Report Chapter.Dot s1

Appendix B1 – Page 1

European Commission: IPPC Implementation Case Study Assessment Report

Case Study Reference: 02/EL/12 Member State: Greece Sector: Large Combustion Plant

Table A.1 Assessment of procedures and conditions set within the IPPC permit

Introduction Overview description of The installation is a lignite-fired power station with 5 large combustion plant (LCP) units type of installation / and a total installed capacity (input) of 1595 MWth. The plant has been operational since application 1984. The first two units (I and II) are type ‘Stein Alsthom Ergas’, which have been running since 1984 and are of 300MWth input capacity each. Units three and four (III and IV) are type ‘EVT TPE Ergas’, which became operational in 1985 (III) and 1986 (IV). The units are 310 MWth input capacity, each with the potential for 290 MW electrical and 70 MW thermal input. The fifth unit is type ‘Wagner Ansaldo Aegek’, operational since 1997 and with an installed capacity of 375 MW (358.5 MW electrical plus 70 MW thermal).

The annual generation of the station is 11,500,000 MWh, which covers approximately 20-25% of the national Greek electricity consumption.

The plant is fired on lignite, approximate consumption 1.8 tonnes/MWh or 21,000,000 tonnes per annum. The ash content is approximately 18%, water 50% and specific heat capacity 5-5.4 MJ/kg, which is one of the lowest amongst carbon-based fuels.

The station uses 27,000,000 tonnes of water per annum (~25,000,000 decarbonated and 1,500,000 demineralised), with a specific consumption of 1.3 tonnes/MWh.

The station operates a range of treatment facilities, including electrostatic precipitators and an integrated wastewater treatment works. Many of the wastes produced are recovered and/or recycled in accordance with the terms of their IPPC permit.

Type of permit / issue The IPPC permit is new, having been issued under transitional arrangements into IPPC date from a previous regulatory regime. The permit is dated 12/09/2006. Basis of BAT The competent authority has determined BAT through a combination of assessment of determination the operator’s submission of BAT (made as part of the technical reports that are required for the IPPC application) and cross-reference to BREF documents, primarily the reference document on Large Combustion Plants, the country’s split views (as included in the BREF), as well as the criteria of Article 9(4) and Annex IV of the IPPC Directive. Having assessed the operator’s BAT comparison at the meeting, there has been a significant level of consideration and input on both parties with respect to assessing and determining BAT.

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Permit application

Question (1) To what extent does the information provided by the applicant in relation to Article 6 appear to be comprehensive and accurate?

Statement on the Completeness: overall completeness The operator made two applications to cover the installation (a primary application and a and quality of supplementary application containing additional technical information). application The application contained all the key elements required by Article 6 although the competent authority noted that a formal request was made for the operator to prepare a more detailed technical report on proposed technologies for reducing or preventing emissions. Particular focus was on particulate matter emission reductions.

Supplementary information was also provided on the sulphur content of the lignite, the fuel, design information relating to the hydrogen fluoride system and water abstraction.

Quality:

The application was generally of a high standard. A brief assessment of the application showed it to be a comprehensive document; however further requests for technical information were made by the CA during the determination period.

Presence of elements Does the application include a description of the following: Yes No required by Article 6 - Installation and its activities  Applications for permits Raw and auxiliary materials, other substances & energy  Sources of emissions from the Installation 

Condition of the site 

Nature & quantities of emission sources (including identification of  significant environmental effects)

Proposed technology and other techniques for reducing or preventing  emissions from the Installation

Measures for prevention and recovery of waste 

Measures for emissions monitoring 

The main alternatives 

Non-technical summary 

Other measures to comply with Article 3 requirements 

Specific consumption and production figures, energy management, waste management and fate (disposal), water abstraction, BAT technical evaluation report.

Permit conditions and permit determination process

Question (2) Has the Competent Authority taken such steps necessary through the development of the IPPC permit to ensure that installations are operated in a manner commensurate with the requirements of Article 3 (a)-(f) of the Directive?

Assessment of the Overall statement general principles The permit as assessed is a comprehensive document containing a mixture of general governing the basic and specific conditions that meets most of the requirements set out in Article 3(a)-(f) of obligations of the Directive 2008/1/EC. The permit does not include any specific or general conditions on the minimisation of energy or the requirement to produce an energy-efficiency plan operator (Article 3 (a)- (reference to Ministerial Decree on energy efficiency), nor does it contain conditions (f)) requiring the development and submission of a site closure plan in advance of closure.

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It is clear from assessment of the permit conditions that there is a significant focus on managing the primary emissions (particulates, SO2 and NOX), water minimisation and recycling and liquid and solid waste management, including recovery. The permit contains a significant number of conditions relating to the minimisation of fugitive dust emissions as this is seen as a significant local impact issue in very dry periods.

Where the determination process has shown the installation is not currently using BAT, the permit contains specific improvement conditions that require the operator to implement BAT techniques as set out in the BREF on large combustion plant. These measures are summarised within Section A.9 of the permit.

Pollution prevention measures:

Section C of the permit contains the conditions relating to the technical works and general measures for reducing environmental pollution.

These include conditions covering the plant infrastructure, production process, compliance assurance with limits and national standards, acquisition of relevant documents and authorisations, implementation of technical measures to reduce pollution during construction and operation of the installation processes and a general requirement to maintain and operate fully effective pollution prevention measures.

