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Technical Assistance for Better Air Quality by Transposing the Large Combustion Plant Directive, Contract no. TR2010/0327.04-01 – Study Tours Report (Final) This Project is co-financed by the European Union and the Republic of Turkey

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Service Contract Number: TR2010/0327.04-01

Technical Assistance for Better Air Quality by Transposing the Large

Combustion Plant Directive

Study Tours Report (Final)

Turkey (May 2016)


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Document Lead Sheet

Client Project No: TR2010/0327.04-01

FW Project No: 1-BH-0511A

Document No: BH0511A-00-16F

Technical Assistance for Better Air Quality by Transposing the Large Combustion Plant Directive

STUDY TOURS REPORT

ISSUE DATE ORIG

APPROVED

FW / PM

APPROVED CLIENT

DISTRIBUTION DESCRIPTION

A 21/05/2016 RCF, RB PS, JM CFCU, MoEU, PSC

Draft for Client Comments

B 29/06/2016 RCF, RB PS, JM UF MoEU Final version

C


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Project Title: Contract Identification Number: Technical Assistance for Better Air Quality by Transposing the Large Combustion Plant Directive

EuropeAid/132843/D/SER/TR

Service Contract Number: Contract Value: TR2010/0327.04-01 € 998,033.00 Date of Project Commencement: Date of Project Completion: 22 July 2014 24 months Contracting Authority: Contact Person: Central Finance & Contract Unit (CFCU) Eskişehir Yolu 4. Km 2. Cd. (Halkbank Kampüsü) No: 63 C-Blok 06520 Söğütözü-Ankara/TURKEY

Ms. Emine Döğer, PAO-CFCU Director [email protected]

Coordinating Body, Key Beneficiary: Contact Person: Ministry of Environment and Urbanization Ceyhun Atıf Kansu Cd. Ehlibeyt Mah.1271. Sok. No:13 06520 Balgat/ANKARA +90 312 5863056 (T) +90 312 4740335 (F)

Ms Betül Aydın [email protected]

Consultant: Contact Person: Consortium AMEC Foster Wheeler, Lead Partner Via Caboto 15 Corsico - Milan Italy - 20094 +39 02 44862175 (T) +39 02 44863112 (F) Project Management Ltd Killakee House, Belgard Square Dublin 24, Ireland +353 1 4040700 (T) +353 1 4599785 (F)

Mr Paolo Sammartino, Project Manager [email protected] Mr Jim McNelis, Project Director [email protected]

Project Office Address: Team Leader:

Ӧveçler Mahallesi 1314 Caddesi No: 18/6 Çankaya/ Ankara Turkey

Mr Rob Bakx +90 312 4961601 (T) +90 312 4961605 (F) [email protected]

Date of report: 21 May 2016 Author(s) of report: Russell Frost, Rob Bakx The content of this report is the sole responsibility of the Consultant and can in no way be taken to reflect the views of the European Union. Adjustments imposed to the report – made during the consultations on the draft text – without the consent of the Consultant fall under the responsibility of those who imposed these adjustments.


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Table of Contents

GLOSSARY OF TERMS 7

EXECUTIVE SUMMARY 9

1. CONTEXT OF THE STUDY TOURS 11

2. STUDY TOURS PREPARATION AND LOGISTICAL ASPECTS 13

3. STUDY TOUR PROGRAMMES 14

4. IMPLEMENTATION AND EVALUATION OF THE STUDY TOURS 17

5. CONCLUSIONS AND RECOMMENDATIONS 18

ANNEX A STUDY TOUR 1, ITALY (22 – 26 JUNE 2015) 19 PROGRAMME 19 PRESENTATIONS 23

EURAL Energy – New co-generation plant 23 IED Directive in Italy 32 Voghera Energia – 400 MW Combined Cycle Power Plant 41 Environmental data: public access to information 49 Emissions monitoring 53 Regulatory framework and environmental context in Lombardy 66 Liberalisation of the energy market in Italy and the role of Lombardy region 78 Sannazaro Refinery 84 ISPRA – Large Combustion Plants 119 Overview of IPPC/IED implementation in Italy 123

PARTICIPANTS 137 PHOTO IMPRESSION OF THE STUDY TOUR 138 EVALUATION 139

ANNEX B STUDY TOUR 2, FINLAND (22 – 26 FEBRUARY 2016) 143 PROGRAMME 143 PRESENTATIONS 147

AMECFW – Company Overview 147 EU environmental legislation changes and their effects 158 Air pollution Control in Finland 180 Environmental permit 188 LCP Directive and NERP – Implementation in Finland 192 General presentation of the Finnish Ministry of Environment 198 HELEN Ltd. Towards a carbon neutral future 201 Salmisaari Power Plants 209 Emission monitoring and reporting at HELEN 216 Reduction of NOx emissions in coal power plants 220 Information exchange role of SYKE – LCP BREF process 234 Integrated assessment modelling of particulate matter in Finland 241


