                16.6      75.0
was about 0.26% according to the Euro-
                                                           UK*                    5.5                                          86.5
pean Environment Agency (EEA, 2002).

Information collected from the replies sent
by countries to the questionnaire on sta-                  *UK: share of the number of engine units out of the number all
tionary engines, show that the share of                    combustion units was 16.5% (where the share of units <3 MWth
NOx emissions from stationary engines in                   was 16.5%, 3-15 MWth 17.1% and units >15 MWth was 4.2%)
2006 varied between 0,1% and 4.6% of
national total NOx emissions, being in Bel-
gium (Flanders) 2.5%, Finland < 0.1%,
Hungary 1%, the Netherlands 4.6% and
the UK 1.9%. According to information
reported by countries, installation of sta-
tionary engines has country specific di-
mensions regarding the fuels used and
sectors where the engines are applied (by
fuel Table 4 and by sector in Table 5).

In some countries the share of stationary
engines has an increasing trend (e.g. in
Belgium and the Netherlands) due to in-
stallation of new units. This development
is due to national programmes that focus
on abating greenhouse gas emissions.

Also, according to the industry, the sales
of stationary engines is rapidly growing.
For instance, the market for 1-3 MW gas
engines grows annually by approximately
7% worldwide. An overview of installed
engine types and manufacturers is pro-
vided in Annex ?.


A summary of information collected from
the countries is presented in Annex 2.



 Table 4. Shares by fuel of the total in-
stalled capacity of stationary engines in
some countries in 2006
Country               Share (%) of total installed capacity by fuel                                      Year
                      NG            Diesel          Biogas          HFO               LFO
Belgium Flanders      37.0          57.3            5.7                                                  2006
Finland               59.3                          17.8            15.7              7.2



Table 5. Share of stationary engines by
sector in some countries in 2006
Source sector NFR1A      NFR2       NFR1A4        NFR1A4             NFR 1A4           NFR 1A4          NFR6

                                                                                                                     26
3.4 Technical questions (TO BE                  on biogases, the impurities of the biogas
COMPLETED BY EUROMOT)                           might create deposits on the engine inter-
                                                nal components and will thus put restric-
There are technical concerns for adoption       tions on the achievable NOx level.
of the current NOx emission limit values for
new stationary engines in Table IV of An-
nex V in the Gothenburg Protocol.

The main concerns are:

A. The stipulated limits are not according
to the trend to improve engine efficiency
and usage of renewable energy in the
spirit of the Kyoto Protocol.

B. The stipulated limits are beyond the
BAT (Best Available Technique) approach.

C.     There   are    technical  difficul-
ties/challenges to meet the stipulated
emission limit values for new stationary
engines

                                                 Figure 4A. Balance between NOx and
3.4.1 Interdependence between emis-              carbon emissions from stationary en-
sions                                                    gines (source MTU)

4-stroke lean burn gas engine types

The spark, or by some other design, ig-
nited lean burn gas engine is a “pure gas”
engine, it operates on low pressure natural
gas and (depending on engine type) also
on biogases such as landfill, digester,
mine gases, etc. The dual fuel engine is
designed to operate in gas mode with low
pressure natural gas as the main fuel.

Engine optimization is a compromise be-
tween NOx emissions, engine efficiency
(fuel consumption and thus CO2 emission)
and other emissions (such as CO, HC). In
Figure 4A below, relations between NOx-
emissions, total hydrocarbon and carbon         Figure 4B. Relation between NOx, total
monoxide emissions are shown.             As    hydrocarbon and carbon monoxide
shown in Figures 4B and 5, a reduction in       emissions in lean burn engines (source
NOx emissions will increase CO2 emis-           GE Jenbacher)
sions (fuel consumption) as well as "un-
burned" emissions such as CO, HC, and
may also finally lead to misfiring, which
might eventually destroy the engine. From
Figure 4B it can be seen that the NOx re-
duction will impact on the air-fuel ratio, at
the lower NOx levels the engine will oper-
ate in a leaner mode (higher flue gas flow)
and the temperature of the flue gas de-
creases as a consequence. In operation

                                                                                       27
                                                  “Miller concept” (early closing timing of the
                                                  air inlet valves) is used, which suppresses
                                                  the in-cylinder temperatures reducing NOx
                                                  formation) and advanced fuel injection
                                                  equipment.




