[ ENERGY / IN DETAIL ]

[ ENERGY / IN DETAIL ]

Emission guidelines and fuels

A U T H O R : J o h a n B o i j , S e n i o r M a n a g e r, R e g u l a t o r y A f f a i r s , P r o d u c t C e n t r e E c o t e c h

Clean air is a basic requirement of

human health. Ambient Air Quality
(AAQ) standards vary widely
around the world due to different
approaches to balancing health risks,
technological feasibility, economic
considerations, and various other
factors.

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Leading international investment banks

today require, as a minimum, compliance
with the IFC (International Finance
Corporation) and World Bank EHS
(Environmental, Health and Safety)
Guidelines and Performance standards.
This is in accordance with the Equator
Principles agreement with the IFC,
the private arm of the World Bank,
and individual business policies. Social
and environmental considerations are
integral parts of good business practice.
Many other nancial institutions (via
environmental and other policies) are, in
addition to national norms, also using
the IFC/World Bank Group Guidelines
in their projects. A project shall full
the more stringent of either the national
ruling or the IFC EHS Guidelines.
In many locations around the world,
the existing fuel infrastructure is still such

that only high sulphur HFO (Heavy

Fuel Oils) or other high sulphur fuels are
commercially available for
power production.
In order to comply with the specied
emission limits of the EHS Guidelines,
therefore, secondary emission abatement
equipment is needed in such cases. In
some places, due to existing conditions,
this might be extremely dicult.
According to the Thermal Power Plants
EHS Guidelines [1]: The applicability
of the EHS Guidelines should be tailored
to the hazards and risks established for
each project on the basis of the results
of an environmental assessment in
which site-specic variables, such as host
country context, assimilative capacity
of the environment and other project
factors, are taken into account. i.e. the
EHS Guidelines contain exibility.

WRTSIL TECHNICAL JOURNAL 02.2011

SO2 limits: maximum S-wt-% in oil, (N)DA = (NoN)Degraded Air Shed

India 2002 for HFO outside big city area

IFC General EHS Guidelines =< 50 MWth plant (to be justied!)

3
2
1

India 2002 for HFO big city area/IFC Thermal Power Plants EHS Guidelines > 50. .< 300 MWth liquid plant NDA
EU 1999/32/EC, Portugal, France for HFO/IFC Thermal Power Plants EHS Guidelines >= 300 MWth liquid plant in NDA

IFC Thermal Power Plants EHS Guidelines > 50 .. < 300 MWth liquid red plant in DA

0.5

IFC Thermal Power Plants EHS Guidelines >= 300 MWth liquid red plant in DA

0.2
0.1

LFO = Light Fuel Oil

HFO = Heavy Fuel Oil

German TA-LUFT 2002, EU 1999/32/EC for diesel oil (LFO) and

US CI NSPS (Mainland US distillate, for displacement >= 30 liters/cylinder volume), June 2012
Note! In Territories HFO allowed

2002

2004

2008

2009

2014

2015

2016

2017

Fig. 1 Selected SO2 emission regulations worldwide.

In this article, a exibility mechanism

built within the IFC EHS Guidelines
is discussed. This might be useful in
locations around the world with a less
developed infrastructure, arid conditions,
or other severe impediments to show
that the achieved performance levels of
the individual project are suciently
protective of human health and the
environment, despite the fact that stack
emission levels deviate from those set out
in the EHS guidelines.
Fuel related emissions
SO2 (sulphur dioxide) is regulated because
of its detrimental health impact on
people, and its acidication eect on the
environment. Sulphur dioxide emissions
are, for the most part, directly proportional
to the sulphur content of the fuel oil used.
Airborne particulate matter (PM),

namely course fractions of PM10 (PM

below 10 microns in aerodynamic
diameter) and especially ne fraction
PM2.5 (PM below 2.5 microns in
aerodynamic diameter), has in recent years
received much attention because of the
adverse health eects and reduced visibility
impacts. These PM emissions are mainly
related to the ash and sulphur content of
the fuel oil.
By reducing stack emissions, the ambient
air quality is improved. As a consequence
of the external costs they impose on society,
there has been increasing global attention
on emissions. Dierent jurisdictions
around the world have gradually imposed
stricter emission limits, such as the latest
IFC EHS Guidelines update of 20072008.
SO2 and PM emissions can be reduced
by either primary or secondary abatement
measures.

