Environmental Advantages of Gasification: Public and Agency Awareness. Steve Jenkins Energy & Chemicals Consulting, LLC October 13, 2015

Transcription

1 Environmental Advantages of Gasification: Public and Agency Awareness Steve Jenkins Energy & Chemicals Consulting, LLC October 13, 2015

2 Topics Environmental advantages of gasification vs. combustion Gasification vs. Incineration Environmental advocacy group responses and actions Gasification permitting examples By-products Telling our story

3 Environmental Profile of Gasification Facilities We know that: Pyrolysis and gasification are very different from combustion Contaminants are typically removed prior to combustion or downstream use to produce chemicals, fertilizers or fuels By-products can be commercially saleable Overall smaller/cleaner environmental profile than combustion/incineration systems You have a great story to tell so tell your story before someone else tells theirs

4 Gasification vs. Incineration

5 Mass-burn Incineration Incineration literally means to render to ash Incineration uses MSW as a fuel It burns with large amounts of air to form heat and CO 2 Hot exhaust gases are used to make steam, which is then used to generate electricity Emissions are treated after combustion of the MSW

6 MSW Gasification When using gasification, the MSW is not a fuel It s a feedstock The MSW itself is not combusted Gasification converts MSW to a usable syngas The syngas (not the MSW) can be combusted to produce steam or electricity Or the syngas can be used to make higher valuable commercial products such as transportation fuels, chemicals, or fertilizers

7 Dioxins and Furans Advantages of MSW Gasification Dioxins/furans need sufficient oxygen to form; a gasifier does not provide the ideal environment needed for that to occur Large organic molecules (like plastics) are decomposed into syngas in the high temperatures of a gasifier Dioxins need fine metal particulates in the gas to reform; syngas from gasification is typically cleaned of particulates before being used When syngas is used to produce fuels, chemicals and fertilizers, the syngas is quickly quenched, so that there is not sufficient residence time in the temperature range where dioxins/furans could re-form When the syngas is primarily used as a fuel, it can be cleaned as necessary before combustion; this cannot occur in incineration, which requires post-combustion clean-up

8 Dioxins and Furans That does not mean that there are zero emissions of dioxins/furans They are likely to be below measurement thresholds There is a significant amount of MSW gasifier and pyrolysis unit emission data available worldwide Emissions are typically far below those from incinerators Use pilot and demo plants to provide data for your project Show that data to the public and to permitting agencies Or they will use what they have, which may not be accurate

9 Environmental Group Responses to Waste Gasification Projects Global Anti-Incinerator Alliance: Incinerators with names like gasification, pyrolysis, plasma arc, and waste-to-energy all emit dioxins and other harmful pollutants, despite industry claims that they are green technologies Greenaction for Health and Environmental Justice: Gasification is Just Incineration In Disguise

10 Environmental Group Responses to Waste Gasification Projects MSW gasification systems compete with recycling

11 MSW Gasification Enhances Recycling Gasification does not compete with recycling, it actually enhances it Metals and glass are typically removed from the waste stream prior to being fed into the gasification system Many plastics, cardboard boxes, and contaminated paper cannot by recycled, and would otherwise end up in a landfill They make excellent high energy feedstocks for gasification, reducing the amount that would end up in a landfill

12 Why Do They Respond Like This?

13 Typical Waste Gasification Project Claims There are zero emissions.. It s a closed loop.. There are no stacks.. It s pollution free.. We won t need landfills any more.. It s green energy.. It s commercially proven..

14 Typical Waste Gasification Project Claims There are zero emissions..except for a very small amount during operation It s a closed loop..except for the small wastewater discharge to the sewer and the ash that goes to the landfill There are no stacks..oh, that stack? That s the flare that we use during startups, shutdowns, and equipment malfunctions It s pollution free..except for the list of pollutants in our permit application We won t need landfills anymore..except for the small amount of ash we need to send there It s green energy..as long as people keep throwing away their garbage It s commercially proven..well, at least part of it is, although at a much smaller scale and in another country

