Emission limits of and waste disposal considerations for ...fossilfuel.co.za/conferences/2015/Independent-Power-Generation-in... · LSD (Lime spray-dryer) (low sulphur) CFB (Circulating

Emission limits of and waste disposal considerations for plant firing coal and plant

co-firing with biomass or waste materials

30 July 2015

Theo Fischer & Abdul Ebrahim, EScience Associates

[email protected]

mailto:[email protected]

NEMAQA Scheduled Processes and Controlled Emitters

ª Situation on the groundª Legislative landscape

§ Constitution§ NEMAQA and Regulations Gazettes there under§ NEMWA, NEMWAA and Regulations Gazettes there under

ª Implications of source based emission limits for existing listed emitters and controlled emitters

ª Implications of source based emission limits for future listed emitters and controlled emitters

ª Procedure for extension of compliance timeframes ª Emission offsets

Industrial Boilers, Kilns And Furnaces in a Carbon-Constrained Environment 2015

Situation on the Ground






Legislation applicable to air quality


NATIONAL ENVIRONMENTAL MANAGEMENT AIR QUALITY ACT (NEMAQA)

ª National Environmental Air Quality Act (NEMAQA) (Act 39 of 2004)§ An ambient air quality management approach§ Regulates both ambient air quality as well as activities that may have an

impact on ambient air quality § National ambient air quality standards § Establish minimum emission standards § Priority Air Pollution Areas and Air Quality Management Plans


NEMAQA:Air Pollution: Ambient Standards

National Ambient Air Quality Standards - GN 1210:2009

Pollutant Averaging period Conc. µg/m3 FOE* Compliance date

PM10

24-hours 120 4 immediate to 31 Dec 201475 4 1 January 2015

Annual 50 0 immediate to 31 Dec 201440 0 1 January 2015

NO21-hour 200 88 ImmediateAnnual 40 0 Immediate

SO2

10-min (running) 500 526 Immediate

1-hour 350 88 Immediate24-hours 125 4 ImmediateAnnual 50 0 Immediate

CO1-hour 30 88 Immediate

8-hours (running)^ 10 11 Immediate

* FOE – Permitted Frequency of Exceedance in occurrences per year^ Calculated on 1-Hourly averages.

National Ambient Air Quality Standards for PM2.5 - GN 486:2012

Pollutant Averaging period

Conc. µg/m3 FOE* Compliance date

PM2.5

24-hours60 4 immediate40 4 01 January 201625 4 01 January 2030

Annual25 0 immediate20 0 01 January 201615 0 01 January 2030


>50MW thermal GN 893 Licensed facility and emission limitsNew & Existing with different emission limitsSolid Fuel Category 1.1 Combustion

Liquid fuel Category 1.2 Combustion

Solid Biomass Category 1.3 Combustion

Gas Category 1.4 Combustion

Reciprocating engines (liquid) Category 1.5 Combustion

Reciprocating engines (gas) Category 1.5 Combustion

Waste co-feed Category 1.6 Combustion

Waste Category 8.1 Incineration

Cat 1.1- Cat 1.4 combined with combustion of material that is recovered from waste

<50MW thermal GN 831 Controlled emitter and emission limitsNew & Existing with different emission limits(1) Solid fuel-fired small boiler(2) Liquid fuel-fired small boiler(3) Gaseous fuel-fired small boiler (using natural gas and liquefied petroleum gas)(4) Gaseous fuel-fired small boiler (using process gas)(5) Co-feedingWhere a small boiler is fired simultaneously with two or more fuels, emission standards for the main fuel shall be applicable.

NEMAQA and Regulations Gazettes there under: Emission limits


ª Environmental Management Air Quality Act Scheduled Activities and Emission limits for (NEMAQA S21 Emission limit regulations):§ Solid Fuel Combustion Installations Emission limits

§ Waste Incineration Emission limits

Combustion installations NEMAQA S21 Emission limit RegsPrimarily for steam raising or power generationSolid fuel combustion installations: design capacity ≥ 50MW heat input (lower calorific value of fuel)

PM NOx SO2mg/Nm3 mg/Nm3 mg/Nm3

New 50 750 500Existing 100 1100 3500

Disposal of hazardous & general waste NEMAQA S21 Emission limit Regs

Facilities for general and hazardous waste (10kg /h or larger)