The permit includes, for example, the following measures:

. Surfacing of road required for a minimum of 80% of the journey to reduce fugitive dust generation and trucks must be covered when transporting lignite. Trucks for transporting ash must be of the silo type.

. Operator must take such measures as necessary to reduce fugitive emissions of dust during the loading and unloading of lignite.

. Cleaning of the transport belts that are used for ash transport and minimisation of dust by wetting ash as necessary.

The permit also contains general pollution prevention conditions on waste conditioning, accident prevention, restriction of non-authorised discharges, no discharges made to ground or groundwater and restoration of the site following closure.

No significant pollution is caused:

The plant has workplace concentration limits set for employees based on national health legislation; however these are not sufficient to ensure adequate environmental protection in all cases. With regard to potential health impacts, dust is the key emission and therefore these limits do not cover NOx and SO2 emissions.

The installation operator has determined that the high alkalinity of the lignite fuel ensures a minimum desulphurisation of the flue gases of 70% and often as high as 90%+ without the use of Flue Gas Desulphurisation technology (FGD). This has been determined by the competent authority to represent the BAT for this installation based on the equivalent desulphurisation factors for dry sorbant injection as stated in the BREF on large combustion plant (for coal and lignite fired power stations). For NOx, the installation is required to use a number of primary measures: air staging, flue gas recirculation, low NOx burners (unit V), over fire air (unit V) and in-furnace burning.

Dust emissions have the potential to be a significant atmospheric pollutant, particularly considering the geographical proximity of other sources of dust emission (power stations). The permit therefore requires strict control and limitation of dust emissions through the use of parallel electrostatic precipitators on all units with efficiencies of a minimum of 99.5% (99.9% for unit V). Furthermore, the improvement of the existing and the addition of new electrostatic precipitators to units I, II, III & IV was imposed as a condition in the permit until 30.09.2007.

In addition to the process and abatement-based conditions, the permit also requires the operator to maintain an accident and emergency response plan to minimise the potential impact of emissions or releases during abnormal conditions. Similarly, the permit also contains a series of conditions relating to the management and control of the installation during abnormal operating conditions.

Waste avoidance, recovery and disposal:

The permit contains a number of conditions that require the operator to implement measures to minimise, recover and recycle waste. Where this is not practicable,

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conditions are in the permit to ensure disposal of the waste whilst minimising the potential impacts upon the environment.

The permit sets specific control conditions and also conditions that reference national Greek laws that implement the requirements set out in EU Directive on Waste (Directive 2006/12/EC).

The permit contains a number of operational conditions relating to waste recovery and management, which are split into liquid and solid waste, including:

. Control, treatment and recovery of liquid wastes including oily wastes;

. Control and recovery of ash wastes;

. Control, treatment, recovery and disposal of hazardous and non-hazardous wastes;

. Recycling and recovery of cooling waters.

The permit contains a significant number of conditions relating to the characterisation of wastes and monitoring of waste arisings, tonnes recovered, tonnes disposed of, etc.

Energy efficiency:

The permit does not contain specific conditions relating to energy efficiency as the operator is a member of the EU-ETS and has demonstrated significant corporate-level commitments to improving energy efficiency and reducing CO2 emissions at a group level. The permit states that the operator must ensure that they comply with the Ministerial Decree KYA/54409/2362/07 on the EU Emission Trading Scheme. An assessment of this decree has not been made.

Accident prevention:

The permit contains a number of conditions relating to accident prevention.

There are conditions relating to the prevention and minimisation of risk in storage of raw materials and products (such as high-level alarms, height detection, covered impermeable tank tops/bottoms, storage control and maintenance procedures).

The permit specifies conditions within Section C.10 relating to the management of accidents and their consequences and includes conditions relating to:

. Dealing with fault situations and maintenance/repair;

. Pro-active operational checks of abatement equipment function and performance, including checking and calibration of CEMs and analysis of trend data to check for operational issues in advance of accident/incident;

. Reporting accidents and near-misses in accordance with the regulations;

. Specifying contingency arrangements in failure of monitoring equipment or long- term operational faults (e.g. failure of ash conveyor system);

. Clarification of the legal positions with respect to liabilities from accidents;

Site closure measures:

It is not clear that there are any conditions addressing site closure although reference is made to the national requirements on site restoration and maintenance.

Question (3) Issues associated with permit determination

Was there suitable dialogue between the operator and the competent authority during the permit determination process?

There was a significant amount of dialogue between the operator and competent authority during permit determination.

Was co-ordination required between Competent Authorities and how did this process work in practice?

There was cooperation required between the competent authority for IPPC and the competent authorities for water management, solid waste and air quality. No issues in

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cooperation were raised.

There was also considerable dialogue between the Ministry of Industries and Ministry of Development.

What timescale was the permit developed on? Did the development meet the target timescales? If no, why?

The target timescale is 60 days from application submission. In this particular assessment, there was a significant level of public engagement and a number of technical requests and studies to support the application. This resulted in a delay (officially freezing the permit determination process), the permit actually taking approximately 1 year to determine and issue.

Were there any disagreements between the operator and the Competent Authority during permit development? If so, how were they resolved?

There were no disagreements highlighted.

Question (4) Was the process for permit application also undertaken in conjunction with development of an Environmental Impact Assessment.? To what extent were these processes co-ordinated? Was information from the EIA incorporated into the permit application in accordance with Articles 6(2) and 9(2)?

Interaction with the EIA The application process was not taken in conjunction with development of an EIA as this was an existing installation moving to IPPC under transitional arrangements. process The application was for a new IPPC permit for an existing installation and therefore fell under transitional arrangements.

