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James,<br>
<br>
I liked Kevin & Doug's wise replies. As you are aware from our
personal discussions we covered this issue at some length with the
NSW EPA at their invitation back in 2013. The core issues have not
changed and you remain definitely up against it. What you are
experiencing now is the reason we opted for a hybrid plant that uses
our gasifier to manage emissions, designing and building the
pyrolysis section ourselves now since no one with existing working
designs believed the approach we offered was necessary. <br>
<br>
The EPA did warn the emerging pyrolysis industry that their apparent
belief that they could apply sufficient political pressure to have
the regulator water down requirements would fail, and that companies
would need to address the issues rather than expect to be able to
ignore them. As you will be aware even those who have enjoyed
considerable Government largesse over the last decade, recieving
millions in public monies, are not exempt from this hence why they
are big on press releases but non existent on working commercial
projects.<br>
<br>
Your a)....d) point list is why the NSW draft waste to energy policy
issued started with prescriptions based on combustion incinerators.
We successfully argued against this since it precluded approaches
other than combustion as a suitable technology, and the final
release version recognises this by setting targets rather than
prescribing things like minimum combustion zone residence times,
allowing then for innovation in the private sector as to how best to
meet the requirement.<br>
<br>
Essentially though it is recognised that pyrolysis systems <u>can</u>
operate under conditions that encourage dioxin and other nasties or
result in above background level release. You can argue till you're
blue in the face that yours doesn't, but at the end of the day you
have to prove it. The onus is on you to do so, not the EPA to prove
you are. Then you have to follow up and confirm it still isn't later
on down the track after you have been operating for a bit, and then
every time someone with little knowledge and a lot of fear (or
simply penchant for stirring trouble, like jealous competitors) lays
a complaint that you might be. The upshot being you will need to
budget for more than one expensive test...and any licensing granted
is only on a project by project basis.<br>
<br>
We were invited to apply for a General Exemption for our own system
as they are satisfied that our plant design could inherently satisfy
the legislation, we have not followed through yet simply because
this too still has confirmation testing and costs associated, is
scale dependent, and has to be repeated for each feed stock change
(Cotton gin trash vs woody wastes from composting operations for
example) so we see it as part of the client expense in the first
instance, and secondly the most likely path for us is offshore due
to continued seemingly Government backed attempts to misappropriate
our IP for the benefit of some of their mates. I don't say this
lightly either, it is currently the focus of a formal fraud
investigation.<br>
<br>
$3000 per sample seems on the low side of quotes we had, $5000 being
the norm. $10,000/day is the cost for a independent technicion to
come to the plant for the same purpose. Any hint, real or perceived,
that you might have fudged the sampling whilst doing it yourself can
prove very, very expensive, particularly where the results are not
accepted and you have to get independent qualified testers involved,
who then come up with adverse results... Hence why established
industry opts for the independent testing route in the first
instance. As an aside this is also the reason we have a properly
engineered gas sampling column to ensure representative samples
built into our latest 500kg/hr industrial scale gasifier module, it
has already been noted by visiting scientists/engineers as "uncommon
practice" but "very smart" (the same scientists who after the
demonstration also recommended we stop calling it a gasifier, not
because it isn't, but because the association with standard industry
expectations of performance does it a grave disservice).<br>
<br>
Assuming you successfully negotiate the testing, don't forget you
will also need to demonstrate how you can address shoddy or
uneducated users of your plant changing the operating parameters or
allowing in problematic feed stocks that increase the risk of
exceeding the emission limits.<br>
<br>
Good luck.<br>
<br>
Peter<br>
<br>
<br>
<br>
<br>
<br>
<div class="moz-cite-prefix">On 30-Jun-14 4:00 AM,
<a class="moz-txt-link-abbreviated" href="mailto:gasification-request@lists.bioenergylists.org">gasification-request@lists.bioenergylists.org</a> wrote:<br>
</div>
<blockquote
cite="mid:mailman.1.1404064801.2916.gasification_lists.bioenergylists.org@lists.bioenergylists.org"
type="cite">
<pre wrap="">Message: 3
Date: Sun, 29 Jun 2014 07:48:07 +0000
From: James Joyce <a moz-do-not-send="true" class="moz-txt-link-rfc2396E" href="mailto:james@jamesjoyce.com.au"><james@jamesjoyce.com.au></a>
To: <a moz-do-not-send="true" class="moz-txt-link-rfc2396E" href="mailto:gasification@lists.bioenergylists.org">"gasification@lists.bioenergylists.org"</a>
<a moz-do-not-send="true" class="moz-txt-link-rfc2396E" href="mailto:gasification@lists.bioenergylists.org"><gasification@lists.bioenergylists.org></a>
Subject: Re: [Gasification] Dioxins ...was Clean air ..
Message-ID:
<a moz-do-not-send="true" class="moz-txt-link-rfc2396E" href="mailto:4C71E96F48AF454D99A0EAE2C116A34A5732721F@MBX-002.ezyexchange.net.au"><4C71E96F48AF454D99A0EAE2C116A34A5732721F@MBX-002.ezyexchange.net.au></a>
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Leland, regarding costs. I have had two scenarios described to me, one where the sample device is provided and I take the sample (therefore up to me to make that representative) and one where a technician comes in to collect the sample. I believe the $3000 applies to the first case ... ie. sampling is an additional cost.
If you are referring to on-line or at-line GS-MS or Gel chromatography I am interested to hear about experiences with these techniques. Our plant operators are not qualified instrument techs or lab techs ... which means at best the devices would get a check over on a monthly basis during scheduled plant visits.
My interest in the bag filter was with respect to particulates. This relates to dioxin in that they tend to be adsorbed onto the particulates (although perhaps more so at <300 deg C than 600 deg C), so it is one way to remove dioxins and their precursors if they are present. Some plants I understand actually inject fine carbon into their flue gas for this very purpose.
Kevin, on your comments about Chlorine and copper, I have been maintaining a watching brief for some time on the topic and from what I understand Chlorine levels are in fact poorly correlated with Dioxin emissions, arguably because the chlorine levels in most feedstocks, even at ppm levels are many many times the quantity needed to make the tiny amounts of Dioxins that regulators are checking for. I read a very good review of the science just last week. If anyone wants the reference I could dig it out next week. The review of a looked critically at a variety of data on Dioxin formation and control. My interpretation of the their conclusions is that Dioxin emissions from pyrolysis, gasification and combustion processes are:
(a) Very poorly correlated with Chlorine levels, with the exception of a few industrial chemicals (not biomass)
(b) Strongly correlated to completion of combustion and the residence time of flue gases between 200 - 400 deg C (the desired residence times in this range were less than 1.6 seconds ...which perhaps does not bode well for torrefaction ! ... and hot running electrostatic precipitators)
(c) Catalysed by copper and copper compounds .. which in turn are inhibited by the presence of sulphur.
(d) Sometimes dictated by the dioxin content of the incoming feedstock rather than formation in the process
If anyone has done Dioxin measurements on flue gases from thermal processing of biomass I certainly would be interested in their experiences.
Regards,
James
</pre>
</blockquote>
<br>
<pre class="moz-signature" cols="72">--
Peter Davies
Director
ID Gasifiers Pty Ltd
Delegate River, Victoria
Australia
Ph: 0402 845 295</pre>
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