Redbank Power Station QA/QC, Supply Chain and Material ...

Level 33, 52 Martin Place, Sydney, NSW, 2000 Australia

Redbank Power Station QA/QC, Supply Chain and Material Handling

Final report: 30 July 2021

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Contents 1. Executive Summary ......................................................................................................................... 5

2. Sources of Feedstock ...................................................................................................................... 6

2.1 Suppliers of eligible waste fuels – forestry and sawmilling residues. ............................. 6

2.2 Suppliers of eligible waste fuels – uncontaminated wood waste ................................... 7

2.3 Use of Coal Tailings as a Fuel ........................................................................................... 7

2.4 Feedstock Schematic Diagrams ....................................................................................... 8

2.4.1 Feedstock Supply Chain Over view .................................................................................. 8

2.4.2 Stage 1 Forestry and sawmill residues (Eligible fuels). .................................................... 9

2.4.3 Stage 2A Forestry wastes, sawmill residues and uncontaminated wood waste (Eligible

fuels). ............................................................................................................................. 10

2.4.4 Draft procedure for gaining a Specific Resource Recovery Order and Exemption to use

forestry waste, sawmilling and uncontaminated wood waste as fuel. ......................... 11

3 Feedstock Criteria QA/QC ............................................................................................................. 12

3.1 Purpose of Procedure .................................................................................................... 12

3.2 Fuel Characteristics ........................................................................................................ 12

3.3 Manufacturing facility QA, QC and Testing – Forestry and Saw Milling Residues. ........ 15

3.3.1 HRL Moisture Over Time Analysis for Forestry Waste................................................... 15

3.4 Manufacturing facility QA, QC and Testing – Uncontaminated wood waste. ............... 16

3.5 Sourcing Eligible Waste Fuels QA-QC ............................................................................ 17

3.5.1 Processing sites/facilities ............................................................................................... 17

3.5.2 Site Preparation ............................................................................................................. 17

3.5.3 Residue Management .................................................................................................... 18

3.5.4 Carbon Balance .............................................................................................................. 18

3.5.5 Contribution to Carbon Cycles ....................................................................................... 18

3.5.6 Anticipated forestry sources and transport routes ....................................................... 19

3.5.7 Auditable chain of custody ............................................................................................ 19

3.6 Receipt of feed stock ..................................................................................................... 20

3.7 Storage of feed stock ..................................................................................................... 21

3.8 Additional Sampling and Testing of feedstock .............................................................. 21

3.9 Notification and Reporting ............................................................................................ 22

3.10 Additional Record Keeping Requirements ..................................................................... 22

3.11 Residual Ash Management ............................................................................................ 23

3.11.1 Ash Produced from Use of Biomass as Fuel ................................................................... 23

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3.11.2 Ash from Coal Tailings .................................................................................................... 23

4 Material Transport ........................................................................................................................ 24

5 Redbank Material Acceptance and Storage .................................................................................. 25

5.1 Safety and Risk Management ........................................................................................ 28

5.2.1 Traffic flows ................................................................................................................... 28

5.2.2 Transport Fleet Configuration ....................................................................................... 28

5.2.3 Fire ................................................................................................................................. 28

Appendix 1 ................................................................................................................................ 29

Verdant Earth Feedstock Production QA/QC ........................................................................ 29

Appendix 2 ................................................................................................................................ 30

EPA Energy from Waste Policy .............................................................................................. 30

Appendix 3 ................................................................................................................................ 31

Eligible waste Fuels Guidelines ............................................................................................. 31

Appendix 4 ................................................................................................................................ 32

Ash from Burning Biomass Order and Exemption 2014 ....................................................... 32

Appendix 5 ................................................................................................................................ 33

Ash from Coal Ash Order and Exemption 2014 .................................................................... 33

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1. Executive Summary The Redbank Power Station was commissioned in July 2001 to use coal tailings as main fuel

and run of mine coal as a backup fuel. The plant consists of two fluidised bed combustion

steam generator units of FiCirc® design and a single 151MW steam turbine and associated

balance of plant equipment. The station has been in care and maintenance mode since

October 2014 and Verdant Energy are planning to restart the plant by using 100% Biomass.

Biomass is defined in the NSW EPA’s Eligible Waste Fuel Guidelines as forestry residues,

sawmilling residues and clean uncontaminated wood waste. This project will focus on

securing quality fuels that are considered residual materials in forestry operations,

sawmilling and from urban sources (e.g. timber manufacturing) to provide a new sustainable

fuel source for the power station.

