MCPD and Specified Generator Controls

5 Jul 2018 02:41 PM

Comments to submit to the Environment Agency on their guidance for MCPD and Specified Generator Controls.

Introduction

techUK is pleased to provide feedback on the draft guidance for MCPD and Specified Generator Controls, from the perspective of data centre operators.  We estimate the total generating capacity of the sector to be in the range of 2GW in the form of emergency backup plant.  The operating profile is to test plant for about 30 minutes a month with a full load test at least once a year.  A few operators engage in demand side response activities though this is not widespread.  Some operators have IED installations.  Generator size is usually above 1MWth and below 20MWth.

MCPD

In general the guidance provides welcome clarification on the legislation.  There are only three issues that we have identified.  The first relates to the way that operating hours have been defined which we disagree with.  The second and third relate to permitting conditions and AQMAs where were need further clarification regarding what is expected for plant that is exempt from meeting ELVs.

Operating hours:

For sites with a large number of generators, the requirement to count all hours of operation irrespective of how many plant are running is in conflict with BAT which requires plant to be run sequentially.  A site with multiple generators running plant sequentially as required by BAT could exhaust the 500 hour threshold very quickly within the testing regime, despite the fact that this plant is not intended to be within regulatory scope.  This will be extremely problematic for data centre operators and is not in line with the purpose of the regulation.  Early feedback from counterparts overseas indicates that this approach is also inconsistent with that taken by other members states.  The hours should be counted by flue, stack or individual plant, not by “anything running”.   There is also an apparent inconsistency between this paragraph which refers to hours counted from 1 January and section 5 which states that counting should be conducted from point of permitting and not by calendar year.

Permits

We understand that emergency back-up generators of the type deployed in data centres and operated for fewer than 500 hours a year are exempt from ELVs but will still need permitting.  We need further clarification on the permit requirements for such plant as opposed to plant that is required to meet ELVs.  The permit requirements will presumably vary in areas like monitoring. 

AQMS

Many data centre MCPs are located in AQMS although they are operated for fewer than 500 hours.  Individual units are tested for fewer than 50 hours.   Further clarification is needed for emergency back up plant located in AQMS and the associated permitting requirements/ degree of exemption. Is emissions data needed for plant that is exempt from ELVs?  We think it will be impractical to obtain such data because the plant is run so infrequently and we would strongly resist a requirement for us to run plant purely to record emissions: we would view this as a perverse outcome.

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