PECM Issue 34 2018 | Page 76

BOILERS LOOKING AT THE MCPD

FULTON

IN THIS ARTICLE , CARL KNIGHT , MANAGING DIRECTOR OF HEAT TRANSFER SPECIALIST FULTON , LOOKS AT THE MEDIUM COMBUSTION PLANT DIRECTIVE ( MCPD )

The list of applications for high quality , dry steam is almost endless . However , while many steam boilers are extremely robust , they are based on old or ageing technology and often inefficient . As a result , and in an effort to make them more efficient , many manufacturers have simply fitted modulating burners and bolt on economisers in an attempt to improve both steam output and efficiency . But for how long can boiler manufacturers simply keep reinventing the wheel when new legislation is knocking on the door and only likely to become more stringent over time ?

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

Seen as a significant source of air pollution , medium combustion plant such as gas- and oil-fired steam boilers are not currently regulated in the UK ; and the government ’ s main aim for action on air quality is the impact it can have on both people ’ s health and the wider environment , because a cleaner and healthier environment benefits individuals and the economy .

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

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An estimated 15,000 to 30,000 manufacturing sites and public , private and government estates in the UK will eventually need to comply with the MCPD legislation ; with emission limit values ( ELVs ) being less onerous for existing plant and depending on their input rating and fuel used .

However , if manufacturers install new plant before 20th December 2018 , life within the requirements of the MCDP will be less of a burden and less expensive because new plant commissioned before this date will not be aggregated .

This is all quite transparent if you ’ re installing new plant , but what if you want to upgrade existing plant ?

At the moment , this hasn ’ t been clearly defined , but the Environment Agency in England is set to publish further guidance over the summer , with Natural Resources Wales , the Northern Ireland Environment Agency and Scottish Environmental Protection Agency undoubtedly following suit very quickly afterwards . What is quite certain is that the Environment Agency ’ s costs for administrating the MCPD will no doubt come via fees for registration , testing , etc . from the main polluters .

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

At Fulton , rather than further-improve products like the J Series to achieve these goals ; and realising the implications the MCPD will have on its fuel-fired steam boiler portfolio , we have gone back to the drawing board and , by adopting a new ‘ PURE Technology ’ initiative , the VSRT – the world ’ s first Vertical Spiral Ribbed Tubeless steam boiler – emerged and features a design that is durable and long-lasting , boasts higher efficiencies and reduces NOx emissions to levels that easily exceed the requirements of the MCPD . And while the requirements of the MCPD do not apply to some of its smaller models , Fulton ’ s new VSRT range has been designed to not only meet , but exceed the requirements set out by the new directive .

With over 15 patents pending in three continents , the VSRT ’ s spiral-rib heat exchanger is a world first . NOx emissions for the new boiler are an ultra-low 20ppm , which means they will not only meet the 100mg / m3 NOx requirement of the MCPD , but the full range will also meet the planning requirement for new commercial developments from the City of London 2015-2020 air quality strategy , which states outputs of less than 40mgNOx / kWh .

For additional information about Fulton , please visit www . fulton . co . uk