PM NOx SO2 CO HCl HF Cd+Tl Hg Pb…* TOC NH3

Dioxins & furans

mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 ng l_TEQ/Nm3

New 10 200 50 50 10 1 0.05 0.05 0.5 10 10 0.1Existing 25 200 50 75 10 1 0.05 0.05 0.5 10 10 0.1

NEMAQA:Emission limits for scheduled emitters


ª In November 2013, the minister of DEA declared small boilers <50MW thermal as controlled emitters in GN 831 Controlled emitter with associated emission limits

ª These standards shall be implemented by the municipalitiesª New small boilers must comply with the new small boiler emission standards while

existing small boiler must comply with these standards by 2017.ª Section 25 (1) of NEM:AQA, 2004, prohibits any person from manufacturing,

selling or using any appliance or conducting an activity declared as a controlled emitter unless that appliance or activity complies with the standards established in terms of section 24

NEMAQA:Emission limits for scheduled emitters


>50MW thermal GN 893 + GN 551 Licensed facility and emission limitsNew & Existing with different emission limitsSolid Fuel+ recovered waste Category 1.1 Combustion

Liquid fuel+ recovered waste Category 1.2 Combustion

Solid Biomass+ recovered waste Category 1.3 Combustion

Gas+ recovered waste Category 1.4 Combustion


NEMAQA and Regulations Gazettes there under: Emission limits

Category 1.6 Waste co-feedCategory 1.1 Solid Fuel+ recovered waste

PM NOx SO2 CO HCl HF Cd+Tl Hg Pb…* TOC NH3

Dioxins & furans

mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 ng l_TEQ/Nm3

New 50 750 500 50 10 1 0.05 0.05 0.5 10 10 0.1Existing 100 1100 3500 75 10 1 0.05 0.05 0.5 10 10 0.1

Category 1.1 Solid FuelPM NOx SO2mg/Nm3 mg/Nm3 mg/Nm3

New 50 750 500Existing 100 1100 3500

ª Existing Background Air Quality is a key factor – Emitter Density

CONFERENCE: Optimisation of Industrial Boilers

LEGAL LANDSCAPE: NEMAQA(Priority Area Air quality Management Plans)


ª Existing Background Air Quality is a key factor – Hot Spots!


ª Existing Background Air Quality is a key factor – Hot Spots!




ª Existing Background Air Quality is a key factor – Priority Areas


EMISSION LIMITS-Implications For Boilers


ª Options for SO2 emission reduction:

§ Raw material changes * Low sulphur coal* Coal sulphur content reduction (Washing, other)* Biomass co-combustion (decreased relative sulphur)

§ Abatement* Lime spray dryer (dry FGD)* Wet limestone (wet FGD)* Circulating fluidized in bed lime absorber (CFBa)

ª Retrofitting abatement requirements (costly)


NEMAQA:SO2 EMISSION LIMITS- IMPLICATIONS FOR BOILERS

ª Adapted from: Economics of Lime and Limestone for Control of Sulphur Dioxide (DePriest and Gaikwad 2001)

LSFO (Limestone forced oxidation)

MEL (magnesium enhanced lime)

LSD (Lime spray-dryer) (low sulphur)

CFB (Circulating fluidised bed) (low sulphur)

SO2 removal efficiencyCapital cost($) 64 451 000 54 665 000 61 291 999 66 914 000Fixed operating costs($/year) 3 929 000 3 574 000 2 539 000 271 000Variable operating costs($/year) 4 369 000 5 527 000 4 202 000 4 089 000

Reagent 2 059 000 3 847 000 2 769 000 2 670 000Disposal 0 0 1 071 000 1 057 000

Byproduct credit 0 0 0 0bag replacement 0 0 341 000 341 000

cage replacement 0 0 21 000 21 000Water 208 000 208 000 102 000 102 000Power 2 102 000 1 472 000 1 156 000 841 000

Levelised cost (cents/kWhr) 0.57 0.57 0.49 0.49

98% 95% (when used with baghouse after scrubber)

FGD system for 500MWWET FGD DRY FGD

NEMAQA:SO2 EMISSION LIMITS- IMPLICATIONS FOR BOILERS


EMISSION LIMITS-Postponement of compliance

time frames


NEMAQAPOSTPONEMENT OF COMPLIANCE TIME FRAMES

ª An application may be made for the postponement of the compliance time frames for an existing plant and should include:§ Atmospheric Impact Report (dispersion modelling and air quality impact

assessment)§ a detailed justification and reasons for the application that includes

consideration of health impacts

ª The National Air Quality Officer with the concurrence of the Licensing Authority§ may grant a postponement of the compliance time frames for existing plant

for a period not exceeding 5 years§ may from time to time review any postponement granted, should ambient air

quality conditions in the affected area of the plant not conform to ambient air quality standards