Figure 5. Impact of NOx emissions on
efficiency and carbon dioxide emis-
sions (source GE Jenbacher)


Diesel engines

For diesel engines, fuel quality has a cen-
tral role on the emissions. The quality of
fuels, e.g. the sulphur content, is largely        Figure 6. Worldwide HFO (Heavy Fuel
alternating (typically 0.5 .. 4 wt-% S, see          Oil) sulphur levels (source MAN)
Figure 6) around the world. Bigger me-
dium (up to about 20 MWe unit size) and
slow-speed engine types (up to about 80           A specific problem for diesel engines is
MWe unit size) are usually operating on           that if your want to decrease particulate
more economical fuel oils such as heavy           unburned (such as CO, HC) and CO2 (fuel
fuel oils, fuel emulsions, refinery vacuum        efficiency) emissions, NOx emissions will
residuals and small high speed engines            increase as shown in Figure 7.
(up to about 3.5 MWe unit size) on distil-
late oils (low sulphur diesel and ultra low
sulphur diesel). Some diesel engine types
can also operate on natural gas and bio-
oils. Medium and slow speed engines are
used in e.g. base load, decentralized
small/medium sized heat and power
(CHP), gas compression and crude oil
pumping and grid peaking plant applica-
tions. High speed engines are mainly
used for stand-by, peak looping short term
capacity applications (< 2 years) and
sometimes also as base load applications
in small remote communities.

The fuel quality will set limits for the avail-
able primary NOx abatement methods. In
small high speed applications e.g. EGR
(Exhaust Gas Recirculation) and high
pressure, electronically controlled injection
can be used and lower NOx levels
achieved compared to the bigger engine
types. In bigger modern engine types the

                                                                                            28
 Figure 7. Typical emission trends as a
  function of efficiency (source CAT)


More details about the achievable NOx
rates for the different engine types are
provided in the chapters below.


3.4.2 Restrictions related to the current
technological solutions


Gas engines

For some bigger lean-burn "pure" gas en-
gines (such as by spark plug or by some
other ignition device) operating on natural
gas it is possible to reach NOx emission
levels presented in the German TA Luft
(90-190 mg/nm3 at 15% O2 = 250 – 500
mg/nm3 at 5% O2) without installing SCR.
In the text above it has been shown that          Figure 8. Deposits in a bio gas fired
by decreasing NOx emissions other emis-              engine (source GE Jenbacher).
sions such as CO, HC and CO2 (and thus
also fuel consumption) will increase. The       For a dual fuel engine in gas mode (natu-
lean-burn engine will also operate in a         ral gas main fuel, pilot liquid fuel typically
leaner mode at lower set NOx levels and         1-2 % of the total heat rate) 400 mg NOx
thus the flue gas temperature gets colder       /nm3 at 15% O2 (~1000 mg/Nm3 at 5% O2)
and as a consequence the useful heat            and with an increased fuel heat rate 200
energy in the flue gas decreases (detri-        mg NOx /nm3 at 15% O2 (~500 mg/Nm3 at
mental for e.g. steam production in a CHP       5% O2) are reached without installing
plant). Due to deposits formed inside the       SCR. The dual fuel engine operates on
combustion chamber of biogas (landfill          natural gas.
gas, anaerobic fermenter gases) fired en-
gines, NOx levels far below 190 mg/Nm3 at       For lower NOx levels than shown above
15% O2 can not be achieved over the op-         SCR is to be used. SCR has a high in-
eration life of the engine because of a drift   vestment cost and needs a reagent such
of the emissions caused by isolation ef-        as aqueous urea or urea to function.
fects and change in combustion chamber          Skilled operators are also needed in the
geometry (Figure 8).                            plant. One concern is also that the re-
                                                quired maintenance is not always avail-
                                                able, especially at remote sites where
                                                these engines are often operated.

                                                If other gaseous fuels (such as biogases)
                                                are to be used , the trace elements (such
                                                as volatile organic silica compounds (si-
                                                loxanes, silanes, etc) which might be pre-
                                                sent would deactivate (“poison”) the SCR
                                                catalyst.