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Roles of SYKE 248 Finnish Environmental Administration 255 LCP Emission Inventory 268 Finnish Environmental Institute - SYKE 272 Vantaa Energy 277 Co-operation with authorities 285 VTT – Technical Research Centre of Finland 288 Utilisation of CFD modelling to design low NOx combustion 292 Combustion process development 297 Finnish Emission monitoring procedures 304

PARTICIPANTS 320 PHOTO IMPRESSION OF THE STUDY TOUR 321 EVALUATION 322


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Glossary of Terms

Acquis Environmental Acquis – the collective body of EU Environmental Legislation

BAT Best Available Techniques

BREF BAT Reference Document

CCGT Combined Cycle Gas Turbine

CSCP Centre for Sustainable Consumption and Production

EEA European Environment Agency

E-PRTR European Pollutant Release and Transfer Register

EU European Union

EÜAŞ Electricity Generation Company Inc.

EV Emission Values

IED Industrial Emissions Directive

IPPC Integrated Pollution Prevention and Control

LCP Large Combustion Plant

LCPD Large Combustion Plant Directive

MENR Ministry of Energy and Natural Resources

MoEU Ministry of Environment and Urbanisation

MoEUA Ministry of Environment, Urbanisation and Agriculture (Finland)

MS Member State

NOx Nitrogen Oxides

RIA Regulatory Impact Assessment

SCR Selective Catalytic Reduction

SNCR Selective Non-Catalytic Reduction

SO2 Sulphur Dioxide

ToR Terms of Reference

VTT Technical Research Centre of Finland


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Executive Summary

This Report documents the implementation of the ‘Study Tours’ element of the project: ‘Technical Assistance for Better Air Quality by Transposing the Large Combustion Plant Directive’ in Turkey. Two five-day Study Tours were held to EU Member States, the Member States determined and agreed with the main Beneficiary in accordance with ToR criteria. One was to Italy in June 2015 and one was to Finland in February 2016. They were attended by a total of fifteen (15) participants from the Project Beneficiaries. The study tours were designed to expose participants to alternative institutional arrangements for implementing the EU’s Large Combustion Plant and Industrial Emissions Directives. Also, to provide an opportunity – assisted by LCP site visits - to see how LCPs may be operated in compliance with these Directives; and to enhance their technical understanding of emissions prevention and control technologies and monitoring / reporting systems. In addition, the programmes were designed to provide opportunities for participants to discuss LCPD / IED implementation arrangements, structures and issues with their EU counterparts – in the Ministries of Environment and Regional Agencies in particular. Participants evaluated both study tours. Overall, they gave ‘satisfactory’ to ‘good’ scores with the exception of scores for logistics and accommodation that received just ‘sufficient’ scores on average. The accommodation was selected in line with the criteria in the project Terms of Reference (ToR) but, according to the received evaluation forms, it was not to the satisfaction of all participants. The study tours were successful in achieving the objective of helping participants to understand the institutional structures in Italy/Finland for implementing legal requirements related to large combustion plants – scores of 8.8 and 9.0 out of ten respectively for Italy and Finland. But their success in helping participants to better understand the challenges to be faced by Turkish institutions was mixed: scores of 8.3 for the tour to Italy and 5.0 for the tour to Finland. The average conclusion of the participants who submitted evaluation forms scored ‘good’ on their perception that ‘the study tours were time well spent’. Observations made during the study tours will be kept in mind by the Consultant when preparing draft guidance materials, as part of project Component 3, that relate to implementing the LCP aspects of the Industrial Emissions Directive.


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1. Context of the study tours

The project ‘Technical Assistance for Better Air Quality by Transposing the Large Combustion Plant Directive’ aims to support Turkey in approximating towards the EU acquis in the sector of LCPs. The project’s overall objective is to improve the protection of human health and the environment in Turkey by implementation and enforcement of the EU’s Large Combustion Plant Directive. This overall objective will be reached through the project purpose that aims to support Turkey with establishing the necessary capacity to implement the LCP Directive in the country. In practical terms, this concerns the implementation of the new emission standards for LCPs, which under the EU’s new Directive on Industrial Emissions (IED) apply from the 1st of January 2016, replacing those previously applicable under the LCP Directive of October 2001. One of the project components (Result 3 as per ToR) is the definition of an institutional structure with procedural arrangements, and the development of technical capacity, for implementing the LCP Directive. To achieve this result four activities are being or have been implemented:

1. Suggest an institutional structure with procedural arrangements for LCPD implementation;

2. Implementation of a training programme;

3. Dissemination workshops;

4. Study tours.

This report refers to the work implemented under the fourth activity in the above list. For the work done under each of the other activities separate reports are prepared. The project ToR describe activity four (4) of component 3 as follows: ‘Consultant should organise two study tours to two different member states (in total) in which LCPD has been implemented for more than 5 years. The selected MSs should also be ones that report their emission inventory containing EVs of LCPs to the E-PRTR via Reportnet regularly for the last two years. For the selection of the MS to be visited, and other details, the main beneficiary will make the final decision. During the study, in order to increase the awareness regarding the LCPD, the participants could visit the department of the MS that is dealing with the environment (i.e. environment agency or equivalence) where they could be informed about the structure of the department, system established for the inventory of LCPs, reporting mechanism to EEA in scope of LCPD and so on. In addition, participants should be able to visit an LCP to identify how the LCPD is implemented, what and how the reporting is realised, the control mechanisms to meet the requirements of the LCPD, and so on.’ The ToR then refer to ‘Table 1’ for further workshops details. Table 1 includes the following text:

