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

[linvent at aol.com]

 	This standard is not uncommon and most of it is just verbiage to cover as many sources as possible. If below detection limit, or not in the input gas,  then it complies. The measurement is very expensive using standard US EPA 
methodologies, but there is equipment that can be used to detect below the standard methods of analysis and costs around the same cost as one comprehensive gas analysis, which could be
$35-60k in US terms. 
	The best way to comply is to remove as many of the contaminants as possible before the fume incinerator or flare. I can go into more detail, and indeed there may be a very inexpensive way of complying
if they would accept it, but I don't do it for free. 
Sincerely,
Leland T. "Tom" Taylor
Thermogenics Inc.?



-----Original Message-----
From: James Joyce <james at jamesjoyce.com.au>
To: gasification <gasification at lists.bioenergylists.org>
Sent: Sat, Jun 21, 2014 4:36 pm
Subject: [Gasification] Clean Air Regulation requirements imposed on Waste to Energy Plants

          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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