Sulphur dioxide
A primary abatement measure consists of
replacing high sulphur/ash fuel oil with a
low sulphur/ash oil or natural gas fuel, if
commercially available. In Figure 1, the
SO2 emission limits in selected standards,
guidelines or national norms around
the world for power production are
indicated. As can be seen, the stipulated
SO2 emission limits reect, in many
locations, the sulphur content of the
locally commercially available fuel oil.
Available secondary abatement FGD
(Flue Gas Desulphurization) methods for
SO2 emissions abatement, include amongst
others:
O Wet scrubber types (CaCO3, NaOH)
O Semi dry methods
O Dry methods.

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PM limits (Measurement Standard: ISO 9096: 2003 if otherwise not mentioned)

3
Unit mg/Nm at 15 vol-% O2

(N)DA = (NoN) Degraded Air Shed

100

IFC General EHS Guidelines =< 50 MWth plant (to be justied) / India 2002 for HFO (> 800 kW unit)

Japanese (nation wide general limits, all area) / India 2002 for LFO (> 800 kW unit)
75
Japanese (nation wide general limits, special area) / Finnish Decree for 5 .. 50 MWth liquid red plant 2010
60
50

30

IFC Thermal Power Plants EHS Guidelines > 50 MWth plant NDA/ EU LCP BREF 2006 (HFO) /TA-LUFT 1986

French Arrete 1999 / IFC Thermal Power Plants EHS Guidelines in DA/EU LCP BREF 2006 (LFO)

LFO = Light Fuel Oil

HFO = Heavy Fuel Oil
German TA-LUFT 2002
7.5
2002

2004

2008

2009

2014

2015

2016

2017

Fig. 2 Selected PM (dry dust) emission regulations worldwide.

The IPPC (Integrated Pollution Prevention

and Control) approach should be used
when selecting the appropriate abatement
method for a specic project. All FGD
methods reduce the SO2-content of the
ue gas with dierent levels of eciency.
However, depending on the method
applied, they also create considerable
amounts of solid and/or liquid end
products that need to be recycled or
disposed of in an environmentally sound
way. Furthermore, energy, i.e. electricity,
which implies an additional GHG
(greenhouse gas) impact, reagents and,
for some processes, huge amounts of clean
water are also consumed.
Particulate matter
PM can be reduced by selecting a cleaner
fuel (see above), i.e. the primary method.
In Figure 2, selected PM limits
around the world are given.
The available secondary PM abatement
methods for large HFO red stationary
diesel engines are:
O ESP (Electrostatic Precipitator)
O Bag lter
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ESPs are preferred to bag lters in most

applications. Bag lters cause a signicant
pressure drop in the ue gas line, and
additional ue gas fans or other such
appliances are thus needed. These too are
parasitic consumers of large amounts of
electricity. Most of the lter materials used
in the bags require the engine ue gas to be
cooled, typically to below 160200C
depending on the material selected,
otherwise the material will be destroyed.
PM is sticky, and in order to minimize
the risk of clogging the lter, a protection
agent is recommended to be used, which
will increase the end product levels as well
as the operative & maintenance (O&M)
costs. ESP technology also has its challenges;
it increases the plants parasitic electricity
consumption and thus increases the specic
CO2 (g/kWhe) emissions of the plant.
However, the ESP electricity consumption
is small compared to the bag lter option.
For both alternatives (ESP/bag lters) the
PM removed must be environmentally
disposed of or re-used. Available options
depend on national legislation in force
and the existing infrastructure.

