NEMAQA Scheduled Processes and Controlled …...LSD (Lime spray-dryer) (low sulphur) CFB...

NEMAQA Scheduled Processes and

Controlled Emitters: Emission Limits for Boilers and Compliance Timeframes

19 September 2013

Theo Fischer, EScience Associates

[email protected]

mailto:[email protected]

NEMAQA Scheduled Processes and Controlled Emitters

Situation on the ground

Legislative landscape

Constitution

NEMA

NEMAQA and its Gazettes

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 (as per GN 248:2010)

Motivation for extension

Offsets

CONFERENCE: Optimisation of Industrial Boilers

Situation on the Ground


Situation from the Air


Situation on the Ground

Situation on the ground

Legislative landscape

Constitution

NEMA

NEMAQA and its Gazettes

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 (as per GN 248:2010)

Motivation for extension

Offsets


LEGAL LANDSCAPE

(Constitutional Environmental Rights)

Section 24 of the Constitution provides the following:

Everyone has the right :

to an environment that is not harmful to their health or well-being; and

to have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that

prevent pollution and ecological degradation;

promote conservation; and

secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development


LEGAL LANDSCAPE (NEMA and Duty of Care)

NEMA constitutes the primary law in terms of which integrated environmental management and environmental impact assessment is carried out and applied

NEMA places a duty of Care on all persons who may cause significant pollution or degradation of the environment


LEGAL LANDSCAPE: Transition from APPA to NEMAQA (NEMAQA)

There has been a shift in Air Quality Management from a sourced based and best practicable means (BPM) approach under the Air Pollution Prevention Act (APPA), Act 45 of 1965)

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 for substances resulting from a listed activity

NEMAQA 2010 Emission limit regulations was brought in to full force on 01 April 2010 and has superseded APPA

Many responsibilities for air quality management have been devolved down from the national level to the local authority level (district and metropolitan municipalities)

Provision for Priority Air Pollution Areas and Air Quality Management Plans


LEGAL LANDSCAPE: Transition from APPA to NEMAQA (Air Pollution: Ambient Standards)

National Ambient Air Quality Standards - GN 1210:2009

Pollutant Averaging period Conc. µg/m3 FOE* Compliance date

PM10 24-hours

120 4 immediate to 31 Dec 2014

75 4 1 January 2015

Annual 50 0 immediate to 31 Dec 2014

40 0 1 January 2015

NO2 1-hour 200 88 Immediate

Annual 40 0 Immediate

SO2

10-min (running) 500 526 Immediate

1-hour 350 88 Immediate

24-hours 125 4 Immediate

Annual 50 0 Immediate

CO 1-hour 30 88 Immediate

8-hours (running)^ 10 11 Immediate

* FOE – Permitted Frequency of Exceedance in occurrences per year

^ Calculated on 1-Hourly averages.


National Ambient Air Quality Standards for PM2.5 - GN 486:2012

Pollutant Averaging period

Conc. µg/m3

FOE* Compliance date

PM2.5

24-hours 60 4 immediate

40 4 01 January 2016 25 4 01 January 2030

Annual 25 0 immediate 20 0 01 January 2016 15 0 01 January 2030

LEGAL LANDSCAPE: NEMAQA (Source Control)

Environmental Management Air Quality Act Scheduled Activities and Emission limits for (NEMAQA S21 Emission limit regulations):

Solid Fuel Combustion Installations Emission limits

Waste Incineration 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 50 750 500

Existing 100 1100 3500

Disposal of hazardous & general waste NEMAQA S21 Emission limit Regs Facilities for general and hazardous waste (10kg /h or larger)

PM NOx SO2 CO HCl HF Cd+Tl Hg Pb…* TOC NH3 Dioxins &

furans

mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 ng l_TEQ/Nm3

New 10 200 50 50 10 1 0.05 0.05 0.5 10 10 0.1

Existing 25 200 50 75 10 1 0.05 0.05 0.5 10 10 0.1

LEGAL LANDSCAPE: NEMAQA (Controlled Emitters: Small Boilers)

In November 2012, the minister of DEA gazetted the intent to declare small boilers as controlled emitters under section 57(1)(a) and section 23 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004)

Draft Declaration applies to all boilers with design capacities of between 10 to 50 megawatts net heat input, capable of burning biomass, solid, liquid and/or gaseous fuels or a combination of these.

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 2017.


LEGAL LANDSCAPE: NEMAQA (Controlled Emitters: Small Boilers)

New small boilers must comply with the new small boiler emission standards while existing small boiler must comply with these standards by 2017.


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

Existing Background Air Quality is a key factor – Priority Areas


LEGAL LANDSCAPE: NEMAQA (Source control- Compliance time frames)


Both PM and SO2 requires reduction

PM reduction does not pose that much of a problem as PM emission reduction has been implemented to varying degrees utilising various technologies

SO2 emission reduction is however a problem as apart from a very few instances is new to industry in SA


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 50 750 500

Existing 100 1100 3500

IMPLICATIONS FOR BOILERS: NEMAQA

Source control- Compliance time frames

New plant must comply with the new plant minimum emission standards on 1 April 2010.

Existing plant must comply with minimum emission standards for existing plant within 5 years of the date of publication of the Notice [April 2015].

Existing plant must comply with minimum emission standards for new plant within 10 years of the date of publication of the Notice [April 2020].