Study Visits

Two at least one-week long study tours should be organized to at least two different EU countries, which should

have been EU members since 2000, and where the EU LCP and IPPC Directives have been successfully

implemented (LCPD has been applied for more than 5 years and their emission inventory containing EVs of LCPs

has been reported regularly to the E-PRTR via Report.net for the last two years). The tours should occur at the

time of RIA preparation if possible. The participants should visit the authorities that are responsible for the

implementation of LCPD, IPPCD and, if available, cleaner production centres and organisations carrying out

practical activities in this field.

[The study tours should be attended by] two different groups of 10 persons involved in the implementation of the

project and the representing personnel of all the Beneficiaries, mostly in MoEU.


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Involved experts: 2 key experts

Locations: should be determined accordingly.

In ‘Table 2’ on page 23 of the project ToR, under 2.3, it is furthermore described that ‘It is expected that Consultant should prepare short report following each facilities like workshops, trainings and study tours including overall assessment of the related activities, important points to be noted, problems and appropriate solutions regarding the encountered problems, participants list, main aim of the activity and so on.’ In fulfilling this ToR requirement, two five-day study tours have been implemented:

1. Italy (Milan and Rome) 22-26 June 2015

2. Finland (Helsinki) 22-26 February 2016

This Study Tours Report collects and describes all information for the two Study Tours in a coherent and accessible manner to allow readers to have a full overview of the visits that were undertaken as an integral part of project component 3.


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2. Study tours preparation and logistical aspects

First drafts of the programmes of each of the two 5-day Study Tours were drawn up by the Consultant, submitted for comments to the main Beneficiary - the MoEU - and adjusted according to their comments received. At an early project stage the Consultant planned dates and locations for the project study tours which were submitted to the Beneficiary for approval. Based on their comments some adjustments were made to the planning. It was agreed that the Study Tours would be organised as per the table below.

Name workshop Date Location

Study tour 1 22 – 26 June 2015 Italy: Milan and Rome

Study tour 2 22 – 26 February 2016 Finland: Helsinki

As per project ToR the Consultant took care of all travel and accommodation arrangements. These arrangements were preceded by the following steps:

Suggestions of the Consultant to the main Beneficiary regarding possible study tour participants;

A List of Invitees compiled by the main Beneficiary, sent to the Consultant;

An Invitation Letter sent out by the main Beneficiary to all persons/institutions on the List of

Invitees, requiring the invitees to get administrative approval from their institutions if they wished to participate;

Administrative follow-up by the Consultant taking reactions with an interest to participate received

from invitees;

Final accommodation and travel arrangements were made by the Consultant for those invitees

expressing a wish to participate and having administrative approval to do so. The table below respectively shows the numbers of persons invited as per List of Invitees of the main Beneficiary, the number of invitees that reacted showing their positive interest to join the study tour, and the number of invitees that were actually present as per travel and accommodation lists. It furthermore shows the number of study tour participants coming from the various public institutions other than the main Beneficiary. Two officials from EÜAŞ, and one from MENR, were interested to participate in the study tour to Finland. However, they were unable to get official approval from their Ministry in time, so were not able to attend this study tour.

Name workshop

Number of invitees On List

of Invitees

Interested to

participate

Present at the Tour

From MoEU

From MENR

From EÜAŞ

Privatisation Authority

Study tour 1 - Italy

9 9 9 4 1 3 1

Study tour 2 - Finland

10 9 6 6 0 0 0

Total 19 19 15 10 1 3 1


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3. Study tour programmes

For each study tour programme, the Consultant provided a proposal. Each of these proposals was adjusted in line with the comments received from the main Beneficiary. The workshop programmes are included at the beginning of Annexes A and B to this Report. The programmes comprised presentations and interactive sessions with speakers from the host organisations and visits to large combustion plants in the electricity generation sectors of the two countries. The participants in each study tour were accompanied by two project experts (Dr Russell Frost and Mrs Darinka Belić), who were present throughout. Staff of AMEC Foster Wheeler Milan and Helsinki also accompanied the study tours, in Italy and Finland respectively. The programmes of each study tour were designed with four main objectives in mind:

1. Gaining an understanding of the institutional structures in Italy and Finland for implementing legal requirements related to large combustion plants.

2. Improve the participants’ understanding of the institutional responsibilities and structures required for the transposition and implementation of the EU acquis regarding LCPs.