Question (5) Does the permit contain conditions that are compliant with the requirements as set out in Article 9(3) of the Directive or general binding rules according to Article 9(8)?

Inclusion of ELVs or Air: equivalent parameters or The permit sets limit values for the main polluting substances. For concentration-based technical measures emissions of particulates, NOx and SO2, the permit ELVs have been based upon the limit (Article 9(3)) or reference values indicated within the large combustion plant Directive (2001/80/EC). The limits are effective from 30.09.2007. Prior to this, the emissions have been controlled by the to GBR (Article 9(8)) national limits in Ministerial Decree KYA 29457/1511/2005.

The permit also sets mass limits for:

. SO2 of 9000 tonnes/year/unit (units I-IV), 3000 tonnes/year/unit (unit V);

. NOx of 13,000 tonnes/year/unit (units I-IV), 4,000 tonnes/year/unit (unit V)

These mass limits in the permit are valid only until the issue of new National Emission Reduction Plan values (NERP) and are valid with maximum exceedence of 305 tonnes/year (units I-IV) and 65 tonnes/year (unit 5). Based on revisions to the NERP (summarised in the meeting), it is understood that these values are no longer valid.

NERP values have since been issued (August 2008) with the following values:

. SO2 - 22,640 tonnes per annum (2008-2015), 22,640 tonnes (2016+)

. NOx – 28,300 tonnes per annum (2008-2015), 11,320 tonnes (2016+)

. Particulates – 5,660 tonnes per annum (2008 onwards)

Based on the current available information and permit, it is not clear if and when the new NERP limits will be transposed into the permit or whether they will replace or supplement existing concentration-based ELVs.

Concentration-based ELVs have also been set in the permit for dust emissions from the boiler room stack and for emissions of cadmium and mercury.

Water:

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ELVs (and other relevant conditions) have been set in the permit for all discharges made to water. These are based on national values developed by the Ministry for Water and transposed into national legislation in the form of Ministerial Decisions. The competent authority noted that the national legislation requires compliance with the requirements set within Directive 76/464/EEC (dangerous substances in water).

Land:

No ELVs have been set in the permit for emissions to land.

Protection of soil and groundwater

No ELVs have been set.

The permits contain a number of conditions (including pollution prevention and accident prevention / control measures) relating to requirements to protect groundwater and soil.

Waste

The permit contains a number of conditions relating to waste and includes technical measures supported by ELVs, for example ‘storage of ash slurry in silos that are fitted with cyclones to reduce vent emissions to below 100 mg/m3.

Transboundary considerations

It is understood that the procedure for taking into account transboundary pollution was done in accordance with Article 17. The permit indicates that conditions are not required in order to control transboundary pollution as the impacts are not likely to adversely affect the environment and air quality of neighbouring Member States.

Further equivalent technical parameters/measures have been set for:

The permit contains the following equivalent technical measures:

. The operational removal efficiency of the ESPs for units 1-4 shall be >99.5%. The improvement of the existing and the addition of new electrostatic precipitators to these units is imposed until 30.09.2007.

. The operational removal efficiency of the ESPs for unit 5 shall be >99.9%.

. The use of any supplementary fuels (e.g. diesel fuel during start-up) is subject to the fuel meeting the minimum requirements of the low-sulphur in fuels Directive.

Table A.1b - Permit Emission Limit Value Summary Table

Emission Pollutant Permit Limit Corresponding Monitoring (Permit) point refer- (ELV) BREF BAT-AEL ence

Method Units Av Period Ref. Cond.

Emissions to Air

LCP point source process emissions

Boiler units I- Particulates1 100 mg/m3 5-20 mg/m3 Continuous mg/m3 48 hour 101.3kPa IV monitoring – average 2 3 3 SO2 400 mg/m 20-200 mg/m QAL 2 value O2 6% Certified 3 3 NOx 500 mg/m 5-200 mg/m and 273K

Cd 10 mg/m3 No BAT-AEL monthly dry average Hg 0.3 mg/m3 >75% reduction value

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Emission Pollutant Permit Limit Corresponding Monitoring (Permit) point refer- (ELV) BREF BAT-AEL ence

Method Units Av Period Ref. Cond.

Smoke Ringelmann1 N/A

Boiler unit V Particulates 50 mg/m3 5-20 mg/m3 48 hour 3 3 SO2 400 mg/m 20-200 mg/m average 101.3kP value 3 3 Continuous NOx 500 mg/m 5-200 mg/m O 6% monitoring – 2 mg/m3 and QAL 2 Cd 10 mg/m3 No BAT-AEL 273K Certified monthly Hg 0.3 mg/m3 >75% reduction average dry value Smoke Ringelmann1 N/A

Note 1: The ELVs listed in the permit are phased with 150mg/m3 applying until 30.09.2007. 100mg/m3 applies only when the lignite fuel has the specific characteristics presented in Paragraph A, Annex 7 of the LCPD. If the characteristics of the lignite differ to this, an ELV of 50mg/m3 is imposed by the permit.

Note 2: ELV is based on a sulphur reduction of 90% and a fuel calorific value of greater than 1200 kcal/kg.

