Regulating power plant emissions from hydrogen combustion
02 October 2024
EUTurbines recommendations in the context of the European Industrial Emissions Directive,
October 2024
The European gas and steam turbine industry, represented by its industry association EUTurbines, promotes the use of hydrogen in power plants as pathway to a reliable dispatchable energy generation that complements the growing share of variable renewables in Europe’s electricity mix.
The European legislative framework regarding emissions from power plants sets fuel-specific Emission Limit Values (ELVs) that need to be considered by national permitting authorities. In today’s version of the relevant legal text, the BAT conclusions for Large Combustion Plants, hydrogen is not (yet) included as a fuel.
Through the concept of H2-readiness, the members of EUTurbines ensure that power plants are ready to use hydrogen as their primary combustion fuel. From political and customer-side there is a growing request for these “hydrogen-ready” plants, that are ready to switch from the use of natural gas to hydrogen as fuel, whenever this is possible and feasible for operators. This can only be ensured, when emission requirements are known, as they define the level of technical efforts and costs required.
EUTurbines therefore recommends to:
- Ensure a harmonised European approach to hydrogen as a fuel through a revision of the LCP BREF BAT Conclusions.
- For the interim period until the revision has taken place, European-wide guidelines for the permitting of hydrogen-ready power plants should be used, ensuring comparable and realistic emission requirements within the EU.
- Set the NOx limit values in a way that recognises that the volume-based measuring and calculation method developed for natural gas is not simply transferable for the combustion of hydrogen. A suitable approach, combining adapted volume-based ELVs with output-related data, is suggested in this paper.