3. Help participants to better understand the potential challenges to be faced by Turkish institutional structures in control of LCP operations

4. Strengthening the participants’ technical understanding of how large combustions plants operate

in the EU. The programme for Study Tour 1 was supported by presentations and two site visits. See below for the institutions visited, speakers and topics/visits:

Speaker Organisation Topic

Mr. Massimo Zanasso AMEC Foster Wheeler Implementation of Industrial Emissions Directive (IED) in

Italy

Mr. Silvio Arienti AMEC Foster Wheeler Coal-fired cogeneration plant (steam and electricity) for

Eural Energy using circulating fluidised bed combustion and

SOx control technology: design experience

Mr. Franco Gasparino AMEC Foster Wheeler Voghera Energiia combined cycle gas turbine plant:

permitting aspects

Mr. Fabio Romeo ISPRA, on behalf of the Ministry of

Environment, Land and Sea

Large Combustion Plants: legislation and legislative aspects

Ms. Nicoletta Valeria

Trotta

ISPRA, on behalf of the Ministry of

Environment, Land and Sea

Overview on IPPC/IED implementation in Italy focused on

Large Combustion Plants (2001/80/EC – 2010/75/EU

(Chapter III – Annex V)

Mr. Mario Nova Director, DG Environment, Energy

and Sustainable Development,

Lombardia Regione

Welcome address

Mr. Fabio Colonna ARPA Lombardia (Environmental

Protection Agency of Lombardy),

on behalf of Lombardia Regione

The regulatory framework and environmental context in

Lombardy

Mr. Paolo Lopinto Innovhub, SSI Emission monitoring under 2010/75/EU (IED)

Mr. Roberto Canobio DG Environment, EESD Energy and

Grids Department, Lombardia

Regione

Liberalization of the energy markets in Italy and the role of

Lombardy Region

Ms. Maria Teresa

Cazzaniga ARPA Lombardia, on behalf of

Lombardia Regione

Environmental Data: Public Access to information


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Mr. Claudio Zanelli Representative of Health, Safety

and Environment Department, ENI

Sannazzaro: petroleum oil refinery

Sannazzaro oil refinery: overview of the plant, its

combustion units and emissions performance

Mr. Marcello Pasquale

with the support of

AMECFW staff (Mr.

Silvio Arienti and Ms.

Rosella Cerioli)

Plant manager, Voghera Energiia

CCGT Plant

Verbal prese tatio o the CCGT pla t’s desig , operatio al performance and the challenges faced.

Facility Date of Site Visit

ENI Sannazzaro: petroleum oil refinery Wednesday 24 June 2015

Voghera Energiia: combined cycle gas turbine (CCGT) power

generation plant

Voghera Energiia: combined cycle gas turbine (CCGT) power

generation plant

A copy of the slideshows that were used during the above presentations can be found in Annex A to this Report. The programme for Study Tour 2 was supported by presentations and two site visits, the latter to coal-fired plants. A large pilot-scale facility for the thermal processing of biomass (Bioruukki) was also visited. See below for the institutions visited, speakers and topics/visits

Speaker Organisation Topic

Mr. Markku Kostamo AMEC Foster Wheeler, Espoo AMEC FW Global Power Group Company overview

Mr. Kalle Nuortimo AMEC Foster Wheeler, Espoo Environmental legislation changes & effect in Europe

Ms. Hannele Pokka Secretary General, Ministry of

Environment, Urbanisation and

Agriculture (MoEUA)

Welcome address: introduction to environmental legislative

developments in Finland

Ms. Oili Rahnasto Ministerial Councellor, Head of

Unit, Emissions and Risks, MoEUA

General presentation of the Ministry of the Environment

Mr. Jaakko Kuisma Senior Specialist, MoEUA Air pollution control in Finland

Ms. Anneli Karjalainen Ministerial Adviser, MoEUA LCP Directive (2001/80/EC) and NERP - implementation in

Finland

Mr. Teemu Lehikoinen Senior Adviser, Regional State

Administration Agency for

Southern Finland

Environmental permitting

Mr. Jyri Seppälä Director, Centre for Sustainable

Consumption and Production

(CSCP) of the Finnish

Environmental Institute (SYKE)

Finnish Environmental Institute (SYKE)

Mr. Kimmo Silvo CSCP, SYKE Pollution prevention and control roles of SYKE, Centre for

Sustainable Consumption and Production (CSCP)

Ms. Kristina Saarinen Air Emissions Team of CSCP, SYKE LCP emission inventory

Mr. Kaj Forsius SYKE Best Available Techniques (BAT) Information Exchange Role

of SYKE: LCP BREF process

Mr. Niko Karvosenoja Air Pollution and Climate Change

Mitigation group, SYKE

Integrated assessment modelling (IAM) of fine particulate

matter (PM) in Finland

Mr. Ilkka Hiltunen VTT, Technical Research Centre of

Finland

VTT in brief and Bioruukki Piloting Centre

Ms. Tuula Pellikka VTT, Technical Research Centre of

Finland

Finnish emission monitoring procedures

Mr, Matti Nieminen, VTT, Technical Research Centre of Combustion process development


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presenting on behalf of

Mr. Toni Pikkarainen

Finland

Mr. Lars Kjäldman Research Team Leader, CFD

Modelling, VTT Technical Research

Centre of Finland

Utilization of Computational Fluid Dynamics (CFD) modelling

to design low-NOx combustion

Mr. Markku Saukkonen HELEN, Salmisaari Welcome to HELEN (Helsinki Energiia)