Redbank Power Station’s FiCirc® fluidised bed combustion system is designed to operate

with a wide range of fuels such as coal tailings and biomass fuels. Investigations have been

performed to scope minor changes to the fuel delivery and handling systems at Redbank to

enable the plant to receive Biomass fuels that have been fully prepared, tested and validated

for storage and use as a replacement fuel in the plant.

Verdant Earth have identified sources of eligible feedstocks to utilise as a

supplementary/replacement Biomass fuel for supplying heat to the boiler within generally a

300 km radius of the Warkworth plant that comply with the NSW EPA’s Eligible Waste Fuel

Guidelines and clauses 96 to 98 of the Protection of the Environment Operations (General)

Regulation 2009 (in relation to the use of native forestry biomass for electricity generation):

• pulp wood logs and heads and off-cuts from clearing carried out in accordance with

a private native forestry property vegetation plan or forestry operations carried out

in accordance with an integrated forestry operations approval under Part 5B of Part

A of the Forestry Act 2012;

• trees cleared as a result of thinning carried out in accordance with a private native

forestry property vegetation plan or an integrated forestry operations approval;

• sawdust or other sawmill waste;

• uncontaminated wood waste includes pre-consumer manufacturing and processing

waste materials such as off-cuts, saw dust, wood shavings, untreated packaging

crates, untreated pallets and engineered timbers made with urea formaldehyde or

phenol formaldehyde resins only.

This report provides an overview of the sources, proposed quality assurance and quality control

processes, transport and handling of the Biomass fuels at the power station to ensure that the

facility is provided with quality fuels at all times that meet all regulatory requirements.

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2. Sources of Feedstock

2.1 Suppliers of eligible waste fuels – forestry and sawmilling residues.

The total estimated volumes for the North Coast are close to one million tonnes. 1

There is a further estimated minimum two million tonnes of available residues per annum

from harvesting operations of private native plantation operations that are otherwise left

and burnt in mass in situ.

Sawmill residues (green) were estimated to range between 46,000 tonnes/year from around

Bulahdelah to 118,000 tonnes/year for facilities around Kempsey (100 km radius). Green

offcuts represented approximately 68% of the total volume of green residues produced. 2

Additional important sources of biomass include residues from agricultural crops (45,000 -

78,000 tonnes/year) and waste currently disposed of in landfills (approximately 700, 000

tonnes/year).3

Further residues are available to Verdant Earth and estimated at minimum 500,000 tonnes

per annum through land clearance, bushfire zoning and other activities carried out in

accordance with an integrated approval under the Forestry Act 2012

Verdant Earth staff have been working with recognised producers of boiler fuels and

woodchip manufactures across the industry and have signed MOU’s to supply with eligible

fuels.

We have identified and have had discussions with a 15-20 suppliers of woody biomass for

the supply of eligible fuels as identified by the EPA.

Once Redbank has been approved to undertake the modification to the feed system of the

plant to utilise waste woody biomass Verdant Earth staff will be in a strong position to

negotiate supply contracts will additional woody biomass processors if required.

It is important to note that the woody waste biomass feedstock materials will be recovered

from forestry and sawmill sites in many parts of regional NSW. Verdant Earth is working

with key companies that operate within the industry to establish centralised manufacturing

facilities with in a 300km radius of the Power Station to process the materials to the required

Redbank specification in accordance with the Specific Resource Recovery Order issued by

the EPA (post approval). Suppliers may or are likely to vary and change from year to year as

market conditions dictate.

Where appropriate, Verdant Earth will work directly with contractors of forestry operations

to bulk haul biomass that meets specifications directly to the Redbank Power Station. In

these cases, the woody biomass may be sized reduced and stockpiled at locations in the

forest compartment in accordance with existing approved management plans. Stockpiles will

be sampled, tested for compliance with the Specific Resource Recovery Order and then bulk

1 Source DPI North Coast Residues: A project undertaken as part of the 2023 North Coast Forestry Project 2017 2 Source DPI North Coast Residues: A project undertaken as part of the 2023 North Coast Forestry Project 2017 3 Source DPI North Coast Residues: A project undertaken as part of the 2023 North Coast Forestry Project 2017

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transported directly to the plant. This will be performed in cases where this can be

conducted on site, where space is available and where current forestry operations permit

this activity.

It is estimated that approximately 70% of the biomass sourced for the plant will be obtained

from approved forestry residues, 15% from sawmill operations and 15% from

uncontaminated wood wastes by weight.