                                                Diesel engines and dual fuel engines

                                                Achievable NOx concentrations for bigger
                                                diesel engines applying primary emission

                                                                                           29
reduction measures are today around
1000 ppm = 2000 mg/nm3 at 15% O2. The                              For diesel engines and liquid fired dual
current target set by engine manufacturers                         fuel engines it is necessary to use SCR as
in development of diesel engines is (de-                           a secondary measure to reach the emis-
pendent on engine type) around 710 - 900                           sion limit values given in the Gothenburg
ppm = 1460- 1850 mg/nm3 at 15 O2%.                                 Protocol. According to the EU BREF
This means that it is possible to reduce                           Document /2/ following items are to be
NOx emissions from diesel engines by                               considered when applying SCR in a recip-
primary measures with about up to 10-                              rocating engine plant:
15% for 2-stroke engines and 20-25% for
4-stroke engines. In the future (by year                              -   A certain minimum flue-gas tem-
2016) with an increased “extreme” Miller                                  perature (dependent on the fuel
concept a NOx reduction up to 40 % from                                   sulphur content) is to be main-
todays´ levels is forecasted. Further re-                                 tained in order to avoid salt forma-
ductions in NOx emissions (for big en-                                    tion on the elements. Some “trace
gines) can be achieved by “water addition                                 metals” (for instance Na, K, Ca,
methods” from todays´ levels: such as                                     Mg, As, Se, P) might act as “cata-
typically 15-25% with fuel water emulsion,                                lyst poisons”. A soot blowing sys-
40-60% with air humidification1 and sec-                                  tem is to be installed into the SCR-
ondary measures namely SCR up to 80-                                      reactor in order to secure proper
85%. Specific “water addition” methods                                    cleaning of the elements. (Figure
available and reduction capacities depend                                 9)
on engine brands, these methods require                               -   Infrastructure for reagent supply is
a huge volume of pure water which is to                                   to exist (ammonia or good quality
be available. “Water addition” methods                                    urea).
are therefore used mainly in shipping in-                             -   SCR has high investment and op-
stallations where the engine operating                                    erating costs. Used catalytic ele-
conditions are different from a stationary                                ments need to be properly dis-
engine plant.                                                             posed off.
                                                                      -   Regular maintenance is recom-
The high speed category is often based on                                 mended in order to prevent high
automotive or off-highway equipment en-                                   ammonia slip, which might deposit
gines running on smaller rpm:s (revolu-                                   on internal surfaces of boilers, etc.
tions per minute) leading and with different
NOx emissions as a consequence. “Best
in cylinder” achievable NOx level is about
750 mg/nm3 in 15 O2%. (~2000 mg/nm3 in
5 O2%) (for a on-highway derived engine),
with use of ultra low sulphur diesel oil.

The dual fuel engine can also operate at
full engine output in liquid mode. Due to
the optimization for two fuel modes it has a
lower compression ratio than a normal
diesel engine. In liquid fuel mode the en-
gine is operating according to the diesel
principle but has higher emissions than a
normal diesel engine.

1
   Other possibilities to reduce emissions are the LEE concept,
i.e. tuning the engine by diesel compression or doing more
Miller cycles. In the LEE concept increasing load is risky and
requires further development of engine technology, which is not
available for efficient power production today. The Miller cycle     Figure 9. SCR deterioration factors
is more suitable for larger engines with lower speeds but not                 (source Wärtsilä).
appropriate for highly transient operation (long expansion
stroke, take a lot of energy out of exhaust).


                                                                                                            30
A limitation for the applicability of SCR is
given for units operated with often varying
loads (the catalyst temperature will fluctu-
ate frequently and be outside the effective
temperature window) and no general NOx-
BAT span-value is therefore given /2/.
Therefore SCR cannot not always in prac-
tice be considered as BAT .