15 Project and Technology Credibility Environmental groups have nationwide and international programs They are very well funded They often show up and rally the locals with fear tactics: Do you want to be guinea pigs with a first-of-a kind plant? It s unproven and the project developer s claims are false When one of your claims is invalidated, the others don t matter, even if they re valid Many projects have died due to false or unclear claims

16 Regulatory Applicability for MSW Gasifiers Not only is gasification different from incineration on a technical basis, but also on a regulatory basis US EPA and state regulatory agencies have determined: Gasification is different from incineration and combustion Unlike incinerators, gasifiers do not combust solid materials; they convert it to a gas, called syngas Syngas is not defined as a solid waste Gasifiers are not incinerators MSW gasification systems are not covered by the air permitting requirements for mass-burn incinerators

17 What Regulations Apply to Incinerators? Municipal solid waste is defined as a solid waste under RCRA Incinerators combust the solid waste Under Clean Air Act Section 129, small ( tons/day) Municipal Solid Waste Combustors (incinerators) must comply with Subpart AAAA Standards of Performance for Municipal Solid Waste Combustors However, a MSW pyrolysis or gasification plant is not an incinerator, since waste is not combusted

18 Gasification Plant Permitting Examples

19 Fulcrum BioEnergy Sierra BioFuels (Nevada) Gasification of MSW, with syngas converted to alcohols Some of the syngas, along with some natural gas, will be combusted to generate steam Air permit issued to the facility by Nevada Dept. of Air Pollution Control (DAPC) in 2013

20 DAPC Technical Review Subpart AAAA, Standards of Performance for Municipal Solid Waste Combustors does not apply The syngas that will be combusted in the facility is not defined by EPA as a solid waste Subpart Ec for Hospital/Medical/Infectious Waste Incinerators does not apply EPA verified that the syngas gasification unit is not subject to Subpart Ec for incinerators Section 112, Subpart JJJJJJ, NESHAPS for Industrial, Commercial, and Institutional Boilers does not apply Exempts gas-fired boilers

21 DAPC Technical Review The syngas-fired boiler is subject to Subpart Dc, Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units Fossil-fired units with a heat input of MMBtu/hr The boiler will fire syngas, and can fire or co-fire natural gas, a fossil fuel No specific NSPS or NESHAPS emission limits apply since the boiler will fire only gases Emission limits based on vendor specifications and engineering estimates The boiler will only be subject to notification and recordkeeping requirements since it combusts only gases If the boiler did not fire/co-fire natural gas, Subpart Dc would not apply because syngas is not a fossil fuel

22 MaxWest Environmental Systems, Inc. (Florida) MaxWest Environmental Systems, Inc. developed a gasifier to convert biosolids to syngas Requested a determination from EPA that their gasification technology for biosolids is not incineration

23 MaxWest Environmental Systems, Inc. EPA provided a response letter that stated: A sewage sludge incinerator is an enclosed device or devices using controlled flame combustion that burns sewage sludge No flame is applied or propagated in the gasifier and the gasifier prevents combustion by limiting the air-to-sludge ratio so that combustion cannot occur Since syngas is a gas, and not a solid, semi-solid, or liquid, it does not meet the definition of sewage sludge We do not believe that the gasifier is a sewage sludge incinerator

24 Permitting of MSW Gasification Projects Not all state and federal agency staff are aware of these technical and regulatory differences Communicating these differences to agency staff is critical Tell your story before someone else tells theirs

25 By-products

26 Ash and Slag Ash from high temperature gasifiers is removed in molten form, then quench-cooled to form glassy, inert, non-leachable slag Molten slag

27 Ash and Slag Use Used for making Cement Asphalt filler Roofing shingles Sand-blasting grit

28 Commercial Byproducts Sulfur Removal Sulfur Recovered in molten form Transported by rail or truck Sulfuric acid Various concentrations can be produced, depending on local markets Transported by rail or truck

29 Advantages of Gasification: Tell the Story Gasification is inherently different from combustion and incineration MSW gasification provides environmental advantages over mass-burn incineration Gasification enhances recycling Gasification produces commercially usable by-products State and federal agencies regulate gasification differently Communicating this information to agency staff is critical Tell the story, and tell it right

30 Questions??

31 Contact Info Steve Jenkins Energy & Chemicals Consulting, LLC St. Petersburg, FL