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The regulations make special provision for MCP's such as emergency generators, which operate intermittently or rarely. Where these MCP's operate less than 500 hours per year (as a rolling average over 5 years), they are exempt from some of the specified ELVs but there is still a requirement [Schedule 3, Part 1] to measure carbon monoxide. Where necessary, for environmental protection, the regulations allow the EPA to reduce this number of hours in specific circumstances for specific plant (similar to the provisions for reducing ELVs). [See Regulations 13(1), 13(3) and 20(4)(c)].

Monitoring of emissions to atmosphere

The European Union (Medium Combustion Plants) Regulations 2017 require that periodic monitoring of emissions to atmosphere from medium combustion plants is carried out. Air emissions sampling and analysis is a particularly difficult aspect of environmental monitoring, and specialist equipment is required to be used. Both the sampling and analysis stages of air emissions monitoring require a high level of competency and quality control. Most MCP facilities will not carry out their own air emissions monitoring, but will instead employ a specialist contractor to carry out the monitoring and provide a report, which can be submitted to the EPA. The EPA generally supports the approach of using external specialist service providers, and would not recommend that facilities attempt to carry out their own air emissions monitoring.

In order to ensure the generation of consistent, high quality and robust monitoring data from MCP facilities, it is a mandatory requirement that all air emissions monitoring carried out is performed by an ISO 17025 accredited air monitoring contractor. Accredited air emission monitoring contractors operating in Ireland either receive their accreditation from the Irish National Accreditation Board (INAB), or else they operate under the United Kingdom Accreditation Service (UKAS).

The details of the INAB ISO 17025 accredited air emissions monitoring contractors are as follows:

• Air Scientific Limited
• Glenside Environmental Ltd

The Irish-based contractors who hold UKAS ISO17025 accreditation for air emissions monitoring are as follows:

• Element Materials Technology
• Fitz Scientific
• Socotec

You must ensure that the air monitoring contractor you intend to use for EPA compliance monitoring holds ISO17025 accreditation. The EPA will not accept monitoring results from a monitoring contractor, who does not hold accreditation to the ISO17025 standard.

For guidance on a standardised approach to monitoring the emissions to atmosphere the operator should refer to the Agency Guidance Note on monitoring of Stack Gas Emissions from Medium Combustion Plants: AirGuidance No.11 (AG11).

ELVs are set in the regulations based on combustion plant type, size, fuel type, and age ( i.e. new or existing). These can be seen in a series of tables in Schedule 2 of the Regulations. Note the detailed footnotes that clarify and, in some cases, modify the ELVs for specific applications.

These ELVs are default values that may be reduced by the Agency in particular instances where lower ELVs are required for environmental protection purposes. This might occur where, for example, air quality problems in an area are considered by the Agency to be caused or partly caused by MCP emissions. [See Regulations 11(5) and 11(6)].

The main requirements are as follows:

• Each MCP must be registered with the EPA by the specified date, unless it is on an installation regulated by an IED/IPC licence from the EPA.
• Operators must provide information to the competent authority (EPA) for the purposes of registration.
• The MCP must comply with emission limit values (ELVs) for SO₂, NOx and dust, by the dates referred to above.
• Emissions (SO₂, NOx, dust and carbon monoxide (CO)) must be monitored at least every 3 years for plants up to 20 MWth, or at least annually for plants greater than 20 MWth.
• For MCPs not subject to ELVs, as they are operating for less than 500 hours per annum, there is still a requirement [Schedule 3, Part 1] to measure carbon monoxide.

In addition the regulations require registered operators to keep various records relating to the operation of the plant and emissions monitoring, and specify other obligations such as notifying the Agency of non-compliances. See Regulation 14 for full details.

A “combustion plant” is defined as “…any technical apparatus in which fuels are oxidised in order to use the heat thus generated” covering boilers, turbines, and engines.  The regulations apply to both new and existing equipment, between 1 and 50MWth.  Regulation 4(3) sets out exemptions for some specific combustion plants.

They are referred to as ‘medium’ because large combustion plants ‘LCP’ (i.e. those >50 MWth) are covered by the Industrial Emissions Directive (2010/75/EC), while small combustion plants (up to 500 kWth) are covered by the Ecodesign Directive (2009/125/EC)