Ms. Henrietta Lahti HELEN, Salmisaari Salmisaari A and B plants (coal-fired electricity and heat

generation)

Ms. Anna Häyrinen HELEN, Salmisaari Emission monitoring and reporting at HELEN

Mr. Reima Rynö HELEN, Salmisaari Reduction of NOx emissions in coal power plants: Salmisaari

SCR and Hanasaari SNCR

Mr. Pekka Karjalainen Vantaan Energia Vantaan Energia: introduction

Mr. Samuli Bjorkbacka Vantaan Energia Martinlaakso power plant (coal-fired, electricity and heat

generation)

Mr. Pekka Karjalainen Vantaan Energia Cooperation with public authorities

Facility Date of Site Visit

HELEN, Salmisaari B coal-fired generating plant Tuesday 23 February 2016

Vantaan Energia: Martinlaakso coal-fired generating plant Thursday 25 February 2016

VTT, Bioruukki Piloting Centre for biomass thermal processing Friday 26 February 2016

A copy of the slideshows that were used during the above presentations can be found in Annex B to this Report.


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4. Implementation and evaluation of the study tours The study tours were implemented according to schedule, although with some flexibility as concerns the timing of the different topics, to allow for putting accents and having more in depth discussion on topics of interest to the audience. During each of the study tours consecutive translation was provided. In general, question and answer sessions were held after each presentation, though in most cases spontaneous exchange of thoughts occurred during the presentations. The Consultant moderated sessions where helpful to stimulate discussion and raise pertinent questions on behalf of the participants. Each study tour commenced with a country and technical overview provided by AMEC Foster Wheeler’s country experts. These introductory sessions were helpful in providing a context for subsequent meetings with institutions and site visits. The study tours included meetings with the Ministries of Environment and subsidiary environmental regulatory institutions in both Italy and Finland. This helped the participants to understand and consider the arrangements for LCPD implementation in these countries. Site visits were also arranged (see the programmes), which enabled participants to exchange views with operators and obtain a broader understanding of the issues at stake. Both study tours were evaluated, receiving overall ‘satisfactory’ to ‘good’ scores with the exception of scores for logistics and accommodation that received just ‘sufficient’ scores on average. The accommodation was selected in line with the criteria in the project Terms of Reference (ToR) but, according to the received evaluation forms, it was not to the satisfaction of all participants. The study tours were successful in achieving the objective of helping participants to understand the institutional structures in Italy/Finland for implementing legal requirements related to large combustion plants – scores of 8.8 and 9.0 respectively for Italy and Finland. But their success in helping participants to better understand the challenges to be faced by Turkish institutions was mixed: scores of 8.3 for the tour to Italy and 5.0 for the tour to Finland. The average conclusion of the participants who submitted evaluation forms scored ‘good’ on their perception that ‘the study tours were time well spent’.

Study tour

Participants

Present on the

study tour

Evaluation forms

submitted

Av. score for study

objectives

Average score for quality

Average score for ‘Time well

spent’

Average score for logistics

Overall average

score

1 - Italy 9 9 8.1 6.6 7.1 5.3 7.4

2 - Finland 6 6 7.3 7.8 9.0 6.0 7.6

Total 18 15 7.7 7.2 8.1 5.7 7.5

Table. Overall evaluation results Study Tour. Scores represent numbers on a scale of 1 to 10

Detailed evaluation scores for each study tour have been included in Annexes A and B of this report and were also annexed to the project’s Progress Reports 4 and 7.


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5. Conclusions and recommendations

Conclusions 1. The study tours have contributed to a better understanding within public administrative institutions of

the institutional framework and responsibilities for the environmental regulation of large combustion plants in two mature EU Member States;

2. Participants observed how LCPs should operate in accord with LCPD / IED and of their emission reporting requirements;

3. The study tours have contributed to strengthened understanding on a range of technical aspects in practice related to LCPD / IED implementation including: BAT for NOx control, especially primary

NOx control measures under variable load conditions and the advantages / disadvantages of SCR and SNCR for secondary NOx abatement; flue-gas desulphurisation technologies; using biomass as a (partial) feedstock to LCPs; Transitional National Plans; underground storage facilities (for coal feedstock); the common-stack approach; other aspects of BAT selection; and the assessment of whether monitored emissions comply with ELVs;

4. Representatives of the different public administrative institutions (environment, energy and privatisation) entered into dialogue during the study tours and built on their network contacts;

Recommendations 1. Utilise the observations made on the study tours to develop guidance materials, as part of project

Component 3, that relate to the process of implementing the LCP Directive / IED, the Flexibility

Mechanism, ELV guidance and BAT for LCPs.

2. Participants are encouraged to disseminate the knowledge they have gained from these study tours to others in their respective public administrative institutions.