2.2 Suppliers of eligible waste fuels – uncontaminated wood waste

Wood waste that is generated in primary and secondary manufacturing processes at

facilities with demonstrated quality control over the uncontaminated waste stream.

Uncontaminated wood waste excludes:

• Post consumer waste;

• Wood waste extracted from the mixed waste streams, such as construction and

demolition waste.

Verdant Earth have been developing supply agreements with 9 companies that have

commercial volumes available of uncontaminated wood waste, it is however important to

note that Suppliers may or are likely to change from year to year as market conditions

dictate.

2.3 Use of Coal Tailings as a Fuel

The Hunter Valley has a rich history in traditional coal mining activities dating back to the early

1900’s and in that time there have been legacy sites that have been exhausted of coal or just closed

for economic reasons.

Some of those legacy sites may contain coal tailings that require removal and disposal/use. The

Redbank Power station has a licence to operate using coal tailings and while we are proposing to run

pretty well exclusively on waste woody biomass there may become sound environmental reasons to

utilise approved coal tailings.

It is noted that the Redbank Power Station will retain the ability to use coal tailings as a fuel. This

material will not be blended or co-fired with biomass. If the plant after using biomass as fuel chooses

to use coal tailings, all woody biomass in the approved storage location will be fully utilised, and the

area cleared before coal tailings are then stored as fuel. No changes to the plant will be required to

re-commence the use of coal tailings. Operational controls of the plant will be adjusted to ensure

that the fuel / air mixing ratios are maximised for plant efficiency in accordance with approved

operational conditions.

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2.4 Feedstock Schematic Diagrams

2.4.1 Feedstock Supply Chain Over view

Eligible Waste Fuels

Forestry

Maintain agreed feedstock

volumes est 5 days minimum

Feedstock processing sites

• Sweetmans

• Burgundy Heights

• TBA

• TBA

Load and transport in B double

configuration max load

44 tonne, availability 7 days

per week


Uncontaminated Wood waste

Maintain agreed feedstock

volumes est 5 days minimum

Feedstock processing sites

• Central Waste Station

•

Load and transport in B double

configuration max load

44 tonne, availability 7 days

per week

Identify trailer

configurations and

suppliers

Identify trailer

configurations and

suppliers

Redbank Feedstock

Acceptance and Storage

Weighbridge

1x Incoming

1x Outgoing

DATA COLLECTION

• Truck Registration• Date/Time• Customer/ Feedstock

Source• Material Category

• Gross weight (on the way in)• Tare weight (on the way out)• Net weight (calculated, GW-

TW = NW)

Drive over bulk unloading hopper bins

• 1 transport feedstock to the power

station feed hopper

• 1 transport feedstock direct to

stockpile area

Feedstock transfer telescopic conveyor

belts (est 4)

Feedstock hopper bin est

90M3

Power station feedstock

dosing hopper

Radial stackerFeedstock stockpile estimate

2.5 Days storage

Transfer telescopic

conveyor

Wheel loaders x 2

ensure back up

2 Transfer conveyors 2 Transfer Conveyors

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2.4.2 Stage 1 Forestry and sawmill residues (Eligible fuels).

GR

IND

ER/

SHR

EDD

ERU

NLO

AD

ING

SC

REE

NIN

G

MIX

ING

QA

/QC

FUEL

(1)LOGS

(2) TIMBER MILL

OFFCUTS

DOUBLE DECKSCREEN

FUEL CHIP

GRINDING SHREDDING

PRODUCT PLUS 10/MINUS 50

OVERSIZE PLUS 50

PRODUCT MINUS 10

(3) VIRGIN WOOD CHIP

WASTE

STORAGE 2

DISPOSAL 1

Testing – Testing and validation of fuel to ensure compliance with the Specific Resource Recovery Order and Exemption

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2.4.3 Stage 2A Forestry wastes, sawmill residues and uncontaminated wood waste (Eligible fuels).

GR

IND

ER/

SHR

ED

DER

Fuel

So

urc

eSC

REE

NIN

G M

IXIN

G P

ELLE

TISI

NG

Q

A/Q

CFe

edst

ock

(1)LOGS

(2) TIMBER MILL

OFFCUTS

(5) PROCESS

ENGINEERED FUEL (WOODCHIP)

DOUBLE DECKSCREEN

PELLETISING MACHINES

Sampling, testing and validation of fuel to ensure compliance with the Specific Resource Recovery Order and Exemption.