ª Meteorology and physical environment§ Topography§ Wind Speed and Direction§ Turbulence (thermal and mechanical)§ Temperature Inversion§ etc

ª Emission characteristics & dispersion potential§ Release Height§ Release Temperature§ Exit Speed

ª Background air quality§ Other sources of emissions

ª Receptors§ Residential areas

ª Cumulative impact

Dispersion modelling

NEMAQAPOSTPONEMENT OF COMPLIANCE TIME FRAMES

Impact assessment


ª Emissions offsetting§ The department is currently using the following definition for air quality

offsets –

“An Air Quality Offset is an intervention, or interventions, specifically implemented to counterbalance the adverse environmental impact of

atmospheric emissions at one location within an air-shed that is implemented at another location within the same air-shed to deliver a net

ambient air quality benefit within the affected air-shed.”

NEMAQAPOSTPONEMENT- EMISSIONS OFFSETTING


ª June 2012 – DEA compilation and dissemination of a discussion document coupled with various outreach activities

ª Draft Guidelines gazetted for emissions offsetting

ª Part of Eskom application for postponement:

§ There is support from both the Department of Public Enterprises and the Department of Environmental Affairs for the implementation of household emission offset projects (for example, through insulating houses and subsidising liquid petroleum gas to replace the use of coal or wood for heating and cooking in houses).

§ These offsets will not reduce Eskom’s emissions, it will improve ambient air quality and reduce human exposure to high levels of pollution at a fraction of the cost of emission abatement retrofits at power stations. Eskom is investigating options, and is currently initiating a household emission offsets pilot project to test the effectiveness of this approach.

NEMAQAEMISSIONS OFFSETTING


Legislation applicable to energy recovery and waste disposal


>50MW thermal GN 893 Licensed facility and emission limitsNew & Existing with different emission limitsSolid Fuel Category 1.1 Combustion

Liquid fuel Category 1.2 Combustion

Solid Biomass Category 1.3 Combustion

Gas Category 1.4 Combustion

Reciprocating engines (liquid) Category 1.5 Combustion

Reciprocating engines (gas) Category 1.5 Combustion


Waste Category 8.1 Incineration

<50MW thermal GN 831 Controlled emitter and emission limitsNew & Existing with different emission limits(1) Solid fuel-fired small boiler(2) Liquid fuel-fired small boiler(3) Gaseous fuel-fired small boiler (using natural gas and liquefied petroleum gas)(4) Gaseous fuel-fired small boiler (using process gas)(5) Co-feedingWhere a small boiler is fired simultaneously with two or more fuels, emission standards for the main fuel shall be applicable.

LEGAL REQUIREMENTS FOR ENERGY RECOVERY


NATIONAL ENVIRONEMNTAL MANAGEMENT: WASTE ACT (SCHEDULED ACTIVITIES THAT REQUIRE AUTHORISATION)

ª GN 636 23 August 2013 National Environmental Management: Waste Act (59/2008): National norms and standards for disposal of waste to landfill

ª Landfill prohibition:

Waste Prohibited or Restricted in terms of Disposal Compliance Timeframe

(c) Flammable waste with a closed cup flashpoint lower than 61° Celsius. Immediate (2013)(j) Re-usable, recoverable or recyclable used lubricating mineral oils, as well as oil filters, but excluding other oil containing wastes. 4 years (2017)(o) Waste tyres: Whole. Immediate (2013)(p) Waste tyres: Quartered. 5 years (2018)(r) Hazardous waste with a calorific value of:

(i) > 25 MJ/kg. 4 years (2017)(ii) > 20 MJ/kg. 6 years (2019)(iii) > 10 MJ/kg. 12 years (2025)(iv) > 6% TOC. 15 years (2028)


FUELS


NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT (NEMWA)

§ When am I combusting waste and when am I combusting fuel (or recovered waste?