IFC Thermal Power Plants

EHS Guidelines
The EHS Guidelines [1] were issued in
December 2008. They are intended for big
power plants over 50 MWth thermal fuel
input based on higher heat value (HHV).
In Table 1 the emission limits set
for stationary reciprocating internal
combustion engines (RICE) are given.
From Table 1 it can be seen that
the liquid red stationary RICE plant
standard has a big plant threshold.
Emission limits are stricter for plants over
300 MWth (= roughly a 120 MWe single
cycle diesel engine plant). For example,
the fuel oil is to contain a maximum of
1 wt-% sulphur (S).
In the EU (European Union), a
maximum 1 wt-% S HFO is widely
commercially available. However, because
of the existing renery capacity, this is not
the case in many places around the world.
In many Middle East countries, for
example, a 1 wt-% HFO must in practice
be imported, on top of which the needed
importation infrastructure is missing in
many locations. A few reneries in the

WRTSIL TECHNICAL JOURNAL 02.2011

Liquid Fuel

NDA: > 50 MWth

NDA:

DA: > 50 MWth

DA:

3
PM emissions (mg/m , dry,
15% 02, 0 C & 1 atm)

50

50

300 MWth **

30

30

3
SO2 emissions (mg/m ,
dry, 15% 02, 0 C & 1 atm)
or wt-% S, N/A on biofuels.

1170 or max. 2.0% S

585 or max. 1.0% S

0.5% S

0.2% S

NOX emissions
(mg/m3, dry, 15% O2,
0 C & 1 atm)

- Diesel engine:
1460 (< 400 mm)
1850 ( 400 mm)
- Dual fuel engine: 2000
- Bio oils + 30%

- 740 (contingent upon

water availabilitys for
injection)
- Bio oils + 30%

400

400

Gas fuel

NDA:

DA:

3
PM emissions (mg/m , dry,
15% 02, 0C & 1 atm), for
other gases than natural gas

50

30

SO2 emissions (% S in fuel)

3
NOX emissions (mg/m , dry,
15% O2, 0C & 1 atm)

300 MWth**

200 (spark ignition)

400 (dual fuel)
*** (compression ignition (CI))
Other gases than
natural gas + 30%

- 200 (spark ignition

on natural gas)
- 400 (other)

Note: NOX limit is 30% higher for bio fuel than for fossil fuels in NDA
For liquid fuel DF engines (50 300 MWth) in NDA, technique-specic NOX limits are given

Table 1 . *The IFC Thermal Power Plants EHS Guideline limits for RICE plants.
*MWth based on Higher Heat value (HHV). (N)DA = (Non) Degraded AirShed
** Plants > 300 MWth CEMS (Continuous Emission Monitoring System) need for: Liquid fuel: NOX (Nitrogen Oxides) and SO2
(if FGD used) Natural gas: NOX
***Emission value should be evaluated on a case-by case basis through the EA process.

region produce HFO of 2 wt-% S grade.

Thus, the HFO commercially available
in many Middle East countries contains
typically 3.5 3.7 wt-% S, and is of high
ash quality. In order to full the SO2 and
PM emission limits in the above Table 1,
secondary abatement techniques, such as
FGD and ESP, would be needed. This will
cause very big challenges for the plant
developer, especially in remote and arid areas.
The IFC EHS Guidelines [1] include,
however, the following exibility option:
O Page 1: If less stringent levels or
measures than those provided in
these EHS Guidelines are appropriate
in view of specic project
circumstances, a full and detailed
justification for any proposed
alternatives is needed as part
of the site-specic environmental
assessment. This justification should
demonstrate that the choice for any
alternate performance levels is
protective of human health and
the environment.
O Page 20, the heading for emission table
6(A) states that the: EA (Environmental