GRINDING SHREDDING

PRODUCT PLUS 10/MINUS 50

OVERSIZE PLUS 50

PRODUCT MINUS 10

(3) VIRGIN WOOD CHIP

CONDITIONING UNIT

(4) SAWDUST

WoodchipWood pellets

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2.4.4 Draft procedure for gaining a Specific Resource Recovery Order and Exemption to use forestry waste, sawmilling and uncontaminated wood

waste as fuel.

Feedstock Approval Process

Verdant Earth lodge application

for an exemption to use

approved eligible Waste fuel

Forrestry, Sawmilling residues

& Uncontaminated Wood Waste

Verdant Earth lodge HRL QA/QC

documents to support use of

eligible fuel as feedstock fuel

Verdant Earth provide copies of

feedstock specification to EPA

for approval

EPA approves the use of eligible

fuel made to specification Feedstock Manufacturer

apply for a resource

recovery order to

manufacture feedstock

Verdant Earth and HRL staff

implement ongoing QA/QC

process to ensure feedstock

complies with Redbank

Exemption.

Verdant Earth and

manufacturing facility

agree to develop a process

to manufacture and supply

feedstock to specification

for use at the Redbank

power station

Verdant Earth staff assess

the process to determine

compliance with relevant

regulations

Feedstock manufacturer

provide feedstock for EPA

authorised trial

Feedstock manufacture 1,000

tonnes to Specification create

10x100t lots

HRL take 1 sample from each lot

for analysis to ensure compliance

with specification.

Each lot is analysed as a discreet

sample &

A composite sample is prepared

and analysed.

A report is produced and lodged

with the EPA for approval for use

in operational trials.

EPA, HRL approve

move to trial

EPA, HRL reject,

review feedstock

processing

procedure

Materials delivered and kept

separate form current

feedstock stockpiles

Redbank staff set up

plant for trial

Live stack emissions

dosing rates of fuel

ash sampling

A report is produced and

lodged with the EPA for

approval to use

manufacturers feedstock

EPA issue resource recovery

order to manufacturer

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3 Feedstock Criteria QA/QC Verdant Earth have engaged the services of HRL Technology Group one of Australia’s most trusted

consulting and advisory services providers in the area of innovation, certification, and the complex

regulatory process for renewable energies to develop a Quality Assurance/Quality Control (QA/QC)

procedure for the processing supply and receipt of suitable feedstock for use as fuel in the Redbank

Power Station.

3.1 Purpose of Procedure

The purpose of this procedure is to define a standard approach for ensuring that the quality of all

feedstock accepted at the Redbank power station meet the approved standards required to safely,

economically and environmentally operate a power station.

In conjunction with HRL Verdant Earth staff have developed a process towards the recommissioning

and profitable operation of the Redbank Power station in two distinct stages:

Stage 1 Start up the plant utilising forestry wastes and timber residues

Stage 2A Work with the EPA and HRL towards a fuel replacement strategy utilising processed

and uncontaminated woods wastes.

3.2 Fuel Characteristics4

The design of the fuel handling system is dependent on the proposed Biomass fuel characteristics. The

fuel source will be Eligible waste fuels as defined by the EPA and includes forestry and sawmill residues

and uncontaminated wood waste that is generated in primary and secondary manufacturing

processes.

The following table illustrates the effect of fuel moisture content on the Biomass properties:

Assumptions for the biomass bulk density is calculated based on a mixture of wood with a mean “Basic

Density” of 525 kg/m3. The ratio of chip volume/ log volume is taken as 2.2 for compacted chips, and

2.7 for loose chips4. On-site measurement of dry chipped recovered waste wood indicated a loose

density of around 250 kg/m3.

Depending on the origin, preparation, handling and storage methods, wood chips and pellets can have

a moisture level between about 15% to 25%. while freshly hogged wood and logs can have moisture

levels up to about 55%. Wet wood may dry to 20 to 30% moisture if left to dry outdoors. The drying

time for logs may be in the order of 10 – 15 days for summer conditions, to weeks or months in winter

4 Redbank Power Station Biomass Handling Plant Concept Study B&PPS Report C12156-03 R4

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conditions. The design of the proposed plant is based on 25% moisture content however the plant will

be able to handle higher levels of moisture but less efficiently and at a lower output.

The following is the basis of the fuel analysis.

