Interesting Determinations Non-Hazardous Secondary Materials (NHSM) PCA MTC Meeting August 26, 2013

Transcription

1 Interesting Determinations Non-Hazardous Secondary Materials (NHSM) PCA MTC Meeting August 26, 2013

2 Overview Brief reminder on what NHSM is Recent/Interesting Non-Waste fuel determinations

3 NHSM Definition NHSM Definition provides a procedure for industry to determine if a non-traditional fuel is a solid waste when combusted Non Traditional Fuel Non Waste NHSM Waste Haz. Waste PC MACT Lime MACT Boiler MACT CISWI HWCMACT

4 Traditional Fuel Materials that are produced as fuels and are unused products that have not been discarded and therefore, are not solid wastes, including:

5 Solid Waste or Non-Waste Fuel? NHSMs are not solid wastes when combusted if meeting the legitimacy criteria, and are: 1. Fuels that remain within the control of the generator, or 2. Fuels not managed within the control of the generator, but are not discarded Application must be submitted to EPA for non-waste determination, or 3. Used as an ingredient, or 4. Fuels or ingredients produced from discarded NHSMs

6 Legitimacy Criteria Overview Fuels Managed as valuable commodity Meaningful heating value Contain contaminants or groups of contaminants at levels comparable to traditional fuels a unit is designed to burn Designed to burn not the same as permitted to burn Ingredients Similar to above, and must provide a useful contribution, and produce a valuable product.

7 EPA Comfort Letters Facilities may want extra assurance that their nontraditional fuel is not a solid waste EPA is willing to provide comfort letters Since the NHSM Rule was updated in (2/2013), EPA has received around 20 requests EPA estimates it will take 6-8 months to respond to a request Current EPA responses:

8 Recent EPA Comfort Letters Coal Ash; We Energies, June 26, 2013 Engineered Fuel from Industrial Sources; VEXOR Technology, May 8, 2013 Paper fluff pellets; Strategic Materials, Apr 17, 2013 Poultry Litter; Response to Wellons Energy Solutions, March 11, 2013 Fuel Cubes; Response to Roaring Springs, February 6, 2013 ReEngineered Feedstock; Response to ReCommunity, August 24, 2012 State Comfort Letters Activated carbon used in corn syrup production in place of coal/coke

9 Case Study: Coal Ash Material EPA 7/26/13 Comfort Letter : Energy company recovers coal ash material from its landfills Energy company will process the coal ash material with virgin coal Use processed material as fuel for energy recovery Subsequent coal ash will be used in cement/concrete Heating value of coal ash material is 2,500 Btu/lb Coal ash material is stored 1-7 days prior to blending with virgin coal

10 Case Study: Coal Ash Material Is it Processed? Excavate from on site legacy monofills Sent to a staging area to drain excess water/air dry, which improves combustion efficiency Coal ash material is crushed/screened and debris is removed, which improves combustion efficiency Blended with virgin coal (1 5% coal ash/99 95% virgin coal) Pulverized into a powder, where heavier density products are separated from the powder and rejected Yes We [EPA] believe that the processing of the coal ash material with virgin coal (and in the same type of processing operations as virgin coal) meets the definition of processing. Next Step: Review the Legitimacy Criteria

11 Case Study: Coal Ash Material Legitimacy Criteria Valuable Commodity Is it a Valuable Commodity? NHSM must be stored and used within reasonable time frames NHSM must be managed in a manner that prevents releases to the environment The coal ash material meets the following criteria: Stored analogous to that of virgin coal Stored for 1 7 days prior to blending with the virgin coal EPA concluded the material is managed as a valuable commodity

12 Case Study: Coal Ash Material Legitimacy Criteria Meaningful Heating Value Meaningful Heating Value? 5,000 Btu/lb or higher, in general If heating value <5,000 Btu/lb need to prove that the combustion unit can cost effectively recover meaningful energy from the secondary material. The coal ash material has a heating value of 550 to 2,500 Btu/lb. However, energy contributed by burning the carbon in the coal ash is equivalent to 21,150 pounds of coal per day, which We Energies then avoids having to buy EPA determines that this figure is a meaningful energy contribution. Coal ash material does have a meaningful heating value.

13 Case Study: Coal Ash Material Legitimacy Criteria Contaminant Levels (1 of 2) Contaminant Levels similar to traditional fuel? NHSM must contain contaminants at levels comparable in concentration to or lower than those in traditional fuels that the combustion unit is designed to burn. Direct comparison between NHSM and all traditional fuels that the boiler is capable of combusting

14 Case Study: Coal Ash Material Legitimacy Criteria Contaminant Levels (2 of 2) Pollutant Coal (ppm) Coal Ash Material (ppm) Arsenic Chromium Lead Mercury Chlorine The coal ash material meets the legitimacy criterion for contaminant levels when compared to coal.

15 Interesting EPA Considerations Comfort letter did not address legitimacy criteria for ingredients discarded material is ultimately used in kiln EPA did comment that it considered the coal ash based on components 1 st component unburned coal 2 nd component Ingredient

16 Activated Carbon Used for refining corn syrup Previously sent to landfill Requested concurrence from state agency that future spent carbon could be used in place of coal/coke as a non-waste fuel. Reviewed legitimacy criteria State agreed with facility

17 Arron Heinerikson Regional Director 9777 Ridge Drive, Suite 380 Lenexa, KS P: E: