North Macedonia: Compliance or Closure - How Western Balkan Countries Violate Air Pollution Regulations30.Sep 2020.
Northern Macedonia has decided that all large combustion plants should be part of the National Emission Reduction Plan, NERP. After the draft Plan was submitted to the Energy Community in October 2016, the Secretariat gave its assessment, confirming that it had been drafted in accordance with the applicable legal framework of the Energy Community.
In April 2017, the Government of Northern Macedonia adopted the NERP and included comments from the Secretariat. However, this Government Decision was not published in the Official Gazette or on the Government website. Northern Macedonia has not conducted a public consultation or strategic environmental assessment.
According to NERP, the plan was prepared only as a way of fulfilling obligations under the LCPD and the Decision of the Ministerial Council of the Energy Community D/2013/05/MCEn.
Both REK Bitola and REK Oslomej, two lignite-fired thermal power plants, should have continuous monitoring of SO2, NOx and dust emissions.
However, as stated in a statement by the Ministry of Energy’s representatives at the meeting of the Environmental Working Group on April 25, 2019, only periodic one-month measurements are made. It would also be a requirement in IPPC permits for power plants, but these plants do not yet have them.
Of the other large combustion plants included in the NERP, three are not currently operational, two of which use natural gas as fuel and only require equipment for continuous NOx monitoring, which they already have.
Compliance with limit values in 2018
Of the three pollutants regulated by LCPD, only NOx emissions were within the upper limit in 2018.
SO2 emissions are the biggest problem. Total emissions in 2018 were 53,855 tonnes, which is 3.4 times higher than the 15.855 tonne cap. This is also significantly more than the 44,267 tonnes emitted in 2014, used as a benchmark for NERP, including three plants that were not operational in 2018.
The biggest contributors to SO2 emissions are the REK Bitola, B1 + B2 and B3 units, with 34,234 and 18,589 tonnes respectively. As can be seen, unit B3 independently breaks through the national ceiling of SO2.
REK Oslomej, with 1,031 tons, is located within the individual ceiling thanks to the small number of operating hours.
Two gas-fired heating plants have low SO2 emissions.
Total dust emissions in 2018 were double the upper limit – 3,586 tonnes compared to 1,738 tonnes. REK Bitola has the largest contribution to emissions here as well. The contribution of B1 + B2 is 2,582 tonnes of dust, compared to the individual ceiling of 823 tonnes.
The ceiling of B3 is 357 tons and the real contribution is 888 tons of dust. The emissions of REK Oslomej are 115 tons. The contribution of gas-fired plants is negligible.
NOx emissions are significantly lower than the upper ceilings, mainly due to investments in REK Bitola. Total emissions amounted to 4,708 tonnes, which is 3.3 times less than the upper limit – 15,505 tonnes.
The only significant investment of the largest polluter in Northern Macedonia, REK Bitola, was realized during 2012-2013- before NERP was adopted. The B2 and B3 boilers were then redesigned to comply with the LCPD requirements.
The tender for the reconstruction and modernization of the electrostatic precipitator in the Bitola REK has been announced several times in the last ten years, and was finally published in March 2019. However, due to irregularities in the procurement process, the tender was cancelled and the whole procedure was returned to the beginning.
The REK Bitola Desulphurisation Unit is still in the feasibility study stage and is unlikely to be completed before 2025.
REK Oslomej is mainly used as a backup unit and there has been no significant investment here in the last two decades.