Ultimate Analysis

Recommended Sizing

• Wood chipped and screened to 50 mm nominal size

• Maximum of the sum of three dimensions to be less than 150 mm

(length+width+thickness)

• Recommended Sizing is Indicated by the dark line

• Acceptable Sizing is indicated by the Shaded Band

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3.3 Manufacturing facility QA, QC and Testing – Forestry and Saw Milling Residues.

Moisture Content

Supply 5kg raw log to

HRL

Materials dried as log

Materials further dried

as chip

Target -25%

HRL to undertake

analysis of moisture

over time analysis

Ambient temps

~15c winter temp

~30-35c Summer temp

Eligible fuels forestry waste and timber mills

Recovery as per the

relevant regulation

• EPA Eligible fuels

guideline

• POEO

(native Forest

Biomaterials)

regulation 2020

• NSW Forestry

Harvesting

Regulation

Grind and screen to

nominal 50mm X 8mm

<5% over +50mm

<5% -8mm

Stockpile for delivery

Target 3 days supply

Verdant Gain

Exemption to Burn

Eligible Fuel Feedstock

3.3.1 HRL Moisture Over Time Analysis for Forestry Waste

Verdant Earth engaged HRL to undertake a moisture over time analysis of the

forestry waste to understand the natural process of allowing the feedstock to

achieve the targeted moisture content the following methodology was developed

and undertaken.

• A sample of wood log was sourced form Brad Smith from Burgundy Heights

Pty Ltd and was wrapped in strong plastic and delivered to HRL Technology

• A portion of the wood log was taken and tested for total moisture content %

at 105°C.

• A 2nd portion of the wood log was taken and ground to ~25mm particle size

to form wood chips.

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• The wood log and wood chips underwent a moisture analysis over time at

two (2) temperatures:

Temperature (°C)

~15 (or ambient winter temp)

~30 – 35 (or ambient summer temp)

• The wood log and chips were monitored for moisture content changes at the

aforementioned temperatures across a six (6) week time period, OR, until

such a time that the measured moisture content of the wood log or wood

chips reaches 25%.

• Readings were taken for each temperature on each sample on a daily basis.

• Resultant data is being plotted at the end of the measurement period.

3.4 Manufacturing facility QA, QC and Testing – Uncontaminated wood waste.

Any manufacturing facility proposed to be engaged for the supply Uncontaminated Wood Waste as a

feedstock to Redbank must meet certain pre-qualification criteria designed to give confidence that

Eligible fuels – Uncontaminated Wood Waste

(UWW)

Redbank Power Station

QA/QC Feedstock Control

Procedure For UWW

• Ensure supplier has approved

• QA/QC assurance and testing

• Ensure supplier is compliant

with the NSW Waste to Energy

Policy

• Has an approved audit process

• Only receives feedstock from

approved suppliers

• Has available auditable chain

of custody documentation

• Implements an approved UWW

quality sampling and testing

regime.

Feedstock accepted and stored as

per EPA requirements

Feedstock spot sampled and

tested as per Redbank Power

station

QA/QC control document

Suppliers must have an approved

order to process and supply UWW

Verdant gain exemption to use

UWW

HRL/Verdant audit Suppliers QA/QC

Programs

HRL Verdant Staff

Approve Reject/Supplier Feedstock

Accept Feedstock implement Spot

Check Audit program

Reject Supplier - work towards

approval

HRL Verdant Staff

Approve Supplier Feedstock

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the manufacturing facility can meet the requirements of the Policy before Verdant Earth will enter

into a feed stock supply agreement.

Each solid waste derived fuel manufacturing facility will be contractually required to maintain an

appropriate quality control/quality assurance (QA/QC) procedure to ensure that fuels supplied to the

Redbank Power Station meet the requirements of the approved feed stock feedstock Specification

presented described in the NSW Eligible Waste Fuels Guidelines. These manufacturing facility QA/QC

procedures will define processes for controlling the quality of raw materials received and the testing

and processing stages to be followed to ensure compliance with the feed stock specification and the

Policy.

The manufacturing facility QA/QC procedures will be independently audited on an annual basis in

order to demonstrate that the manufacturing facility is complying with these procedures. An initial

audit of the manufacturing facility QA/QC system will be conducted prior to the commencement of

the supply of feed stock feedstock to Redbank by the supplier. The QA/QC audits will be conducted in

accordance with AS 19011-2014 Guidelines for Auditing Management Systems.

It is also noted that all fuels supplied will need to be tested and assessed for full compliance with the

chemical and physical specifications of the Specific Resource Recovery Order and Exemption as issued

by the EPA. Only fuels that have been tested and validated for compliance will be permitted to be

received at the power station.