Assessment) may justify more stringent

or less stringent limits due to ambient
environment, technical and economic
considerations, provided there is
compliance with applicable ambient
air quality standards and incremental
impacts are minimized.
Ambient air quality levels shall not exceed
relevant ambient quality guidelines and
standards by applying national legislated
standards, or in their absence,
internationally recognized sources, such as
the US EPA NAAQS (National Ambient
Air Quality Standard) or relevant European
Council Directives [2]. Hence, ambient
air quality compliance with national
standards is the starting point of
the guidelines exibility.
The IFC suggests that a single project
should not contribute more than 25% of
the applicable ambient air quality standards.
The text below shows how to proceed as
a function of plant increments [1]:
O - If incremental impacts predicted
by EA >= 25% of relevant short-term
ambient air quality standards or if the

plant is > = 1200 MWth;

Monitor parameters (e.g. PM10/
PM2.5/SO2/NOX to be consistent
with the relevant ambient air quality
standards) by a continuous ambient
air quality monitoring system
(typically a minimum of 2 systems
to cover predicted maximum ground
level concentration point/sensitive
receptor /background point).
O If incremental impacts predicted by EA
< 25% of relevant short term ambient
air quality standards and if the facility <
1200 MWth but >= 100 MWth:
Monitor parameters either by passive
samplers (monthly average) or by
seasonal manual sampling (e.g. 1 week/
season) for parameters consistent with
the relevant air quality standards.
In other words, if the plant increment
is >= 25% of the short term ambient air
quality standard, continuous ambient air
sampling is required. Otherwise, manual
seasonal/monthly passive sampling of
the ambient air in the surroundings of
the plant is sucient.

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Note !
The IFC recommendation for a single
plant AAQ CEMS is strict. In the EU,
continuous emissions monitoring of the
air-shed in the surroundings of the plant
is demanded, if the upper threshold depending on the pollutant and short/
long term ambient air quality limit,
which is typically 60 to 80% of the total
AAQ limit - is reached or exceeded.
[3]. This should be compared to the
IFC continuous emissions monitoring
trigger for AAQ monitoring, which is
set at 25 % individual plant increment
of the total ambient air quality limit.
Ground Level Concentration
(GLC) Calculations
In this chapter, the fundamentals of
professional GLC calculations are briey
explained.
It should be borne in mind that GLC
is a cumulative issue covering all polluters,
such as factories, cars and power plants,
contributing to the total pollutant level
of the surrounding air-shed. Furthermore,
weather conditions, such as wind direction
and speed, as well as the stack height and
conguration, and the surrounding
topography, also aect GLC. Transboundary pollution also contributes to the
resultant GLC. The plants contribution,
or impact, can be estimated by special
computer calculation programmes.
In order to calculate the total overall GLC,
the existing background level (contribution
from others, locally and trans-boundary)
should be added to the plant impact.
Therefore, GLC cannot be
guaranteed, as the above factors are not
entirely within the control of the plant
owner or operator.

The GLC in the vicinity of the plant

can be reduced using the correct stack
conguration and/or by reducing
the mass ows of emissions within
the stack. The following stack design
features will eectively decrease
GLC in the vicinity of the plant:
O Minimum stack height should be in
accordance with Good Engineering
Practice (GEP) or
Good International Industrial
Practice (GIIP), in order to avoid
downwash of the exhaust gas plume
in the power plants surroundings. In
most cases GEP or GIIP = 2.5 times
the height of the rectangular power
house building, assuming there are
no nearby interfering structures. For
more information see [2] page 16.
O The number of stacks should be
minimized by grouping them into
segments with equivalent stack
diameters. An example of a segmented
stack approach is shown in Figure 3.
In order to get the permissible
exceedences in the NAAQS excluded, and
access to real weather databases around
the world, the calculation should be
performed by a third party expert with
suciently advanced calculation
programmes. Progressive NAAQS contain
percentiles (permitted exceedences) e.g. per
year for short term immissions (e.g. 1 hour,
24 hours, etc.), to accommodate unusual
meteorological events. This makes
the standard more robust.
Note !
In ambient air quality outdoor monitoring,
the macro-scale testing is praxis in order
to exclude special micro topography e.g.
nearby small hills: Sampling points