Non-LCP point source emissions to air

Boiler room Particulates 100 mg/m3 No BAT-AELs and fuel pulverising Pb, As or Cd 10 mg/m3 Periodic (4 mg/m3 Not given areas each times/yr)

Hg 0.3 mg/m3

Emissions to Water

Wastewater treatment plant

Wastewaste pH 6.5-8.5 N/A Continuous pH / On-line N/A treatment On-Line mg/l plant Flow 2000 m3/hr discharge to River Temp 25°C N/A Periodic – mg/l 3 spot weekly samples Suspended 30 mg/l 5-30 mg/l over 24 Solids hours

Dissolved 600 mg/l N/A Solids

Total oil 30 mg/l <30 mg/l ------Heavy Unknown Hg: 0.01-0.02 mg/l metals and Periodic - minerals Cd: <0.05 mg/l monthly (P,N,F,B) F: 1-30 mg/l

N: <50 mg/l

Emissions of waste materials

No ELVs are given in the permit.

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Question (6) Does the permit contain conditions that are demonstrably based on BAT according to Article 9(4) of the Directive?

Inclusion of permit Are the permit conditions relating to ELVs and the equivalent technical measures based on BAT? Does the permit or other supporting documentation show how conditions based on BAT BAT was taken into account in setting these conditions? (Article 9(4)) The permit ELVs relating to the LCP units are not based directly upon BAT as presented within the BREF on large combustion plant. The installation-specific BAT implementation has been based on the BAT determined at European level in the LCP BREF, the country’s split views (as included in the LCP BREF) and Article 9(4), as well as Annex IV of IPPC. This is designed to ensure that all European Directive requirements are effectively transposed into installation-level control measures. The priority is those Directives where emission limits are presented (e.g. LCPD).

The conditions set within the permit as compared to BAT for the key pollutants is listed as:

. Dust (BAT is ESP and Fabric Filter and/or ESP and Wet Scrubbing)

o The technical permit conditions are in line with BAT on this aspect. Although wet scrubbing is not required, the units are required to achieve the minimum removal efficiencies stated in the BREF.

o The ELVs set for dust (50/100 mg/m3) are not in line with BAT-AELs, but with the BAT implemented/interpreted for the specific installation, as described above.

. NOx (BAT is combination of primary measures for lignite fired LCP)

o The technical conditions of the permit require a combination of primary measures to be used and are therefore in accordance with and based on BAT.

o The permit ELVs set for NOx emissions are not equivalent to BAT, but with the BAT implemented/interpreted for the specific installation, as described above.

. SO2 (BAT is low-sulphur coal with FGD, seawater scrubbing and a combination of NOx/SO2 reduction measures)

o The technical conditions do not require FGD on the basis of the operator’s justification that low-sulphur coal and natural de-sulphurisation achieves a level that would be equivalent to dry sorbent injection. On the basis of the assessment, the technical conditions of the permit are not equivalent or based on BAT for a >300MW LCP.

o The ELVs are based on the values set in the LCP Directive and are not equivalent to BAT-AELs, but with the BAT implemented/interpreted for the specific installation, as described above.

Other technical aspects of the permit (such as storage, transportation, reduction of fugitive emissions and treatment/recovery of combustion residues) have been considered and are based on BAT as presented in the BREF.

Is there evidence of consideration of specific technical characteristics of installation, geographic location or local environmental conditions?

In accordance with regional and district authorities, the competent authority reviews the use of ELVs having regard to any particular local factors, including the geographic location, ambient air and water qualities and public sensitivities.

The geographic distribution of power stations, mines and other significant industrial installations in close proximity in the region was of concern when assessing the suitability of the ELVs within the LCP Directive.

The operator and competent authority both commissioned several technical studies of the local environmental quality (ambient air and water) against national standards and those set within the Air Quality Directives. There was concern that the concentrations of dust were higher than national averages and therefore this was of primary concern when setting permit conditions and ELVs.

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The requirement to fit BAT-based abatement for dust removal (ESP’s >99.5% efficiency) was based on the local factors, as was the requirement to seal the transport road from the mines, cover the ash conveyors and require only covered silo trucks to transport fly ash and pulverised fuel ash.

Emissions and local ambient air concentrations of NOx and SO2 were not considered to be of such a high priority and on the basis of extended monitoring, the competent authority determined that the operator’s proposals to use primary measures (for NOx reduction) and no FGD, instead relying on natural desulphurisation, was BAT for this plant.

Is there evidence of any trade-offs to balance different environmental impacts (such as emissions to different media)?

There is no evidence in the permits of trade-offs being made.

Any evidence of factors influencing permit conditions not compatible with Directive (e.g. operator’s economic circumstances)?

No specific evidence of this has been seen during the assessment.

Does the permit contain conditions that relate to any transboundary impacts of emissions from the installation?

The permits contain a statement that indicates transboundary considerations have been assessed but specific conditions are not applicable due to there being no impact at this level.

Question (7) How have the relevant BREF documents been taken into account during the setting of permit conditions?

The operator made a comprehensive assessment of actual operations against BAT as presented in the BREF document on Large Combustion Plant. The operator presented the conclusions at the meeting and these were the result of a significant amount of technical work. It was clear that the BREF conclusions had been clearly investigated and measures taken in a number of areas to upgrade the plant to BAT standards.

There is evidence within the permit that a large number of general and operational conditions have been set in accordance with the requirements given in the BREF.

Question (8) Inclusion of suitable release monitoring requirements:

Inclusion of release Does the permit contain release monitoring requirements that specify the following? monitoring requirements and . measurement methodology and frequency; obligation to supply . evaluation process; and data (Article 9(5)) . an obligation to supply data to the Competent Authority The permit contains a wide range of conditions relating to the requirement for the operator to monitor emissions. The measurement method, frequency and evaluation process are specified or references made to the relevant national laws.