3.5 Sourcing Eligible Waste Fuels QA-QC

3.5.1 Processing sites/facilities

As forestry management is largely dictated by the plantation owner or in the case of native forests

forestry NSW the processing facilities established at an approved area close to where the waste

woody biomass has been produced.

The following paragraphs procedures and positions have been reproduced from the Forestry

Corporation NSW Forest Management Plans for the Coastal Forests of NSW, The Western Forests of

NSW, Forest Management Plan – Softwoods Plantations Division.

Section 3.5.2 Describes the site preparation for the regeneration of the site

Section 3.5.3 Describes the residue management

Section 3.5.4 Describes the carbon balance from harvesting and regenerating the Forests

Section 3.5.5 Describes the contribution to the carbon cycles (We note the last bullet point

highlights the point that forestry NSW is seeking opportunities for the potential for harvesting

waste to be used as bio fuels such as proposed by Verdant Earth Technologies).

3.5.2 Site Preparation

Site preparation is the process undertaken before plantation establishment to enhance the prospect

of achieving a vigorous and well stocked plantation. The process generally involves preparation of

the planting area. Site preparation involves residue management, cultivation and weed

management. Each site is assessed for site specific risks which are identified and managed in a site

establishment plan.

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3.5.3 Residue Management

Harvesting residue can have a significant impact on re-establishment costs and the available plant

able area of second rotation sites. The volume of residue retained on site is heavily influenced by the

available markets for low quality wood such as pulp, paper and biofuels.

Where residue is retained on site, management will generally require the stacking of debris in

windrows which is subsequently burnt to reduce the impact on the plant able area and minimise the

risk associated with management of fire. Broadscale burning or chopper rolling may be undertaken

in lighter residue loads.

Once the sites are established Redbank staff will visit the site to ensure that it is in accordance with

the fuel acceptance criteria and the Redbank approved specification.

3.5.4 Carbon Balance

Forestry Corporation recognises the important role forests play in the carbon cycle. Carbon dioxide

(CO2) is absorbed by growing trees through photosynthesis. This carbon is stored in the tree for the

life of the wood, even after it has been harvested and processed into a wood product.

3.5.5 Contribution to Carbon Cycles5

In the sustainable management of forests for wood and other products, the Forestry Corporation

will maintain the carbon cycle and contribute to Australia’s net emission reduction program by:

▪ enabling captured carbon to be stored long term in harvested wood products

▪ providing for further net atmospheric carbon capture in the growth of vegetation

following wood harvest

▪ reducing the potential for large intense wildfires, which generate greenhouse gases

▪ maintaining or improving the productive capacity of the native and plantation forest

estate, as the level of carbon sequestration is proportional to the vigour of the trees

▪ seeking opportunities for harvesting waste and residues to be used as bio-fuels

5 Forestry Corporation NSW Forest Management Plans for the Coastal Forests of NSW, The Western

Forests of NSW, Forest Management Plan – Softwoods Plantations Division.

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3.5.6 Anticipated forestry sources and transport routes

Source of Waste Woody Biomass Roads access to Redbank

Coastal Forests

North Coast New England Highway

Golden Highway

Long Point Rd

South Coast New England Highway

Golden Highway

Long Point Rd

Western Forests

Brigalow Golden Highway

Long Point Rd

Nandewar New England Highway

Golden Highway

Long Point Rd

South West Cyprus New England Highway

Golden Highway

Long Point Rd

Riverina New England Highway

Golden Highway

Long Point Rd

Softwood Plantation

Snowy Region New England Highway

Golden Highway

Long Point Rd

Northern Region New England Highway

Golden Highway

Long Point Rd

Forestry and Sawmill Residues

New England Highway

Golden Highway

Long Point Rd

3.5.7 Auditable chain of custody

There will be an auditable chain of custody of feedstock from the supplier’s facility to Redbank. Each

vehicle load of feedstock despatched from the supplier’s facility will be assigned a transport certificate

detailing the following:

• Delivery date;

• Time of departure;

• Description of feedstock (e.g. forestry waste or uncontaminated wood waste);

• Gross/tare and net weights of delivering/exporting vehicle;

• Vehicle registration number; and

• Unique reference number assigned to the load.

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On arrival at Redbank each load will be weighed over a weighbridge and the data recorded, detailing

the following:

• Arrival date;

• Time of arrival;

• Description of feedstock;

• Source of material (manufacturing facility)


• Vehicle registration number;

• Unique reference number assigned to the load;

• Test report demonstrating compliance with the Specific Resource Recovery Order.

