Emission limits of and waste disposal considerations for plant … · LSD (Lime spray-dryer) (low...

Emission limits of and waste disposal

considerations for plant firing coal and plant co-firing with biomass or waste materials

17 March 2016

Theo Fischer & Abdul Ebrahim, EScience Associates

[email protected]

mailto:[email protected]

NEMAQA Scheduled Processes and Controlled Emitters

Situation on the ground

Legislative landscape

Constitution

NEMAQA and Regulations Gazettes there under

NEMWA, NEMWAA and Regulations Gazettes there under

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

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

Procedure for extension of compliance timeframes

Emission offsets

Power Generation from Coal By Independent Power Producers (IPPs) 2016

Situation on the Ground





http://cer.org.za/news/in-pictures-what-coal-is-doing-to-the-mpumalanga-highveld




http://cer.org.za/news/in-pictures-what-coal-is-doing-to-the-mpumalanga-highveld



Legislation applicable to air quality


NATIONAL ENVIRONMENTAL MANAGEMENT AIR QUALITY ACT (NEMAQA)

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 2014

75 4 1 January 2015

Annual 50 0 immediate to 31 Dec 2014

40 0 1 January 2015

NO2 1-hour 200 88 Immediate

Annual 40 0 Immediate

SO2

10-min (running) 500 526 Immediate

1-hour 350 88 Immediate

24-hours 125 4 Immediate

Annual 50 0 Immediate

CO 1-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-hours 60 4 immediate

40 4 01 January 2016 25 4 01 January 2030

Annual 25 0 immediate 20 0 01 January 2016 15 0 01 January 2030


>50MW thermal GN 893 Licensed facility and emission limits

New & Existing with different emission limits

Solid 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 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-feeding Where 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


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 Regs

Primarily for steam raising or power generation

Solid fuel combustion installations: design capacity ≥ 50MW heat input (lower calorific value of fuel) PM NOx SO2

mg/Nm3 mg/Nm3 mg/Nm3 New 50 750 500

Existing 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 0.1

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

NEMAQA: Emission limits for scheduled emitters


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

These standards shall be implemented by the municipalities

New small boilers must comply with the new small boiler emission standards while existing small boiler must comply with these standards by 2017.

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 limits


Solid 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-feed

Category 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 0.1

Existing 100 1100 3500 75 10 1 0.05 0.05 0.5 10 10 0.1

Category 1.1 Solid Fuel PM NOx SO2

mg/Nm3 mg/Nm3 mg/Nm3

New 50 750 500

Existing 100 1100 3500


Existing Background Air Quality is a key factor – Emitter Density

CONFERENCE: Optimisation of Industrial Boilers

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


Existing Background Air Quality is a key factor – Priority Areas

CONFERENCE: Optimisation of Industrial Boilers


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


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



Legal challenges to Coal IPP development

To date, groundWork (gW) and Earthlife Africa Johannesburg (ELA) - together with community partners in the Vaal, Mpumalanga Highveld and KwaZulu-Natal - have launched a legal challenge against three proposed new coal-fired power stations proposed under the CBLIPPPP.

These are the 1,200MW Thabametsi power station (near Lephalale in the Limpopo); the 600MW KiPower power station (near Delmas, Mpumalanga); and the 1,050MW Colenso Power station (near Colenso in KwaZulu-Natal).

CER : “The detrimental impacts on the health of local communities, and the huge water demands of the proposed dirty coal power plants, are major grounds for the appeals”

All three proposed stations would be located in drought-disaster areas, with KiPower to be based in the Highveld, an area already so overburdened by industrial exploitation and air pollution that it has been declared an air quality priority area under the Air Quality Act. The Waterberg (where Thabametsi power station will be situated) has also been declared an air quality priority area.



EMISSION LIMITS- Implications For Boilers


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)

Retrofitting abatement requirements (costly)

NEMAQA: SO2 EMISSION LIMITS- IMPLICATIONS FOR BOILERS


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 efficiency

Capital cost($) 64 451 000 54 665 000 61 291 999 66 914 000

Fixed operating costs($/year) 3 929 000 3 574 000 2 539 000 271 000

Variable 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 2 670 000

Disposal 0 0 1 071 000 1 057 000

Byproduct credit 0 0 0 0

bag replacement 0 0 341 000 341 000

cage replacement 0 0 21 000 21 000

Water 208 000 208 000 102 000 102 000

Power 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 500MW

WET FGD DRY FGD

NEMAQA: SO2 EMISSION LIMITS- IMPLICATIONS FOR BOILERS


EMISSION LIMITS- Postponement of compliance

time frames


NEMAQA POSTPONEMENT OF COMPLIANCE TIME FRAMES

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

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


Meteorology and physical environment

Topography

Wind Speed and Direction

Turbulence (thermal and mechanical)

Temperature Inversion

etc

Emission characteristics & dispersion potential

Release Height

Release Temperature

Exit Speed

Background air quality

Other sources of emissions

Receptors

Residential areas

Cumulative impact

Dispersion modelling

NEMAQA POSTPONEMENT OF COMPLIANCE TIME FRAMES

Impact assessment


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.”

NEMAQA POSTPONEMENT- EMISSIONS OFFSETTING


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

Draft Guidelines gazetted for emissions offsetting

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.

NEMAQA EMISSIONS OFFSETTING


Legislation applicable to energy recovery and waste disposal


>50MW thermal GN 893 Licensed facility and emission limits


Solid 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 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-feeding Where 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)

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

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.




“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]




Gypsum or ash or complex mix of things?


Boiler Coal and Limestone

Input 100 Coal

2 Sulphur Umgala

33 Ash

3.497623651 Lime

Stochiometry overdose factor 1.80

Ash 31.22702721 Ash excl CaO MgO 71%

Output 8.491336618 CaSO4 19%

2.798098921 CaO added above stoch SO2 re 6%

1.3827 CaO Ash inherent 3%

0.2805 MgO 1%

44.17966275 Total Product 100%


National Environmental Management: Waste Amendment Act of 2014 i Schedule 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

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.



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”.

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


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

17 March 2016

Theo Fischer & Abdul Ebrahim, EScience Associates

[email protected]

mailto:[email protected]

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