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ANNEX A Study Tour 1, Italy (22 – 26 June 2015)

PROGRAMME


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21


22


23

PRESENTATIONS

EURAL Energy – New co-generation plant


24


25


26


27


28


29


30


31


32

IED Directive in Italy


33


34


35


36


37


38


39


40


41

Voghera Energia – 400 MW Combined Cycle Power Plant


42


43


44


45


46


47


48


49

Environmental data: public access to information


50


51


52


53

Emissions monitoring


54


55


56


57


58


59


60


61


62


63


64


65


66

Regulatory framework and environmental context in Lombardy


67


68


69


70


71


72


73


74


75


76


77


78

Liberalisation of the energy market in Italy and the role of Lombardy region


79


80


81


82


83


84

Sannazaro Refinery


85


86


87


88


89


90


91


92


93


94


95


96


97


98


99


100


101


102


103


104


105


106


107


108


109


110


111


112


113


114


115


116


117


118


119

ISPRA – Large Combustion Plants


120


121


122


123

Overview of IPPC/IED implementation in Italy


124


125


126


127


128


129


130


131


132


133


134


135


136


137

PARTICIPANTS

Name and Surname Title Institution Telephone

Number

E-mail Address

1 Ülkü Füsun ERTÜRK

Head of the Division

Ministry of Environment and

Urbanization

0312 586 30 32

[email protected]

2 Derya

SARIOĞLU

Chemist Ministry of

Environment and

Urbanization

0312 586 31 53

0530 281 45 24

[email protected]

3 Sezin ÇALIK

ÇEPE

Expert Ministry of

Environment and

Urbanization

0312 586 31 46

0505 811 81 48

[email protected]

4 Nazan ÖZYÜREK Expert Ministry of

Environment and Urbanization

0312 586 32 94

0530 284 04 15

[email protected]

5 Ayhan

KABAKTEPE

Head of the

1st Project

Department

Group

Privatization

Administration

0 312 585 83 25

0 532 714 38 44

[email protected]

6 Tolga YILDIZ Head of the

Department

Electricity

Generation

Company

0 532 473 85 72 [email protected]

7 Selma SEVGÖR Electricity Generation

Company


8 Ayberk KIRBIYIK Electricity

Generation

Company


9 Ergün KOÇ Engineer Ministry of

Energy and

Natural

Resources

0 312 212 64 20

/7615

[email protected]


138

PHOTO IMPRESSION OF THE STUDY TOUR


139

EVALUATION

Evaluation STUDY TOUR 1, 22 – 26 June 2015, Italy

Statistical Information

1.1 Workshop Study Tour 1 - Italy

1.2 Name and Surname of Participant (evaluator)

OVERALL SCORE

Your expectations

Please indicate to what extent specific expectations were met, or not met:

My Expectations

My expectations were met Scor

e Fully

(10 points) Partially

(5 points) Not at all (0 points)

(80)

8.8

1. Understanding of the institutional structures in Italy regarding development and implementation of legal requirements related to large combustion plants.

IIIII II (70)

II

(10)

(75)

8.3 2. The Study tour has helped

to better understand the institutional responsibilities and structures required for the transposition and implementation of the EU acquis regarding LCPs.

IIIII I (60)

III (15)

(75)


to better understand the potential challenges to be faced by Turkish institutional structures in control of LCPs operations.

IIIII I (60)

III (15)

(65)

7.2 4. The Study tour has

strengthened the technical understanding on how large combustions plants operate in the EU.

IIII

(40)

IIIII (25)

8.1 AVERAGE TOTAL SCORE


140

Seminar and Presentations Please rate the following statements in respect of this study tour:

Score Aspect of Workshop Excellent

(10) Good

(8) Average

(6) Acceptable

(4) Poor (2)

Unacceptable (0)

(60)

6.6

1. The study tour achieved the objectives set

IIIII (40)

II

(12)

II

(8)

(56)

6.2

2. The quality of the study tour was of a high standard

IIIII (40)

I

(6)

II

(8)

I

(2)

(66)

7.3

3. The content of the study tour was well-suited to my level of understanding and experience

I

(10)

IIIII (40)

II

(12)

I

(4)

(56)

6.2

4. The study tour was interactive and networking could be achieved

II

(10)

III

(24)

III

(18)

I

(4)

(66)

7.3

5. The facilitators were well-prepared and knowledgeable on the subject matter

I

(10)

IIIII (40)

II

(12)

I

(4)

(66)

7.3

6. The duration of the different components of the study tour were neither too long nor too short

I

(10)

IIIII (40)

II

(12)

I

(4)

(48)

5.3

7. The logistical arrangements (accommodation, meals, refreshments, equipment) were satisfactory

IIII

(32)

I

(6)

I

(4)

III (6)

(64)

7.1

8. Attending this study tour was time well spent

I

(10)

IIIII (40)

I

(6)

II

(8)



141

Comments and suggestions

Study tour Sessions:

Duration of Question-Answer periods could be longer.

It is appropriate for studies, permits, evaluations, and those who prepare report, make decision on the issues to be present during trainings; in addition to that, it may be more beneficial for experts who conduct, examine these studies, take duty in decision making mechanism on the side of Turkey, to take part in direct applications for longer time for information and experience transfer.