should in general be sited to avoid

measuring very small micro-environments
in their immediate vicinity. As a guideline,
a sampling point shall be representative of
air quality in a surrounding area of no less
than 200 square metres at trac oriented
sites, and of several square kilometres at
urban background sites. [3].
Shown below are modelled GLC
calculations using real weather conditions
and topography for a HFO red big
stationary RICE plant example in
the Middle East.
In Table 2, the AAQ limits of the
country are listed. In the calculations, the
GLC limits of SO2 were shown to be more
dicult to full than the those for NO2
and PM. Therefore, only the SO2 GLC
calculation is discussed further below.
In Table 3 the calculated GLC (impact)
in comparison to the country standard
refers to a large stationary diesel
(9 unit) engine plant (8 engines producing
totally about 140 MWe for 8 months, and
all 9 engines producing about 150 MWe
for 4 months of the year).
The options were as follows:
O stack height of 45 m for a single
stack cluster case (all 9 engine stacks
grouped into one segmented stack).
Fuels 2.0 or 3.7 wt-% S HFO.
O stack height of 31 m for a single stack
cluster case (all 9 engine stacks grouped
into one segmented stack). Fuel 3.7
wt-% S HFO.
O a two segmented stack approach (one
cluster of 4 engine stacks and the other
with 5 engine stacks), 31 m stack height
and fuel 3.7 wt-% HFO.
The permitted exceedances (for short
term immissions), according to the
country standard, have been reduced

Fig. 3 Segmented stack (left)

consisting of three individual stack
pipes.

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WRTSIL TECHNICAL JOURNAL 02.2011

Pollutant

Averaging Period

Limit value ( g/m3)

Permitted exceedances

Sulphur dioxide (SO2)

1 hour
24 hours
year

730
365
80

twice per month

once per year
-

Nitrogen dioxide (NO2)

1 hour
year

660
100

twice per month

-

Particulates, (PM10)

24 hours
year

150
50

once per year

-

Particulates, (PM2,5)

24 hours
year

65
15

once per year

-

Table 2 Ambient Air Quality standard in example country.

Fuel sulphur
content 2.0%,
1 stack cluster,
stack height 45 m,
SO2 emissions 40.9
g/s

Fuel sulphur
content 3.7%,
1 stack cluster,
stack height 45 m,
SO2 emissions 75.8
g/s

Fuel sulphur
content 3.7%,
1 stack cluster,
stack height 31 m,
SO2 emissions
73.0 g/s

Fuel sulphur
content 3.7%,
2 stack clusters,
stack height 31 m,
SO2 emissions
73.0 g/s

Annual average

80

5.9

11

15

30

24-hour average

365

83

154

247

390

1-hour average

730

202

374

618

805

Table 3 A 140/150 MWe Heavy Fuel Oil stationary RICE plant (impact) modelled and compared to the applicable national
GLC (NAAQS) SO2 standard.

from the gures in the Table 3.

From the above simulation results,
the following can be concluded:
A. GLC drops substantially when changing
the design from a two cluster stack
arrangement to a single common
cluster.
B. Increasing the stack height from 31 m
to 45 m lowers the GLC.
C. In the single stack cluster 2 wt-%
S HFO case, the short term GLC
is slightly above 25% single plant

contribution threshold suggested by

IFC (about 27.6 % of the 1-hour
average SO2 NAAQS limit).
By increasing the stack height this
threshold would probably not be
exceeded.
D. IFC EHS Guidelines should require
continuous ambient air quality
monitoring in all the above modelled
cases. But, if the stack height in
the 2 wt-% HFO one stack cluster case
were to be raised above 45 m, manual

GLC monitoring would probably

become a viable alternative.
For both HFO qualities; 2 wt-% S /
3.7 wt-% S exceeding the IFC EHS
stipulated big plant 1 wt-% S limit; the
national ambient air quality SO2 limits
were fullled (with the single stack cluster
design for both stack heights). Performance
levels should thus be suciently protective
of human health and the environment.