The operator was required as part of the permit improvement programme to install continuous monitoring systems for the key pollutants (see table above) on all units by 2007. This has been achieved and now emissions are trended on a daily, even hourly, basis by plant operatives.

The permit includes a condition that obliges the operator to produce and submit reports on defined frequencies (monthly/annually).

Are the monitoring requirements sufficiently detailed?

The requirements are sufficiently detailed.

Do the monitoring requirements take into account the details contained within the BREF documents?

Monitoring requirements are based on BAT as presented within the operator’s proposals.

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Where it was judged by the competent authority that improvements to bring the measures in line with BAT were required, these are explicitly listed in the permit improvement programme (e.g. continuous monitoring).

Water discharges require continuous composition samples or at least 3 spot-samples in 24 hours (with >2 hours between samples).

Does the permit include information on duration in relation to monitoring requirements?

Yes.

Question (9) Does the permit contain measures relating to conditions other than normal operation? (Article 9(6))

Yes, the permit contains a number of conditions relating to measures and procedures that must be followed in the event of abnormal operation or fault conditions.

Question (10) Are there any General Binding Rules that govern the control of the installation other than conditions set within the permit and if so how do they interact with the permit?

Prescription of Are there any GBRs implementing the IPPC Directive that govern control of the installation? requirements in general binding rules (GBRs) Yes (see below) (Article 9(8)) If so, are these used to set conditions within the permit?

GBRs (Ministerial Decisions and national laws) are used to set permit conditions such as monitoring requirements, ELVs and general operational conditions.

Question (11) Are there relevant Environmental Quality Standards that require stricter conditions than those achievable by the use of BAT and was this reflected in the permit or supporting documentation? If so, what measures have been placed in the permit to ensure compliance with EQSs? (Article 10)

Reference to need to The competent authority judges the operator to be applying BAT in most aspects of installation operations (including the environmentally significant aspect of emissions and comply with EQSs discharges). The ELVs as set within the permit have been assessed having regard to (Article 10) local conditions and judged to be sufficient to ensure that relevant EQSs (Community – Air) (National – Water) are met. Stricter conditions than those achievable by the use of BAT were not deemed by the competent authority to be required in this case.

Question (12) Is there evidence of measures to ensure that Competent Authorities periodically reconsider and where necessary, update permit conditions?

Inclusion of information The permit is valid for a period of 7 years, after which time, the operator must prepare and submit a new application. on period of validity of permit and when it will be reconsidered / updated (Article 13)

Question (13) Is there evidence that public participation and access to relevant documentation in accordance with the requirements of Article 15 of the Directive has been provided for by the Member State?

Public Participation Are the application/ decision document and permit available on a public register? (Article 15(a)) Yes. The competent authority makes the key documents available such as the application non-technical summary and results of the environmental impact assessment (no EIA was required with the IPPC permit application in this case). The decision on BAT (permit determination) is also made available to members of the public upon request.

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Are monitoring records made available to the public?

Yes.

Table A.2 Assessment of the actual installation operation when compared to permit conditions and BAT

Emissions monitoring

Question (14) What is the current emission monitoring performed by the operator?

Details of actual Air emissions monitoring undertaken Continuous monitoring of all LCP. Periodic monitoring of all remaining point source emissions.

All continuous emissions equipment is certified to Quality Assurance Level 2 (QAL 2) standards (in line with EN 14181: Quality Assurance of Automated Measuring Systems) and the permit requirements include independent calibration and testing on an annual basis. All monitoring conducted must comply with the national standards as set out in Greek legislation. In addition to the key monitoring requirements of the permit, the on-line analysers also measure CO and CO2. This information is fed back to the competent authority as part of the annual report.

Water emissions

Continuous monitoring of pH and flow. Periodic monitoring (at least 3 spot-samples in 24 hours (with >2 hours between samples)) of temperature, colour, dissolved solids, suspended solids, total oils and conductivity (Weekly). Periodic monitoring of trace and heavy metals, nitrogen, phosphorous, fluorine and boron (Monthly).

Other

On-line efficiency performance evaluation project (2006) to monitor boiler unit efficiency (total and partial).

Question (15) Does the emission monitoring comply with the permit conditions?

Actual monitoring Yes, based on discussions with both the operator and competent authority, the installation presently complies with all elements of the permit. The operator has made a significant undertaken compared number of improvements in line with BAT as presented within the BREF document on to permit conditions, large combustion plant. requirements of Article 9(5)

Installation performance

Question (16) What were the emissions of the installation before the implementation of the conditions of the permit?

Emissions of key The operator provided quarterly monitoring data for SO2 and NOx emissions from units I-IV as follows: pollutants 3 SO2 (mg/m )

2004: 40 (I) / 32 (II) / 49 (III) / 74 (IV);

2005: 127 (I) / 127 (II) / 83 (III) / 152 (IV);

2006: 524 (I) / 238 (II) / 422 (III) / 652 (IV);

3 NOX (mg/m )

2004: 316 (I) / 300 (II) / 285 (III) / 274 (IV);

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2005: 326 (I) / 291 (II) / 269 (III) / 295 (IV);

2006: 420 (I) / 347 (II) / 313 (III) / 407 (IV);

The emissions monitoring data shows the general trend that SO2 emissions fluctuate far more than NOx due to the different composition of the lignite fuel; primarily the concentration of calcium.