Presentations related to issues were pretty successful.

Study tour sessions have been satisfactorily successful, especially those to LCP’s in Italy, and subjects on how and based on which directives they have been managed. Presentations were pretty explanatory and informative. Also, the matters on how existing institutions work and how they make their inspections were adequately understandable.

Meetings sessions with competent authorities, Ministry and Regional administrations could be longer.

We have learned from presentations what institutions are involved in IPPC applications (and how these institutions have been formed). However, it was observed that a procedure and time list do not exist as in Turkey, and this varies in accordance with the characteristics of the installation. It was understood that local, National authorities and committees forward the matter to Ministry in this order. However, there exist other issues such as; at what stage the unaccepted matters go to an upper institution, and if the application should be initiated from the beginning again or not. How does a plant owner follow these procedures? Maybe, permit application of an X company could be explained as an example. In Turkey, time and procedure standards can be seen in one chart. And this provides convenience for plant owner very much. Of course, Italy has developed the best system under all those experiences. However, through this example, we could better understand these transitions and the one that performs a more effective control. Note: I wrote these comments within a limited time. I apologize for grammatically incorrect and imperfect sentences. I would like to thank all of those who provided this experience to us and to all participants.

During sessions, more time could be reserved for question-answer periods. Allowing short period of time for questions or pressure on asking the questions at the end of presentations were not nice at all.

Trip to refinery was not efficient at all. Authorized staff of plant should be informed about the content and expectations. The presentation was away from our focus point and was in detail. As asking questions have insistently been prevented (by project expert) (by showing time limitation as an excuse), we did not have a chance to guide (direct) the subject and the time was used inefficiently.

Everything was OK about sessions. Hotel accommodations were strict for us. It was too far from central. We couldn’t manage time arrangement, in relax time.

Facilitators:

Facilitators were satisfactory in both accommodation and transfer issues. However, I

believe that it is beneficial to review the matters such as quality and vicinity to city center in the selection of accommodation places, once again.

Our hotel in Milan had surely been selected because of its close location to Amec

Foster Wheeler. However, service was very poor in all areas.

Since hotels in Milan and Rome were pretty away from city center, we have spent


142

most of our time on transportation. Hotels at central locations could be preferred.

The hotel in Milan was out of town and had hygiene problem. The third morning, I

woke up with bites of insects. I learned from the reception that it might be an insect coming from wood furniture in the room (I think it is chinch/bedbug). The receptionist changed my room with a reserved room for someone else who is going to start staying at the hotel, and this was a careless approach to continue to use the room

with insect. The hotel in Rome was clean and beautiful, but away from city center. „As the most important”, the other factors in the organization (food, payments etc.) should be shared with participants a week or weeks before the tour and necessary adjustments should be made in common sense. Otherwise, during site visit, it is dealt with making the decisions, changing, discussing, adjusting and uncertainty. This

steals from time and efficiency.

Facilitators have helped to better understand the EU practices. But, I have expected

to see thermal power plant facilities especially based on coal.

Study tour level and content:

Sufficient

I think the level and content of the study tour were satisfactory. However, I believe

that it is especially necessary that the study group should be supported with private sector.

As the tour was very fine, a site trip to a thermal power plant could also be arranged.

The presentations and sincerity during our site visits were very successful. Of course,

we had our experiences all on Thermal power plant area. A visit to a Thermal power plant could be useful, as well. It was understood that there wasn’t a Thermal power plant in close proximity geographically. I hope, this group may have a chance to visit

such a plant next time. May a regional competent authority officer, a plant owner accompanies our group? (During the visit)

I would like to talk especially about: When presentations and site visits are over, it

could be much more efficient to make a meeting (maybe for 1-1,5 hours) that our group members may share their opinions and suggestions, the experience they gained on the day’s activities. At the same time, we could be prepared prior to tomorrow’s (next day’s) presentation based on our branches.

More plant visits could be arranged.

Natural Gas Combined Cycle Plants are in the same condition in our country. We

have visited the sister plant of this one in Ankara, and the one with a very similar

technology in İzmit. If we could visit a solid fuel combustion plant using coal instead of natural gas, it could be more beneficial. On the other hand, visit to refinery was not efficient. Meetings with official institutions and the one at AMEC FW were very good, but the plant visits were not satisfying.

The study tour has helped to better understanding on how large combustion plants

operate in EU and especially in Italy with technical guys and samples.