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Technical and economic

justication aspects
In addition to showing that the NAAQS
has been fullled, a full and detailed
technical and economic justication is
also required in order to justify deviating
from the emission limits given in Table 1.
In many locations around the world,
water resources are rather limited. A water
preservative (air), radiator cooled (single
cycle), stationary RICE plant with primary
emission abatement methods is thus
a preferable choice for power production
in such areas.
In this chapter, some general aspects are
discussed for why higher SO2 limits than
those specied in Table 1, are justied.
The focus is only on SO2 in this article,
similar studies should also be made of other
pollutants, if needed, by the project
developer.

O To reduce project related

GHG emissions.
*pollution refers to both hazardous
and non-hazardous chemical pollutants
in the solid, liquid or gaseous phases.

Primary measures
As stated above, due to existing
infrastructures such as old reneries, and
crude oil with high sulphur content, etc.,
in many parts of the world, only high
sulphur HFOs are commercially available
for power generation. The importation
option might also not be viable because
of such infrastructure obstacles as a lack
of storage tanks in harbours, non-existing
pipelines, unsuitable roads, and similar.
The price of imported low sulphur/ash
fuel oil might also be too expensive where
the overall domestic demand is low.

Feasibility Denitions:
O Technical feasibility is based on
whether the proposed measures can
be implemented with commercially
available skills, equipment and
materials, taking into consideration
prevailing local factors such as
climate, geography, infrastructure,
security, governance, capacity and
operational reliability. Financial
feasibility is based on commercial
considerations, including relative
magnitude of the incremental cost of
adopting such measures and actions
compared to the projects investment,
operating and maintenance costs.

Secondary abatement techniques,

such as FGD
In brief, the chosen pollution control and
process technology should be practical,
cost-eective and suitable for the specic
project according to local conditions,
considering available technical and
nancial resources, existing environmental
conditions, and other infrastructure
aspects.
IFC Performance Standard 3 (Resource
Eciency and Pollution Prevention) [4]
stipulates, amongst other things,
the following:
Objectives:
O To avoid or minimize adverse impacts
on human health and the environment
by avoiding or minimizing
pollution* from project activities.
O To promote a more sustainable use of
resources, including energy and water.
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Requirements:
O During the project life-cycle, the client
will consider ambient conditions and
apply technically and nancially feasible
resource eciency and pollution
prevention principles and techniques
that are best suited to avoid or where
avoidance is not possible, minimize
adverse impacts on human health and
the environment. The principles and
techniques applied during the project
life-cycle will be tailored to the hazards
and risks associated with the nature of
the project and consistent with good
international industry practice (GIIP).

As shown earlier, there are many dierent

FGD techniques available. The most
suitable for large stationary RICE plants
is the wet scrubber type using CaCO3
as a reagent. The challenges associated
with wet scrubbers are:
O Signicant quantities of good quality
fresh water are consumed. Roughly 1
m3/MWhe of fresh water is needed
in a single cycle diesel engine plant.
For example, a 100 MWe plant
needs about 100 m3/hour of clean
fresh water for the FGD process.
O A reagent, such as transports, supplies,
and an end product infrastructure must
exist. End product issues include the
question as to whether possible pretreatment, if local rules so stipulate,
and disposal can be handled in an
environmentally sound way or not.

O
O

Impurities should not be transferred

from the gaseous phase to liquid or
solid phases, at least not according
to the IPPC.
The availability of spare parts and
skilled personnel for the operation
of the FGD.
Increase in the parasitic electric load of
the plant and thus increased CO2
emissions, due to additional ue gas
fans or the need for other such
appliances.
High investment costs. Operating costs
are very dependent on the reagent, raw
water, electricity, and end product
disposal costs.
Visible water plume in the stack and
the risk of increased GLCs locally.