Some general SCR (Selective Catalytic
Reaction) aspects

Generally, the reduction reagents used in
the SCR systems are an aqueous NH3
solution of about 25 wt-% or 40 wt-% urea
water solution (Figure 10). In some instal-
lations pure ammonia (100 %) is used.
When NOx reduction rate is up to about 85
- 90 %, the SCR system can be controlled
by a simple control system, with higher
NOx reduction rates complicated reagent
premixing and injection systems and a
more controlled advanced control system
are needed /2/.                                 Figure 10. Typical SCR configuration
                                                         (source Wärtsilä).
As above stated, a sufficiently high flue
gas temperature is needed in order to
avoid salt formation (ammonium sulphate        Flue gas temperatures from bigger en-
condensation) on the catalyst elements in      gines burning heavy fuel oil is to be kept at
the SCR reactor and as a consequence           an appropriate level in order to avoid hot
clogging of the SCR reactor (Figures 11).      corrosion in the affected engine compo-
The minimum flue gas temperature is de-        nents, the set efficiency target of the en-
pendent on the fuel sulphur content. Fuel      gine will also have an impact. As a result
qualities around the world in many regions     in many cases the flue gas temperature
are relative high (Figure 6). Fuels with 1     will not be high enough in all engine load-
wt-% sulphur content or lower are used         ing points, especially when burning high
e.g. in Western Europe (EU area) and in        sulphur fuel oils. In many parts around the
the US. For instance in Belarus and in the     world the only commercially available fuel
more eastern regions, the sulphur content      oils are of high sulphur content and the
can often be up to 3.5 wt-%. Even some         price makes it impossible for many coun-
distillate diesel fuels may contain up to 2%   tries outside the European Union to import
of sulphur. In the EU the sulphur content in   low-sulphur fuels.
HFO fuels, which can be used without any
emission abatement, is restricted to maxi-
mum 1 wt-% S and for light fuel oil to
maximum 0.1 wt-% S /3/.




                                                                                         31
   Figure 11. Clogged SCR elements                                                         Installed Cost Costs
                                                                                                      O&M
           (source Wärtsilä)
                                                                                      7 MW Engine          17 MW Engine
                                                                                               Urea (solution)          Ammonia
2. Installation and operation costs                         50
                                                                                  8
                                                            40
                                                                     Euro / MWh
                                               Euro / kWe




                                                                                  6
SCR has a high initial purchase price. The                  30
                                                                                  4
catalytic elements in the reactor need to                   20
                                                                                  2
be replaced with a certain frequency (de-                   10
                                                                                  0
pendent on the used fuel quality). In addi-                  0
                                                                                      20        40            60        80         100
tion, SCR requires good technical support                        0                    20       40        60        80        100
                                                                                                    NOx abatement [ % ]
including spare parts and expertise to op-                                                 NOx abatement [ % ]
erate and maintain. A proper disposal of
used catalyst is also to be arranged.
                                              Figure 12. Typical SCR costs as func-
Typical SCR costs as function of NOx re-            tion of NOx reduction rate
duction rate with the related assumptions
are presented in Figure 12. Note that the
availability of reagent might vary from lo-
cation to location and prices may vary
greatly.




                                                                                                                          32
4             Views of Parties and Industry


4.1 Country-specific concerns

Belgium

In Belgium there is a national ceiling for NOx, which is split into 4 parts: a ceiling for stationary
sources for each of the three regions (Flanders, Walloon and Brussels) and one ceiling for
the transport sector on the federal level. Therefore, in Belgium, the contribution of stationary
engines to the NOx emissions is more relevant at the regional level than at the national level.

For instance, the NOx ceiling for stationary sources in Flanders from 2010 is 58.3 kilotonnes,
while the current NOx emissions of stationary engines in Flanders are estimated to be about
4.5 kilotonnes. The emissions of stationary engines are estimated to increase due to invest-
ments especially in CHP engines (including biogas/biofuel fed engines) and in large diesel
engine plants. This development is mainly due to pressure of the climate policy as subsidies
are given to renewable energy and CHPs.

The Netherlands

In the Netherlands both the population density and air pollution are high. The national legisla-
tion (BEES B) concerns stationary engines and gas turbines (1-50MW) as well as boilers
(0.9-50 MW). There is also a national NOx trading scheme. Update of BEES B will bring
emissions back to BAT level, i.e. the same emission limit values for all combustion plants
and CHP installations. Implementation is scheduled for new installations from 1st January
2009, existing installations from 1st January 2015 restricting emissions of NOx, SO2, PMs and
VOCs. This means also changes to the present ELVs for new installations.