143

ANNEX B Study Tour 2, Finland (22 – 26 February 2016)

PROGRAMME


144


145


146


147

PRESENTATIONS

AMECFW – Company Overview


148


149


150


151


152


153


154


155


156


157


158

EU environmental legislation changes and their effects


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161


162


163


164


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167


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169


170


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173


174


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176


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180

Air pollution Control in Finland


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186


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188

Environmental permit


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190


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192

LCP Directive and NERP – Implementation in Finland


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198

General presentation of the Finnish Ministry of Environment


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200


201

HELEN Ltd. Towards a carbon neutral future


202


203


204


205


206


207


208


209

Salmisaari Power Plants


210


211


212


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214


215


216

Emission monitoring and reporting at HELEN


217


218


219


220

Reduction of NOx emissions in coal power plants


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223


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228


229


230


231


232


233


234

Information exchange role of SYKE – LCP BREF process


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236


237


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239


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241

Integrated assessment modelling of particulate matter in Finland


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245


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248

Roles of SYKE


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255

Finnish Environmental Administration


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265


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268

LCP Emission Inventory


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272

Finnish Environmental Institute - SYKE


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Vantaa Energy


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285

Co-operation with authorities


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VTT – Technical Research Centre of Finland


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Utilisation of CFD modelling to design low NOx combustion


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Combustion process development


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Finnish Emission monitoring procedures


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PARTICIPANTS

Name and Surname Title Institution Telephone

Number

E-mail Address

1 Mr. Mücahit

De irtaş

Deputy

Under-

secretary

Ministry of

Environment and

Urbanization

[email protected]

2 Mrs. Çiğde Bayrak

Deputy Chief of

Cabinet

Ministry of Environment and

Urbanization

[email protected]

3 Mrs. Ülkü

Füsun Ertürk

Head of

Division

Ministry of

Environment and

Urbanization

0312 586 30 32 [email protected]

4 Mrs. Sezi Çalık Çepe

Expert Ministry of

Environment and

Urbanization

0312 586 31 46

0505 811 81 48

[email protected]

5 Mrs. Nazan

Özyürek

Expert Ministry of

Environment and

Urbanization

0312 586 32 94

0530 284 04 15

[email protected]

6 Mrs. Elifcan

Ka atlı Apaydı Expert Ministry of

Environment and

Urbanization

0312 586 31 43 [email protected]


321

PHOTO IMPRESSION OF THE STUDY TOUR


322

EVALUATION

Evaluation STUDY TOUR 2, 22 – 26 February 2016, Finland

Statistical Information

1.1 Workshop Study Tour 2 - Finland

1.2 Name and Surname of Participant (evaluator)

OVERALL SCORE

Your expectations

Please indicate to what extent specific expectations were met, or not met:

My Expectations

My expectations were met Score Fully

(10 points) Partially

(5 points) Not at all (0 points)

(55)

9.2

5. Understanding of the institutional structures in Finland for implementing legal requirements related to large combustion plants.

IIIII (50)

I

(5)

(40)


to better understand the institutional responsibilities and structures required for the transposition and implementation of the EU acquis regarding LCPs.

II (20)

IIII (20)

(30)


to better understand the potential challenges to be faced by Turkish institutional structures in control of LCP operations.

IIIII I (30)

(50)

8.3 8. The Study tour has

strengthened the technical understanding on how large combustions plants operate in the EU.

IIII

(40)

II

(10)



323

Study tour and Presentations Please rate the following statements in respect of this study tour:

Score Aspect of Workshop Excellent

(10) Good

(8) Average

(6) Acceptable

(4) Poor (2)

Unacceptable (0)

(50)

8.3

9. The study tour achieved the objectives set

II

(20)

III

(24)

I

(6)

(44)

7.3

10. The quality of the study tour was of a high standard

I

(10)

III

(24)

I

(6)

I

(4)

(46)

7.7

11. The content of the study tour was well-suited to my level of understanding and experience

II

(20)

I

(8)

III

(18)

(42)

7.0

12. The study tour was interactive and networking could be achieved

I

(10)

II

(16)

II

(12)

I

(4)

(50)

8.3

13. The facilitators were well-prepared and knowledgeable on the subject matter

III

(30)

I

(8)

II

(12)

(52)

8.7

14. The duration of the different components of the study tour were neither too long nor too short

III

(30)

II

(16)

I

(6)

(36)

6.0

15. The logistical arrangements (accommodation, meals, refreshments, equipment) were satisfactory

I

(10)

III

(18)

II

(8)

(54)

9.0

16. Attending this study tour was time well spent

IIII

(40)

I

(8)

I

(6)



324

Comments and Suggestions

Study tour Sessions:

There was some trouble about translation. Due to constant changing of project’s language assistants, translator had difficulty in some translations. Although this issue is indicated before, recruitment of an expert translator is not done. The sessions were good. Especially at VTT, really nice information was given.

The duration of the sessions was sufficient and relevant with the Study Tour. From the institutions and organizations which are visited, some evaluations relevant to project were taken. Pretty good.

Facilitators:

The team has comprehensive knowledge about the subject and they are eager.

Extremely successful.

The translator could be better. A better hotel could be arranged. The hotel rooms

were too small, cold and far away from the city.

There was some trouble about translation. Translation has not been made

completely. Some of the subjects were passed without completely translated- briefly. There was a brief translation in technical subjects which were explained in detail.

Logistic opportunities and organization should be more satisfying.

Generally, organization team has sufficient background relevant to study tour aims.

There were some minor flaws about car organization and translation.

Study tour level and content:

I took quite an advantage even if I don’t know the subject at all. Good.

Some technically useful facilities were visited.

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