Each month a reconciliation will be made between the manufacturing facility delivery data and the

arrival data received at the works to confirm a match-up of delivered and received loads. Any

mismatch between delivered and received loads will be investigated by the manufacturing facility and

Verdant Energy.

At least one vehicle load of feed stock per manufacturing facility will be visually inspected by suitably

trained Verdant Energy staff each day where deliveries are received and a grab sample collected. This

visual check will confirm, as far as practicable, that prohibited materials are not included in the load.

The grab sample will be checked for grading and moisture content a small laboratory will be onsite

and used by Redbank staff as required and by external consultants for process auditing.

Relevant staff will be trained in the QA/QC procedures outlined in this document, including:

• The feed stock specification; (Grading and Moisture Content);

• Identification of prohibited waste materials;

• Procedures for managing contaminated loads;

• Recording details of the inspection;

• Procedures for waste acceptance and rejection; and

• Method for contact and communications with the relevant third parties where required.

3.6 Receipt of feed stock

Only deliveries of feed stock from approved suppliers carrying the necessary transport certificate and

evidence of compliance with our Specific Resource Recovery Order, as defined above, will be

permitted to be received and discharged into the feed stock storage and handling system at the

Redbank.

A register of pre-approved delivery vehicles will be maintained by Verdant Earth and only such

approved vehicles will be permitted to weigh-in at the Works. Only drivers who have successfully

completed the relevant site safety and operations induction will be permitted to weigh-in and

discharge feed stock at Redbank.

On arrival of a load of feed stock at Redbank, the transport certificate will be checked by site personnel

or via an automatic check system prior to being discharged into the feed stock storage and handling

system. Automatic interlocks or barrier systems will be installed to prevent discharge without prior

authorisation.

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Records of daily inspections will be maintained by the site.

In the case that feedstocks cannot be accepted at the Redbank Power Station (for either legal or

technical reasons) the vehicle will be directed to a dedicated quarantine area for non-acceptable feed

stock and not discharged. For those loads not accepted, the manufacturing facility will be notified in

writing and the load will be directed to return to the supplier. The return of such loads will be the

responsibility of the supplier.

The point of discharge of feed stock from the delivery vehicle into the Redbank Power Station feed

stock storage and handling system will be monitored by video camera and the image will be displayed

in the central control room at the Works. Where discharged loads are observed or suspected to

contain prohibited materials, this material will be transferred to a designated quarantine area within

the feed stock storage building and not transferred to the fluidised bed feed system unless the suspect

material has been checked and approved by site personnel.

Sufficient vacant storage capacity must be maintained within the feed stock storage area to cater for

the storage of up to 200 m3 of quarantined feed stock.

Records of disputed loads will be included in a reject loads register and stored on site or returned to

the supplier.

3.7 Storage of feed stock

All acceptable feed stock received and discharged at the Redbank Power Station will be stored in the

existing coal tailings storage area as originally approved.

Levels of materials within the storage area will be monitored by site personnel and if necessary,

deliveries from the manufacturing facility will be cancelled or restricted to ensure the capacity of the

undercover area is not exceeded.

Sufficient spare capacity must be maintained within the storage area to receive deliveries in transit

from the supplier.

3.8 Additional Sampling and Testing of feedstock

In addition to the ongoing sampling and testing outlined in Appendix 1 of this document, for any new

feed stock source introduced to the Redbank Power Station (e.g. woodchip from forest thinning’s from

a new plantation), a series of representative samples will be collected from the new feed stock source

for characterisation of the fuel in terms of its composition and variability. Sampling and

characterisation will allow for an assessment of the feed stock and its ability to conform to the fuel

specification prior to its use.

Twenty composite samples will be collected and analysed for all parameters specified in Table A1.1

using the corresponding test methods (or equivalent as agreed with Verdant Energy) for the purposes

of characterisation. Sampling will be undertaken with reference to EN14780:2011 “Solid Biofuels –

Methods for sample preparation”.

A composite sample is defined as: a sample that combines four discrete sub-samples of equal size into

a single sample for the purpose of analysis.

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3.9 Notification and Reporting

Redbank will keep a written record of the following for a period of minimum six years:

• The sampling plan required to be prepared under this procedure;

• All characterisation, routine and/or one-off sampling results in relation to the feed stock

supplied;

• The quantity of feed stock supplied; and

• The name and address of each manufacturing facility that supplied feed stock to Redbank

Verdant Energy must provide, on request, the most recent characterisation and sampling (whether

routine or one-off or both) results for the feed stock supplied. Verdant Energy must notify the EPA

within seven days of becoming aware of any material that does not meet this specification having

entered the Redbank Power Station.