§ No clear cut answer§ Concept of end of waste in context of fuels – when material combusted

becomes desirable (tradable in market?) or when it deemed a by-product (NEMWA def : has the characteristics of an equivalent virgin product or material);

§ Depending on existence of a formal standard (RDF and biomass pellet standards) and marketability, probably thus waste


FBC INSTALLATIONS YEAR OF COMMISSIONING AND FUEL TYPE

Smaller combustion plants are increasingly used to recover energy

from waste materials


Combustion residue


NATIONAL ENVIRONMENTAL MANAGEMENT WASTE AMENDMENT ACT (NEMWAA)

Is this waste?s


§ What is it the ash that I will be recovering or disposing? Waste? Or by-product?

§ Most notable in this respect were the changes to the definition of ‘waste’ itself, as well as that of ‘recovery’.

§ The definition of waste has been amended to remove the previously applied exclusion of ‘by-products’ from the definition thereof, and has furthermore been linked to two non-exhaustive lists of hazardous (Category A) and general (Category B) waste streams/industry sectors under Schedule 3 to the Waste Amendment Act.



§ What is it the ash that I will be recovering or disposing? Waste? Or by-product?

“waste” means-(a) any substance, material or object, that is unwanted, rejected, abandoned,

discarded or disposed of, or that is intended or required to be discarded or disposed of, by the holder of that substance, material or object, whether or not such substance, material or object can be re-used, recycled or recovered and includes all wastes as defined in Schedule 3 to this Act; or(b) any other substance, material or object that is not included in Schedule 3 that may

be defined as a waste by the Minister by notice in the Gazette, but any waste or portion of waste, referred to in paragraphs (a) and (b), ceases to be a waste-

(i) once an application for its re-use, recycling or recovery has been approved or, after such approval, once it is, or has been re-used, recycled or recovered;

(ii) where approval is not required, once a waste is, or has been re-used, recycled or recovered;(iii) where the Minister has, in terms of section 74, exempted any waste or a portion of waste generated by a

particular process from the definition of waste; or(iv) where the Minister has, in the prescribed manner, excluded any waste stream or a portion of a waste

stream from the definition of waste.

[Definition of “waste” substituted by s. 38 of Act 14/2013 and s. 1 of Act 26/2014]



ª National Environmental Management: Waste Amendment Act of 2014 iSchedule 3 refers to two categories of waste namely:§ CATEGORY A: Hazardous Waste§ CATEGORY B: General Waste (that includes inert waste)§ Waste classification is now used to demonstrate that materials listed in CATEGORY

A: Hazardous Waste is in fact CATEGORY B

ª Generators of waste listed in Schedule 3 to demonstrate that the waste was not hazardous which will then allow the generator to apply to be exempted from the provisions of the Act in terms of sections 74-77.



ª Draft regulations have been published that allows Exclusion of a waste stream or a portion of a waste stream from the definition of waste if “that any contaminant of concern from waste reaching a receptor will not exceed the acceptable environmental limits for any contaminant of concern for such a receptor”.

ª This requires amongst others the following information:§ What is the classification of the Waste or portion of waste? Provide evidence of

classification§ List all potential impacts from the use of the waste (both negative and positive)§ Demonstrate that contaminant of concern will not exceed the acceptable

environmental limits (air, land, water based receptors)§ Provide information on the mitigation measures that will address all the negative

impacts



§ A DRAFT National Pricing Strategy for Waste Management Charges was published for comment in February 2015. The development of the strategy is a requirement under the 2014 Waste Amendment Act and its aims are broadly stated as, “…providing a basis and guiding methodology(ies) for setting of waste management charges in South Africa.

§ This is through providing an enabling environment for waste recycling and contributing to the recycling economy in South Africa, through recovery, re-use and recycling of waste”.

§ The draft Strategy provides, in broad terms, an outline of economic instruments and fiscal mechanisms under review consideration by the South African Government for potential implementation in South Africa, toward achieving the above aims.


Conclusions

Conclusions• Significant body of legislation applicable to combustion of

fuels and disposal of wastes arising• Significant opportunity for recovery of energy from

biomass and waste materials through recovery or direct combustion in addition to coal

• South Africa is lagging the rest of the world in recovery of energy from biomass and waste materials

Emission limits of and waste disposal considerations for plant firing coal and plant

co-firing with biomass or waste materials

30 July 2015

Theo Fischer & Abdul Ebrahim, EScience Associates

[email protected]

mailto:[email protected]

Documents

Emission limits of and waste disposal considerations for ...fossilfuel.co.za/conferences/2015/Independent-Power-Generation-in... · LSD (Lime spray-dryer) (low sulphur) CFB (Circulating