Emission limits of and waste disposal considerations for plant firing coal and plant co-firing with biomass or waste materials

Transcription

1 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

2 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

3 Situation on the Ground

4 Situation on the Ground

5 Situation on the Ground

6 Situation on the Ground

7 Situation on the Ground

8 Legislation applicable to air quality

9 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

10 National Ambient Air Quality Standards - GN 1210:2009 Pollutant Averaging period Conc. µg/m 3 FOE* Compliance date PM 10 NO 2 SO 2 CO NEMAQA: Air Pollution: Ambient Standards 24-hours immediate to 31 Dec January 2015 Annual 50 0 immediate to 31 Dec January hour Immediate Annual 40 0 Immediate 10-min (running) Immediate 1-hour Immediate 24-hours Immediate Annual 50 0 Immediate 1-hour Immediate 8-hours (running)^ Immediate * FOE Permitted Frequency of Exceedance in occurrences per year ^ Calculated on 1-Hourly averages. National Ambient Air Quality Standards for PM GN 486:2012 Pollutant Averaging period Conc. µg/m 3 FOE* Compliance date PM hours Annual 60 4 immediate January January immediate January January 2030

11 NEMAQA and Regulations Gazettes there under: Emission limits >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 New & 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-feeding Where a small boiler is fired simultaneously with two or more fuels, emission standards for the main fuel shall be applicable.

12 Environmental Management Air Quality Act Scheduled Activities and Emission limits for (NEMAQA S21 Emission limit regulations): Solid Fuel Combustion Installations 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 Existing Waste Incineration Emission limits Disposal of hazardous & general waste NEMAQA S21 Emission limit Regs Facilities for general and hazardous waste (10kg /h or larger) NEMAQA: Emission limits for scheduled emitters PM NO x SO 2 CO HCl HF Cd+Tl Hg Pb * TOC NH 3 Dioxins & furans mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 ng l_teq/nm 3 New Existing

13 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 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

14 NEMAQA and Regulations Gazettes there under: Emission limits >50MW thermal GN GN 551 Licensed facility and emission limits New & Existing with different 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 Waste co-feed Category 1.1 Solid Fuel PM NOx SO2 mg/nm3 mg/nm3 mg/nm3 New Existing Category 1.6 Combustion Category 1.6 Waste co-feed Category 1.1 Solid Fuel+ recovered waste PM NOx SO2 CO HCl HF Cd+Tl Hg Pb * TOC NH 3 Dioxins & furans mg/nm3 mg/nm3 mg/nm3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 mg/nm 3 ng l_teq/nm 3 New Existing

15 LEGAL LANDSCAPE: NEMAQA (Priority Area Air quality Management Plans) Existing Background Air Quality is a key factor Emitter Density CONFERENCE: Optimisation of Industrial Boilers

16 LEGAL LANDSCAPE: NEMAQA (Priority Area Air quality Management Plans) Existing Background Air Quality is a key factor Priority Areas CONFERENCE: Optimisation of Industrial Boilers

17 LEGAL LANDSCAPE: NEMAQA (Priority Area Air quality Management Plans) Existing Background Air Quality is a key factor Hot Spots!

18 LEGAL LANDSCAPE: NEMAQA (Priority Area Air quality Management Plans) Existing Background Air Quality is a key factor Hot Spots!

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

20 EMISSION LIMITS- Implications For Boilers

21 NEMAQA: SO2 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)

22 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) WET FGD MEL (magnesium enhanced lime) FGD system for 500MW LSD (Lime spray-dryer) (low sulphur) DRY FGD CFB (Circulating fluidised bed) (low sulphur) SO2 removal efficiency 98% 95% (when used with baghouse after scrubber) Capital cost($) Fixed operating costs($/year) Variable operating costs($/year) Reagent Disposal Byproduct credit bag replacement cage replacement Water Power Levelised cost (cents/kwhr)

23 EMISSION LIMITS- Postponement of compliance time frames

24 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

25 NEMAQA POSTPONEMENT OF COMPLIANCE TIME FRAMES 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 Impact assessment

26 NEMAQA POSTPONEMENT- EMISSIONS OFFSETTING 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.

27 NEMAQA 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.

28 Legislation applicable to energy recovery and waste disposal

29 LEGAL REQUIREMENTS FOR ENERGY RECOVERY >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 <50MW thermal GN 831 Controlled emitter and emission limits New & 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-feeding Where a small boiler is fired simultaneously with two or more fuels, emission standards for the main fuel shall be applicable.

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

31 FUELS

32 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

33 FBC INSTALLATIONS YEAR OF COMMISSIONING AND FUEL TYPE Smaller combustion plants are increasingly used to recover energy from waste materials

34 Combustion residue

35 NATIONAL ENVIRONMENTAL MANAGEMENT WASTE AMENDMENT ACT (NEMWAA) Is this waste?s

36 NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT (NEMWA) 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.

37 NATIONAL ENVIRONMENTAL MANAGEMENT WASTE AMENDMENT ACT (NEMWAA) 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]

38 NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT (NEMWA) What is it the ash that I will be recovering or disposing? Waste? Or by-product? Gypsum or ash or complex mix of things? Boiler Coal and Limestone Input 100 Coal 2 Sulphur Umgala 33 Ash Lime Stochiometry overdose fa 1.80 Ash Ash excl CaO MgO 71% Output CaSO4 19% CaO added above stoch 6% CaO Ash inherent 3% MgO 1% Total Product 100%

39 NATIONAL ENVIRONMENTAL MANAGEMENT WASTE AMENDMENT ACT (NEMWAA) 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

40 NATIONAL ENVIRONMENTAL MANAGEMENT WASTE AMENDMENT ACT (NEMWAA) 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

41 Conclusions

42 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

43 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