Options for SO2 emission reduction:

Raw material changes

Low sulphur coal

Coal sulphur reduction (Washing, other)

Abatement

LSD (Lime spray dryer) dry FGD

Wet limestone FGD

Circulating Fluidized bed absorber (CFB)

Retrofitting abatement requirements (costly)




Adapted from: Economics of Lime and Limestone for Control of Sulphur Dioxide (DePriest and Gaikwad 2001)


LSFO (Limestone forced

oxidation)

MEL (magnesium

enhanced lime)

LSD (Lime spray-dryer)

(low sulphur)

CFB (Circulating fluidised

bed) (low sulphur)

SO2 removal efficiency

Capital cost($) 64 451 000 54 665 000 61 291 999 66 914 000

Fixed operating costs($/year) 3 929 000 3 574 000 2 539 000 271 000

Variable operating costs($/year) 4 369 000 5 527 000 4 202 000 4 089 000

Reagent 2 059 000 3 847 000 2 769 000 2 670 000

Disposal 0 0 1 071 000 1 057 000

Byproduct credit 0 0 0 0

bag replacement 0 0 341 000 341 000

cage replacement 0 0 21 000 21 000

Water 208 000 208 000 102 000 102 000

Power 2 102 000 1 472 000 1 156 000 841 000

Levelised cost (cents/kWhr) 0.57 0.57 0.49 0.49

98% 95% (when used with baghouse after scrubber)

FGD system for 500MW

WET FGD DRY FGD

To meet these regulations emitters may need to incorporate abatement technologies in the design phase



LEGAL LANDSCAPE: NEMAQA (Postponement of compliance time frames)

An application may be made to the National AQO for the postponement of the compliance time frames for an existing plant (S 5.4.3.5 of the National Framework for Air Quality Management - 2007). Should include:

an Atmospheric Impact Report (requires dispersion modelling and air quality impact assessment)

a detailed justification and reasons for the application; and

a certified copy of the announcement of the intention to seek postponement in, at least, one newspaper distributed in the area affected by the specific plant

The National Air Quality Officer with the concurrence of the Licensing Authority

may grant a postponement of the compliance time frames in 5 for an 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


LEGAL LANDSCAPE: NEMAQA (Implications for emitters)

Procedure for extension of compliance timeframes may be costly, it includes

an Atmospheric Impact Report

a detailed justification and reasons for the application; and

a certified copy of the announcement of the intention to seek postponement in, at least, one newspaper distributed in the area affected by the specific plant


LEGAL LANDSCAPE: NEMAQA (Motivation for extension)

Meteorlogy 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

LEGAL LANDSCAPE: NEMAQA (Implications for emitters: Motivation for extension)

Atmospheric Stability



Existing Background Air Quality is a key factor – Emitter Density



Existing Background Air Quality is a key factor – Hot Spots!



Typical Dispersion modelling results – Source Only



Typical Dispersion modelling results - Background



Typical Dispersion modelling results - Cumulative


LEGAL LANDSCAPE: NEMAQA (Emissions Offsetting)

Emissions offsetting

Air Quality offsets are a type of “environmental offset”

The department is currently using the following definition for environmental offsets –

“An environmental offset is an intervention, or interventions, specifically implemented to counterbalance an adverse environmental impact of land-

use change, resource use, discharge, emission or other activity at one location that is implemented at another location to deliver a net

environmental benefit”.


LEGAL LANDSCAPE: NEMAQA (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.”


Summary Development History (Cont.)

June 2010 – DEA makes a presentation during the Highveld Priority Area Logical Framework Air Quality Management Planning Workshop held at the Protea Hotel in Witbank from 3 to 4 June 2010 entitled “Offsets as a Strategy for Cost Effective Air Quality Improvements”.

July 2010 – Escience Associates (Pty) Ltd share a summary of a proposed atmospheric emission offsetting process with the DEA. In summary, the process has two components:

A prefeasibility process (typically undertaken as part of an EIA air quality impact assessment) and

A feasibility process (yielding initial conditions of approval), undertaken as part of the Atmospheric Emission Licensing process (yielding licensing conditions)

More Recent Developments

October 2010 – Escience Associates (Pty) Ltd present their proposed atmospheric emission offsetting process during the 2010 Air Quality Week in Polokwane

July 2011 – Eskom initiates its “Household Emission Offset Pre-Feasibility Study”

Current Developments

April 2012 – policy development work relating to progressing the air quality offset concept is included in the Annual Performance Plan of the DEA’s Directorate: Atmospheric Policy, Regulation and Planning

June 2012 – DEA management approve – That the overall environmental offset concept is popularised through, among

others, the compilation and dissemination of a discussion document coupled with various outreach activities;

That, informed by feedback from the outreach process, a general overall policy on environmental offsets and their use is developed in parallel with the development of the more detailed policies and guidelines on, for example, biodiversity offsets;

That work is initiated on developing more detailed policies and/or guidelines on national carbon offsetting and air quality offsetting;

Draft Policy will be presented at Air Quality Lekgotla 30 September 2013


Inevitability of compliance

These are legal requirements i.e. all operations which are in the list of activities must comply with the regulations.

There must be headroom for economic growth whilst not compromising air quality and health of population


NEMAQA Scheduled Processes and

Controlled Emitters: Emission Limits for Boilers and Compliance Timeframes

19 September 2013

Theo Fischer, EScience Associates

[email protected]

mailto:[email protected]

NEMAQA Scheduled Processes and Controlled …...LSD (Lime spray-dryer) (low sulphur) CFB...

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