Question (17) What are the current emissions of the installation?

Emissions of key The current emissions are summarised in table A2.b. pollutants

Question (18) How do the current emissions from the installation compare with permit ELVs and BAT-AELs (where defined) in the relevant BREF documents?

Installation Current performance: performance and On the basis of the data requested and submitted (2007), it is clear that the emissions assessment of BAT fluctuate between units and are very dependent upon the characteristics of the lignite fed into the boilers.

An examination of the available data indicates that permit ELVs are being met for particulates and NOx but not for SO2.

SO2

The data taken from quarterly periodic measurements during 2007 shows that the four of the five units do not comply with the permit ELV of 400 mg/m3. Having asked for explanation at the meeting as to why this is, the operator cited the characteristics of the lignite as the key factor. The emissions of SO2 are, as indicated by the operator, subject to very large fluctuations because the SO2 concentration is directly related to the ability of the natural calcium within the lignite to de-sulphur the gases during combustion.

The operator highlighted that, in accordance with BAT, they have made some significant measures to reduce the fluctuations (fuel mixing, staged sorting and loading from different bunkers, etc).

An evaluation of the on-line data at the meeting in November 2008 demonstrated this fluctuation. Emissions of SO2 did fluctuate but were all demonstrated as being within the ELV of 400mg/m3 on the day of evaluation. For a period exceeding 30 minutes, emissions 3 of SO2 were around the 10mg/m mark.

The conclusion is therefore that the emissions of SO2 during 2007 were not compliant with the permit ELVs. Based on an single ‘snap-shot’ made during the meeting in 2008, are typically within the permit ELV of 400 mg/m3 however there are substantial and wide- ranging fluctuations in the concentration of SO2 within the gas stream.

Despite the introduction of BAT-based measures such as low sulphur fuel (<1%), fuel mixing and staged combustion feed from different source bunkers, there remains a significant level of fluctuation correlating directly to the conversion efficiency of gases based on the calcium content of the lignite. At 70% reduction of SO2, this equates to the minimum level of performance anticipated by using dry sorbent injection however this technique is not listed as BAT for plants over 200MW. The BAT conclusions are that low sulphur fuel should be used in combination with other SO2 reduction techniques (wet FGD, seawater scrubbing, DESOX) and therefore on this basis, it can be concluded that the installation is not applying a combination of the measures considered to be BAT as presented in the BREF on large combustion plant.

The comment from the Ministry on comparison with BAT was that “the installation applies BAT, as implemented specifically according to IPPC, taking into account the BREF LCP, the cited country’s split views, Article 9 (4) and Annex IV of the IPPC Directive”.

NOx and Particulates

Emissions of NOx were shown to be far more stable than those for SO2, with a range of between 200 - 450 mg/m3.

Emissions of particulate matter are now well below 10 mg/m3 for all units due to the new ESPs coming on-line during the last 12 months. The raised emissions of particulates from

unit III were due to a fault and subsequent shut-down of the unit for maintenance.

Other

Given the fact that the installation does not use FGD, the added benefits of emissions reductions of heavy metals are not realised and therefore the use of ESPs as a sole method of abatement of heavy metal emissions may not represent BAT. The view of the Ministry was that “nevertheless, the installation complies with the BAT conclusion on heavy metals, i.e. ’… is to use a high performance ESP (reduction rate>99.5%) …’”.

During the site visit, the operator highlighted that further assessment and monitoring following installation of the ESPs is necessary to reach an adequate conclusion on this issue.

Table A.2b Comparison of installation performance with permit conditions and with BREF BAT-AELs

Emission Pollutant Installation Permit Limit Corresponding Compliant BAT-AEL Monitoring (actual) point refer- performance (ELV) BREF BAT- with per- reached? ence AEL mit?

Method Units Av Period Ref. Cond.

Emissions to air

LCP point source process emissions

Boiler units I- Particulates 1) 5.37 mg/m3 100 mg/m3 5-20 mg/m3 YES1 NO Periodic monitoring – mg/m3 6-8 hourly 101.325kPa IV quarterly in interval 3 2) 4.57 mg/m accordance with sampling O2 4.5-5% national standards averaged over 3 3)158.8 mg/m 3 days 273K 4) 81.27 mg/m3

3 3 3 2 SO2 1) 777 mg/m 400 mg/m 20-200 mg/m NO NO

2) 639 mg/m3

3) 172 mg/m3

4) 654 mg/m3

3 3 3 NOx 1) 461 mg/m 500 mg/m 5-200 mg/m YES NO

2) Not Operating

3) 199 mg/m3

4) 296 mg/m3

Cd No data 10 mg/m3 No BAT-AEL Not known N/A

Hg No data 0.3 mg/m3 >75% Not known N/A

Emission Pollutant Installation Permit Limit Corresponding Compliant BAT-AEL Monitoring (actual) point refer- performance (ELV) BREF BAT- with per- reached? ence AEL mit?

Method Units Av Period Ref. Cond.

reduction

Smoke No data Ringelmann1 N/A N/A N/A

Boiler unit V Particulates 32.8 mg/m3 50 mg/m3 5-20 mg/m3 YES NO Continuous monitoring mg/m3 30 min average 101.325kPa – QAL 2 Certified values 3 3 3 SO2 909.8 mg/m 400 mg/m 20-200 mg/m YES NO O2 5.5-7.5%

3 3 3 NOx 236.2 mg/m 500 mg/m 5-200 mg/m YES NO 273K

Cd No data 10 mg/m3 No BAT-AEL N/A N/A

Hg No data 0.3 mg/m3 >75% N/A N/A reduction

Smoke No data Ringelmann N/A N/A N/A 1

Note 1: Emission limit of 150mg/m3 in force until September 2007 therefore permit was compliant despite several exceedences of 150mg/m3. Analysis of trend data from 2008 indicates that emissions of particulates have been reduced to a normal range of 60-90 mg/m3.

