Legislation governing emissions on medium combustion plant – such as boilers – came into effect at the tail end of last year, but just how stringent are the new rules? Robert Smith reports.
Boilers have sat at the heart of most industrial facilities for decades, tirelessly circulating heat to vital manufacturing processes and pieces of equipment.
A 2014 report for the UK government by independent organisation the Carbon Trust highlights that in 2005 industry in the UK consumed roughly 250,000GWh of fossil fuel – of which about 35% was used in steam boilers.
The report, which is designed to offer an overview of steam boiler equipment specified on the energy Transfer List (ETL) and illustrate the reductions in energy bills that could be achieved by investing in qualifying ETL energy saving equipment, says “a significant proportion of energy used for steam generation is wasted”. The report says: “The energy delivered to the point of use can be as low as 50% of the energy in the fuel burned by the boiler. Good practice – for example addressing leakage and improving pipework insulation – may increase the level of useful heat delivered.
“Losses can also be reduced significantly by replacing low efficiency steam boilers and adding energy saving devices to the steam system.”
Reinventing the wheel…
Boiler design, however, has not radically changed since this piece of kit was first introduced.
That is according to Carl Knight, managing director at Fulton Boilers, who says that while there has been some progress in burner technology, “the actual boiler itself has been unchanged for around 150 years. That’s a bold statement but it’s true”.
Fulton Boilers, which is predominantly based in the US but has offices in the UK, recently introduced the VSRT – a gas-fired, vertical spiral-rib tubeless steam boiler designed as a successor to its J Series.
Leigh Bryan, sales and marketing manager at Fulton, claims the VSRT is “different to any other boiler currently on the market”.
The actual boiler itself has been unchanged for around 150 years. That’s a bold statement but it’s true
Carl Knight, managing director, Fulton Boilers
Bryan says: “We brought in a team of engineers from the US who typically design jet engines and gave them the remit to design a tubeless boiler from the ground up, meaning there were no preconceptions.”
He says that traditionally, boiler manufacturers come up with an idea for an improvement, build it, test it, and see how well it works. “With the VSRT, we didn’t even build anything until we completely modelled the unit.”
Essentially, the new boiler needed to meet ever-more stringent industry and environmental standards, improve steam quality and reduce NOx emissions.
Throughout Europe, the latest clampdown on pollution resulting from industrial equipment – including boilers – comes in the form of the Medium Combustion Plant Directive (MCPD), a piece of legislation proposed by the European Parliament in 2013 which was written into national law across member states (including the UK) in December last year.
The Commission estimated in 2016 there were around 143,000 pieces of medium combustion plant throughout the EU that would fall under the remit of the new legislation.
MCPD, which also covers sulphur dioxide, carbon dioxide, and dust emissions, is aimed at combustion plant ranging from 1MWth to 50MWth. It is largely designed to plug the regulatory gap at EU level between large combustion plants (greater than 50MWth), which are covered under the Industrial Emissions Directive (IED), and smaller appliances – such as heaters and boilers under 1MWth – covered by the Ecodesign Directive.
According to a statement from the European Commission: “The emission limit values set in the MCPD will have to be applied from 20 December 2018 for new plants and by 2025 or 2030 for existing plants, depending on their size. The flexibility provisions for district heating plants and biomass firing will ensure that climate and air quality policies are consistent and their synergies are maximised.”
Reaching retirement?
Fulton’s Knight believes that because of the introduction of MCPD, legacy and ageing kit is living on borrowed time. More specifically, he says the age of the reverse flame boiler “is gone”.
Knight says: “If boiler manufacturers don’t work on solutions to enable low-NOx on reverse-flame boilers, reverse-flame will become a thing of the past.”
This is despite a 2017 report by Transparency Market Research which estimates the market for these products in Europe could swell from around $93 million in 2016 to $142.1 million by 2025.
However, modifications to plant that might not comply with MCPD could act as a simple workaround for some boiler house and burner manufacturers. Knight says this could render MCPD little more than “a box-ticking exercise”, rather than transformative piece of legislation.
I don’t think people are simply turning a blind eye to MCPD. There is just a lack of clarity
Leigh Bryan, sales and marketing manager, Fulton
Should the legislators, therefore, consider making MCPD more stringent?
Knight suggests that through the Department for Environment, Food and Rural Affairs (Defra), stricter measures could be imposed. “If that happens, some of the boilers currently on the market will have to disappear. At the moment, they comply. If it changes, they won’t.”
Regardless, plant operators with kit over 1MW will still have to comply with the new rules. In an editorial last December for the Combustion Engineering Association (CEA), honorary member Paul Whitehead said it was the plant operator’s responsibility to register their plant with the relevant authorities and that owners of new plants would have to be able to prove that they actually operated the plant before 20 December 2018 for it to qualify as an existing MCP.
He indicated that MCP users aware of the legislation may already be prepared – and might have “listened to their suppliers and industry contacts, and heard the messages from the trade associations”.
Whitehead said: “However, they represent a very small percentage of the anticipated 30,000 MCPs currently installed in the UK.”
Educating the industry
The CEA, which counts Fulton Boilers as a member alongside several of the industries’ major boiler manufacturers, has been pushing for the introduction of MCPD for over two years, says Bryan.
“We – as the CEA – have driven some of the legislation, assisted Defra, written technical papers and, among ourselves, organised conferences. We tried to educate the world, but even now, we get specifications for boilers that fail to mention MCPD.”
As can sometimes be the case, particularly in the process engineering industry, there is an ignorance around understanding new legislation and the implications of falling foul of the rules.
“But I don’t think people are simply turning a blind eye to MCPD. There is just a lack of clarity,” Bryan says.
Electric dreams
Perhaps, however, the answer lies in the type of boiler a facility chooses to install. While gas or oil-fired boilers are typically the standard, electric boilers do offer unique benefits.
For instance, they are more environmentally friendly than their gas or oil-fired counterparts and can be less cumbersome – particularly when fuel storage requirements are taken into consideration.
These boilers are generally installed in research facilities and at universities, as well as some food processing plants and power stations, Knight says, adding that as they aren’t fired, the MCPD does not apply.
“However, power requirements negate any advantages with regard to costs,” he says.