Many areas of the world are arid and

water shortage is acute. FGD water usage
could have signicant adverse impacts on
other consumers in the area. In a regionwide health approach, integrated water
resource management and sustainable
water supply and usage should be
included along with outdoor air quality
considerations. In other words, what is
the most sustainable option: the use of
FGD for SO2 emission reductions in
weak infrastructure areas where water is a
nite/scarce resource? Or the assimilative
capacity of the surrounding air-shed?
Dry scrubbers use reagents such as
NaHCO3 or high active ne grounded
Ca(OH)2, and water is not needed.
Therefore dry FGDs have, in some arid
area projects, been proposed as being
the technique.
Challenges associated with dry FGDs
include however:
O Reagent availability and investment
costs.
O Moderate SO2 reduction (typically
about 50 to 60 %) if the reagent is not
dosed with a high over-stochiometry.
A high SO2 reduction results in a high
reagent consumption and big amounts
of end product, i.e. a high O & M cost.
O In order to prevent leachates of
impurities into water drains, the
produced end product needs to be
stabilized before disposal. Alternatively,
the end product should preferably be
sent to a dedicated treatment plant.
O The availability of spare parts and
skilled personnel for the operation
of the FGD
O Bag lter based systems require cooling

WRTSIL TECHNICAL JOURNAL 02.2011

of the ue gas temperature, otherwise

the lter material will be destroyed.
O Increase in the parasitic electric load of
the plant and thus increased CO2
emissions, due to additional
ue gas fans or the need for
other such appliances.
O Dry scrubbers have so far been used
only in special applications, such
as small scale incinerators, in Europe.
Because of the special reagent and the end
product infrastructure required, the dry
FGD option is only for plants in areas with
a good existing infrastructure.
Thus, FGD use cannot be said to be
according to the objectives, nor is it feasible,
according to the IFC Performance
Standard 3 in arid remote areas.
CONCLUSION

This article briey discusses the exibility

option provided in the IFC EHS
Guidelines for deviating from prescribed
emission levels in areas with severe
impediments.
Compliance with NAAQS is the starting
point. The above mentioned exibility
option is very briey described in the EHS
Guidelines. Signicant pre-work, such

as proper GLC modelling, must be

performed and good technical and
economic justications for deviating from
emission limits are also needed as a part
of the EA (Environmental Assessment).
GLC calculation example results for
a 140/150 MWe high sulphur HFO
red stationary RICE plant in an arid
area are discussed and compared to the
national SO2 GLC standard. Results
show that the NAAQS is fullled - the
rst step in checking as to whether or not
application of the exible mechanism
could be accomplished. Some arguments
relating to a remote arid area with a
weak existing infrastructure are put forth
in this article. They indicate that if a
secondary emission abatement technique,
such as a FGD is applied, in this case
the objectives and technical feasibility
denitions of the IFC Performance
Standard 3 would not be fullled.
In other words, the available exibility
option in the IFC EHS Guidelines could
be workable in these kinds of project.
However, this is highly dependent on the
attitude of the project nanciers and local
and federal authorities. Close contact with
the relevant authorities and nanciers from
the initiation of the project is important

in order to secure their acceptance of

the exibility option. An upfront study,
including site investigations and GLC
modelling should be carried out by
an experienced third party consultant
appointed by the project developer. If
successful, meaning that the performance
levels of the specic project are concluded
to be suciently protective, it will make
the project much more feasible, based on a
cost eective environmental quality need,
and in line with the IPPC approach.

SOURCES
[1] IFC Thermal Power Plants EHS
Guidelines at http://www.ifc.org/ifcext/
sustainability.nsf/AttachmentsByTitle/
gui_EHSGuidelines2007_
ThermalPower/$FILE/FINAL_
Thermal+Power.pdf
[2] IFC General EHS Guidelines at
http://www.ifc.org/ifcext/sustainability.
nsf/AttachmentsByTitle/gui_
EHSGuidelines2007_GeneralEHS_11/$FILE/1-1+Air+Emissions+and+Ambien
t+Air+Quality.pdf
[3] EU 1999/30/EC Directive
[4] IFC Performance Standard 3 at
http://www.ifc.org/ifcext/policyreview.
nsf/AttachmentsByTitle/Updated_PS3_
August1-2011/$FILE/Updated_PS3_
August1-2011.pdf

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