Note 2: Periodic monitoring data was not available at the time of assessment as the continuous emissions monitoring equipment was installed and operational in 2008. On the basis of the information provided, the mass emissions for the period Jan-Dec 2007 were reported as:

. SO2 - 6,790 tonnes (unit I), 8,410 tonnes (unit II), 8,080 tonnes (unit III), 5,230 tonnes (unit IV).

. NOx – 5,450 tonnes (unit I), 5,140 tonnes (unit II), 5,190 tonnes (unit III), 3,490 tonnes (unit IV – shutdown Sept 07 onwards for maintenance).

This element is critical to the assessment as the competent authority indicated that they had not taken direct enforcement action following SO2 emission limit breaches due to the on- going evaluation of the installation’s NERP limit. There was some significant confusion at the meeting as to why the NERP should over-ride the ELVs set in the permit and it remains unclear as to whether the correct action was taken by the competent authority.

Non-LCP point source emissions to air

Boiler plant Particulates No data 100 mg/m3 No BAT-AELs N/A N/A Periodic monitoring – mg/m3 Not specified Not specified and lignite not specified pulverising Cd 10 mg/m3 N/A N/A

Emission Pollutant Installation Permit Limit Corresponding Compliant BAT-AEL Monitoring (actual) point refer- performance (ELV) BREF BAT- with per- reached? ence AEL mit?

Method Units Av Period Ref. Cond. areas Hg 0.3 mg/m3 N/A N/A

Emissions to water

Liquid process pH 8.07 (annual 6.5-8.5 N/A YES Unknown Continuous mg/l Daily average Not given wastewaters av.) monitoring using values composite samples Flow 819 m3/hr 2000 m3/hr N/A YES Unknown over a 24 hr period (annual av.)

Temp No data 25°C N/A YES Unknown

Suspended No data 30 mg/l 5-30 mg/l YES Unknown Periodic Monitoring Solids 3 spot samples inside 24 hr period Total oil No data 1 mg/l <30 mg/l YES Unknown (2 hrs apart)

Heavy P <0.025 mg/l N/A Hg: 0.01-0.02 N/A YES (Hg, F, Hg-ELOT EN1483 metals and mg/l Cd) minerals F 0.29 mg/l Cd-ELOT EN1233 (P,N,F,B) Cd: <0.05 mg/l Hg <0.01 mg/l F-ELOT EN ISO F: 1-30 mg/l 10304-1 Cd <0.02 mg/l N: <50 mg/l

Future operation

Question (19) What improvements in performance have been made since issue of the permit and what future improvements have been planned?

Improvements since permit issue:

. Implementation of a staged dust emissions reduction programme through improvement of the existing and installation of new ESPs with emissions abatement performance for dust of >99.95%.

. Completion of continuous monitoring systems for all units.

Planned improvements in the future:

A full list of improvements was not presented by the operator due to considerations of time; however several examples of major improvements were illustrated, including:

. Turbine II and IV upgrading;

. Flue gas heat recovery systems (energy efficiency measures) on units III and IV.

. Cooling towers upgrading

Question (20) Is there evidence that measures are in place to ensure that at cessation of activities, the site is returned to a satisfactory state?

Inclusion of measures It is not clear within the permit conditions that the operator is required to produce a formal site closure plan. The operator is required by the IPPC law within Greece to make foreseen to ensure that adequate provision for ensuing that the site is returned to a satisfactory state following at cessation of final closure and although the operator has not developed a formal plan yet; they were activities, the site is aware of the obligations upon them to undertake and make provision for this. returned to satisfactory state (Article 3(f))

Sanctions and ensuring compliance

Question (21) What measures are currently used to ensure compliance with the permit conditions?

Measures taken by the Procedures used by the Competent Authority for ensuring compliance: Competent Authority to The primary measures for checking compliance are performed by the inspection division ensure compliance with of the competent authority. The inspectorate undertakes a review of submitted permit conditions monitoring data on a regular basis and supports this with on-site compliance inspections. All results are fed back to the competent authority and there remains the ability for the (Article 14) competent authority to conduct on-site inspections if they feel it is necessary or in response to accidents or faults. The local prefecture also retains the right of on-site inspection for wastewater treatment processes/discharges.

Have sanctions or other measures been applied in cases of non compliance with the permit conditions?

There are a range of measures that can be taken in the event of non-compliance with permit conditions. These include informal and formal communications, enforcement actions (improvements) and suspension/permit revocation.

In this instance, the operator reported (through monitoring data) a non-compliance with emission limits set for boilers I-IV for SO2. The competent authority indicated that they did not take any action other than communicating with the operator. The reason for the breach was due to the character of the lignite (low in natural calcium); however the fact that the breach was extended by a significant period without redress raises questions as to whether action should have been taken.

The competent authority indicated at the meeting that the NERP value limits were being revised during this period and it was not clear if the installation should be regarded as

being compliant based on the existing NERP values (equivalent to much higher ELVs when transposed).