Currently, there are not many diesel engines installed in the NLs. The new legislation will
include all stationary engines and all fuels but only expressed with one NOx limit value. The
new limits will include also methane slips from gas engines (methane is a greenhouse gas).
The limit will be 2,3% for gas engines. It has not been decided whether the reference oxygen
content for the ELVs will be 5 or 15%. All gas engines must be equipped with SCR and will
have low VOC emissions including methane slip. Desulphurisation of biogas is required. All
diesel engines should be equipped with highly efficient SCR, which means at least 90% of
NOx removal (also for bio fuel). The reduction costs are updated in the BEES B, 4 to 5 €/kg
NOx. The solution to reduce emissions is considered to be a combination of techniques.

Greece

Greece is the biggest user of large stationary 4-stroke and 2-stroke stationary engines in
Europe. These engines are used on the Greek islands. The main issue beside the NOx emis-
sions is the engine efficiency of the units (CO2 emissions, fuel consumption) and the reliabil-
ity of the engine, which is very important for people living on the Greek islands.

 The engines on the Greek islands are operated with heavy fuel oil, which makes the applica-
tion of some primary techniques for NOx reduction difficult. Also the use of SCR is thus a
problem (catalyst poisoning, temperature fluctuation etc.) as well as the costs. Furthermore,
application of urea in emission removal is difficult to develop on the Greek islands. Industry
views




                                                                                                  33
4.2 Concerns of industry


According to the engine industry the NOx emission limit values presented in the UNECE
Gothenburgh Protocol are too low and do not represent BAT nor IPPC principles due to the
following reasons:

   -   The emission limit values for HFO fired diesel engines (> 5 MWth) and spark ignited
       lean burn gas engines (> 1 MWth) seem to be similar to the French Arrete Ministeriel
       2010 limits for very big > 100 MWth reciprocating engine plants. Smaller plants
       should have leaner limits. In the EU the big plant “threshold” is usually set at 50 MWth
       which is not the case for stationary engines in the Gothenburg Protocol.

   -   In the EU BREF document (for plants > 50 MWth) it is stated that SCR is not BAT for
       all diesel engine applications.

   -   Most bigger spark-ignited lean burn engines can by engine tuning reach the pre-
       scribed NOx value. However, the fuel consumption will increase (and as a conse-
       quence the CO2 emissions while the engine efficiency drops), total CHP efficiency will
       decrease (colder flue gas temperature) and unburned emissions such as CO, HC will
       increase. Biogas fired engines should not due to fouling problems be tuned to the
       prescribed NOx level.
       Thus the NOx emission limit value is not according to the Kyoto Protocol spirit nor to
       the IPPC principle (focussing on only one emission component and disregarding the
       negative impacts).!

According to the engine industry there is a big need to revise the NOx emission limit values in
the UNECE Gothenburgh Protocol for new stationary engines. The NOx emission limit val-
ues should be technically feasible, cost-effective (BAT) and represent IPPC. The dual fuel
engine type should have own specific NOx ELVs beside the diesel and spark ignited lean
burn engines.




                                                                                            34
5 Options for revision of the current ELVs


5.1 Possible approaches to revise NOx ELVs


1) Keep the scope the same- cover only new stationary engines

2) ELVs for diesel engines

a) to be left outside or b) be the same as in the current Table 4 of the Gothenburg Protocol,
or c) to be updated

Diesel engines: NOx limit values according to the World Bank Guidelines

Dual fuel engines fired with NG: NOx limit values between 200-400 nm/Nm3 at 15% O2 ( 200
mg/nm3 is possible with increased fuel consumption and increase in CO2 emissions)

Issues for fuels:
• Different fuels by S-content in different regions…..
• Availability of fuel….
• For engines fired with heavy fuel oil, impurities in the flue gases create fouling that deac-
    tivates the SCR unit.

