[Gasification] Clean Air Regulation requirements imposed on Waste to Energy Plants

[James Joyce]

Some questions for the group. We have been asked to comply to the following regulation regarding operation of our thermal oxidiser. My questions are:


1.       Can any technology anywhere in the world claim to comply to this regulation ?    For example 99.99% destruction efficiency means that 100 ppmw of say formaldehyde in your process off-gas has to be reduced below 0.01 ppmw, which I am sure is well below the detection limit of available detection devices.  How you demonstrate 99.9999% removal is another matter again.

2.       How many pyrolysis plants are using the nuclear fission reactions that would be necessary to destroy the metals in their list !

3.       What work around are people using to deal with emissions regulations that appear impossible to comply with ?


New South Wales
PROTECTION OF THE ENVIRONMENT OPERATIONS (CLEAN AIR) REGULATION 2010 - REG 52
52 Destruction efficiency
(1) Group 6 treatment plant (other than flares) must be operated in such a way that the destruction efficiency of the plant, in relation to an air impurity entering the plant, is:
(a) if the air impurity originates from material containing any principal toxic air pollutant-more than 99.9999%, or
(b) in any other case-more than 99.99%.
(2) An enclosed ground-level flare for the treatment of landfill gas must be operated in such a way that the destruction efficiency of the flare, in relation to landfill gas entering the flare, is more than 98%.
(3) A reference in this clause to the destruction efficiency of Group 6 treatment plant in relation to an air impurity (including landfill gas) is a reference to the destruction efficiency of the plant, in relation to the air impurity, calculated by using the following equation:
DE = (1 - MWout / MWin ) x 100

"DE" is the destruction efficiency, expressed as a percentage.

"MWout" is the mass emission rate of the air impurity in exhaust emissions prior to its release to the atmosphere using a 1 hour rolling averaging period.
"MWin" is the mass feed rate of the air impurity in a waste feedstream using a 1 hour rolling averaging period.

"principal toxic air pollutant" means any one or more of the following elements, compounds or classes of compounds:
(a) acrolein,
(b) acrylonitrile,
(c) alpha chlorinated toluenes and benzoyl chloride,
(d) arsenic and arsenic compounds,
(e) benzene,
(f) beryllium and beryllium compounds,
(g) 1,3-butadiene,
(h) cadmium and cadmium compounds,
(i) chromium VI compounds,
(j) 1,2-dichloroethane (ethylene dichloride),
(k) dioxins or furans,
(l) epichlorohydrin,
(m) ethylene oxide,
(n) formaldehyde,
(o) hydrogen cyanide,
(p) MDI (diphenylmethane diisocyanate),
(q) nickel and nickel compounds,
(r) PAH, as benzo[a]pyrene equivalent,
(s) pentachlorophenol,
(t) phosgene,
(u) propylene oxide,
(v) TDI (toluene-2,4-diisocyanate and toluene-2, 6-diisocyanate),
(w) trichloroethylene,
(x) vinyl chloride.

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