Based on the level of exceedence and extended nature of the breach of ELV for SO2 on all units, the fact that the competent authority did not take any enforcement action in this case may be considered to be not in accordance with the Directive 2008/1/EC (Article 14(a)).

Procedures and/or systems used by the operator to ensure compliance with permit conditions

The operator has developed a range of IPPC permit compliance matrices and written the key compliance elements into procedures, which have been briefed to all members of staff in training. The operator maintains a formal EMS, verified according to ISO 14001, and references the requirements within this system to enable adequate training to be provided to educate employees regarding the importance of system checks and monitoring with regard to permit compliance.

Daily operational checks are undertaken on key elements, including process control, monitoring and compliance with IPPC. Any operational deviation must be communicated back to the environmental team and there are corporate and site-level environmental audits.

The assessment gathered significant evidence that the operator is using BAT to undertake compliance checks and communicating this right up through the management hierarchy. The key roles for environmental management and those with a responsibility for IPPC permit conditions compliance are listed and persons held to account.

Procedures used or action taken by the operator in the event of non-compliance

In the event of non-compliance, there is initial communication to the environmental department. The competent authority would be informed immediately (according to the permit within 24 hours in most cases) and corrective actions would be implemented, which may include emergency response. Accident management and mitigation reports are developed and key management roles briefed. Preventative actions will be implemented where necessary.

As indicated above, this process does not appear to have been followed for the reported breaches of the SO2 emission limits.

Question (22) Does the competent authority conduct on-site inspections? How many on-site inspections by competent authorities have been carried out during the last 12 months? Does the operator assist the competent authority in the inspections?

Operator must afford The inspectorate department of the competent authority conducts on-site inspections. Typically, the inspectorate would undertake 1-2 major audits per annum with minor audits the competent where necessary or in response to non-compliance. authority all necessary assistance to allow Both the operator and competent authority highlighted that the operator is required by law to cooperate and provide assistance as may be necessary to the inspectorate. It was not inspections to be clear at the meeting how inspections were used to ensure compliance given the carried out, to gather highlighted breach of the SO2 limit during 2007. information and to take samples

Consultant’s overall assessment Do the permit conditions and the current performance of the installations fully comply with the requirements of the IPPC Directive?

With the exception of BAT-based ELVs and techniques for reducing SO2, the assessment shows that the permit has been issued in accordance with the requirements of the IPPC Directive. This is supported by the following findings:

. There is a single IPPC permit covering the main activities at the installation.

. The application contained all the key elements required by Article 6. The operator also produced a comprehensive

BAT comparison that considered existing processes and equipment in light of other techniques/technologies given within the BREF on large combustion plant.

. The permit as assessed is a comprehensive document containing a mixture of general and specific conditions that meet most of the requirements set out in Article 3(a)-(f) of Directive 2008/1/EC, having regard to the fact that the permit references the national requirements on energy efficiency. A site closure report is not required under the current terms of the permit.

. Where the determination process has shown the installation is not currently using BAT, in most cases, the permit contains specific improvement conditions that require the operator to implement measures based on BAT.

. ELVs have been set for all sources of air and water emissions. The basis for setting these ELVs has been on Ministerial Decisions that transpose European legislation into Greek national law. The Ministry has indicated that the installation applies BAT, as implemented specifically according to IPPC, taking into account the BREF LCP, the cited country’s split views, Article 9 (4) and Annex IV of the IPPC Directive. The ELVs for the large combustion plant units have been set directly using values from the LCP Directive 2001/80/EC.

. An assessment of the main permit conditions against BAT as given in the BREF on large combustion plant shows that, with the exception of ELVs and SO2 abatement techniques, the permit conditions are based on BAT and offer a high degree of protection to the environment as a whole.

. ELVs have not been based on BAT but have been transposed directly from Directive 2001/80/EC. The suitability of these ELVs has been assessed by the competent authority on the basis of local environmental impacts and air/water quality standards protection. The conclusions are that the ELVs as set retain a high level of overall environmental protection when considered in parallel with the technical abatement equipment and operational conditions within the permit but that these are not in line with the BAT-AELs.

. The permit includes a series of detailed conditions relating to the requirement for the operator to monitor emissions. The measurement method, frequency and evaluation process are specified or references made to the relevant national laws. The permit required the operator to implement continuous monitoring of emissions from the 5 boiler units. The permit conditions oblige the operator to produce and submit reports on defined frequencies (monthly/annually).

. The permit has a suitable period of validity (7 years) and there was evidence that the permit, application and monitoring records are available to members of the public upon request.

With the exception of breaches of emission limits for SO2 during 2007, the assessment demonstrates that the installation is currently operating in accordance with their permit but not in accordance with BAT in all cases.

. On the basis of the current data available (2007), operational performance against BAT-AELs shows that the installation meets does not meet BAT-AELs for SO2 or NOx but meets BAT-AELs for particulates for boilers I, II and IV. The assessment concludes that for other aspects, the installation is utilising BAT to prevent or where not practicable, to reduce, emissions of pollutants and to improve aspects of performance such as waste recovery, water and energy minimisation and prevention of accidents.

. Breaches of SO2 emission limits were reported for 4 out of 5 units during 2007. The extended nature of this breach shows that the competent authority did not take enforcement action against the operator in this case.

. Based on a snap-shot of current performance (following progressive upgrades to reduce pollution emissions), the installation is presently complying with the emission limits in the permit and achieving BAT performance for dust but not for SO2 or NOx.

What recommendations can be made as regards the actual implementation of the Directive for this case study?

No specific recommendations.