Concerns identified by the industry:

• To define use of biogas.
• To consider impacts if NOx limit values for renewable gases are introduced. Fluctuations of
  gas composition and contaminations need to be considered when defining NNG (Non
  Natural Gas) NOx limits
• to introduce NOx limit values for biogas in the revised Gothenburg Protocol.
• engines fired with renewable energy sources are not covered by the Gothenburg Protocol


3) ELVs for gas fired engines to be updated


4) Consistent plant size

Consider changing the plant size to the same as for other combustion plants       50 MW and
delete he other stationary engines from the scope


5) Reference oxygen content

Consider changing the reference oxygen content from 5 % to 15 %

6) Capacity

Divide ELVs to different size categories according to the size of the engine plant e.g. (en-
gines are summed up or aggregated to define plant size)
> 50 MW th
20 – 50 MW th
5 -20 MW th
3 - 5 MW th


                                                                                            35
7) Region & local air quality

Divide ELVs according to a) rural area or b) to special area

          •      more flexibility for the whole UNECE region by general strict ELV’s, but allowing
                 derogations for certain cases (f.e. diesel engines with frequent load variation);

          •      flexibility for different regions depending on ….
                 availability of fuel, local conditions, availability of technology, air quality conditions,
                 possibilities for abatement/maintenance…..

PROPOSAL: Revise Table IV NOx ELVs to include ELVs for diesel engines and spark ignited
engines giving different values for special and rural areas.

    Technology                                                         NOx mg/m3 (all in 15% O2)

                                                                       Special area(e.g. city)     Rural
    Liquid fired diesel engine > 400 mm bore                                    750                1600
    Liquid fired diesel engine 400 mm bore                                      750                1850
    Spark ignited 4-strpke gas engine
                                        High pressure Gas (diesel)              190                190
                                       Dual fuel engine (gas mode)              750                1600
                                      Dual fuel engine (liquid mode)            400                400




8) Different timescales

Apply ELVs in different timescales a) for EU, b) for UNECE Europe, USA, c) for other regions
of UNECE (EACCA; Russia, Belarus..)



5.2 Guide values/ ELVs / BAT

-    indicative in stead of mandatory ELV's;
-    application of product (emission) standards (to be guaranteed by manufacturers) coupled
     to good maintenance procedures instead of imposing emission limit values
-    transition periods;
-    application of BAT in stead of ELV's (with indication of specific BAT which can be ap-
     plied);
-    .....
-    less strict ELV’s on a hourly basis, but maintain values on f.e. a daily basis;



5.3 Keep current ELV's, still allowing the use of equivalent reduction strategies
                                        -     ….

5.4 Correct the miscopying of TA Luft values for gas engines

The NOx emission limit values in Table 4 of Annex V of the Gothenburg protocol, given for
gas engines, seem to be in opposite order than in the German TA-Luft, where they are 500
mg/Nm3 for lean burn gas engines and 250 mg/Nm3 for all other gas engines in 5% oxygen
content (see Table 1).



                                                                                                           36
6 Impact of the proposed options

Impact of proposals on NOX emissions: rough estimates: for proposals softening the current
NOX emission limit values, the impact on NOX emissions should be examined….




                                                                                         37
7 Conclusions/recommendations…




                                 38
REFERENCES



/1/ “Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution to Abate
Acidification, Eutrohication and Ground Level Ozone”, Euromot April 2003, available at:
http://www.euromot.org/download/news/positions/stationary_engines/UNECE_CLRTAP_AB
C_Analysis_080403.pdf

/2/ Integrated Pollution Prevention and Control (IPPC) Reference Document on Best Avail-
able Techniques for large Combustion Plants , July 2006, available at
http://www.jrc.es/pub/english.cgi/d1254325/19%20Reference%20Document%20on%20Best
%20Available%20Techniques%20for%20Large%20Combustion%20Plants%20%28adopted
%20July%202006%29%20-%2022%20Mb

/3/ EU Fuel Directive 1999/32/EC

/4/ Position Paper of the CIMAC WG5 Exhaust Gas Emissions Controls on “Prime
Mover Technique Specific Emission Limits Need Stationary Reciprocating Engine
Plant”, at http://www.cimac.com/workinggroups/Index1-working-groups-
exhaustemission.htm

/5/ EUROMOT Position Paper…




                                                                                       39
Annex 1
(copy of the questionnaire)




Annex 2 Summary on replies received to the questionnaire on sta-
tionary engines

- until now only the summary for NOx ELVs has been finished (see Table 3)




                                                                            40

				
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