It is noted that these notification and reporting requirements will be introduced by the EPA into the

Specific Resource Recovery Order and Exemption post approval.

3.10 Additional Record Keeping Requirements

The Protection of the Environment Operations (General) Regulation 2009 (the Regulation) requires the

occupier of any premises on which bio-material is burnt in any electricity generating work to keep

certain records.

The EPA’s requirements for record keeping are set out in Guidelines for the Burning of Bio-material -

Record-keeping Requirements for Electricity Generating Facilities (2013)6.

Records must be kept in a manner that allows:

• All fuel held on the premises at the beginning of the relevant period that is to be used for the

generation of electricity to be easily ascertained;

• The date on which all fuel that is to be used for the generation of electricity enters or leaves

the premises, together with its source, record type and amount (tonnes dry weight) to be

easily ascertained;

• At the end of the reporting period, the closing balance of all materials on the premises that

are to be used for the generation of electricity.

If the fuel is bio-material, the records must be kept in a way that makes it clear which of the following

categories the fuel belongs as defined in Section 3 of the guidelines.

These records must be kept in English and in a manner that allows the summary information for a

reporting period to be verified by an authorised EPA officer or any independent auditor.

6 NSW EPA (2013). Guidelines for the Burning of Bio-material - Record-keeping Requirements for Electricity Generating Facilities. Internet publication: https://www.epa.nsw.gov.au/-/media/epa/corporate-site/resources/legislation/130811glbioburn.pdf?la=en&hash=8550CD2556376339717EA2429029E3E7609B7594

https://www.epa.nsw.gov.au/-/media/epa/corporate-site/resources/legislation/130811glbioburn.pdf?la=en&hash=8550CD2556376339717EA2429029E3E7609B7594



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The records must be kept in sufficient detail to show particulars of:

• The name of the supplier from whom the bio-material was purchased/obtained;

• The date of supply of the bio-material;

• The type of bio-material;

• The location where the bio-material was harvested or sourced from;

• The amount of bio-material in tonnes dry weight;

• The amount of electricity (in kilowatt hours) produced from the bio-material supplied during

the reporting period; and

• The total amount of electricity (in kilowatt hours) produced by the electricity generating works

during the reporting period.

3.11 Residual Ash Management

3.11.1 Ash Produced from Use of Biomass as Fuel

Burning waste woody biomass in the Redbank power station will produce a residual ash of

approximately 3%-5% of the feedstock. Utilising the worst case scenario of 5% we have calculated

that there will be a requirement to remove 134 tonnes of the ash per day or the equivalent of 3

transport loads.

112t/h x 24 hours = 2,688 tonnes per day

2688 x 5% = 134.4 tonnes

As we will be having up to 70 B double configured semi trailers delivering waste woody biomass to

the site those vehicles will when required back load the ash to an approved site(s) where the ash will

be used as a soil amendment. The ash bunker is large enough to hold 2½ days production.

The application of ash from the burning of biomass as a soil or fertiliser amendment on land is

permitted in accordance with the EPA’s The Ash from Burning Biomass Order 2014. This Order

permits the reuse of ash when fuels used biomass from “…agriculture, forestry and sawmilling

residues, uncontaminated wood waste and/or organic residues from virgin paper pulp activities.”

Ash from the burning of the proposed biomass as fuel will be sampled and tested in accordance with

the Order, meeting all chemical requirements under Table 1 of the Order, and if compliant, then the

ash will be transported and used as a soil amendment in agriculture or forestry in accordance with

The Ash from Burning Biomass Exemption 2014.

3.11.2 Ash from Coal Tailings

The application of ash from the burning of coal as a soil or fertiliser amendment on land is permitted

in accordance with the EPA’s The Coal Ash Order 2014. This order applies to coal ash and coal ash

blended with other materials (blended coal ash). In this order, coal ash means coal combustion

products (CCPs), fly ash or furnace bottom ash from burning Australian black coal. It is noted that

coal tailings are derived directly from Australian black coal.

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Ash from the burning of the proposed coal will be sampled and tested in accordance with the Order,

meeting all chemical requirements under Table 1 of the Order, and if compliant, then the ash will be

provided to a contractor who will then use it as a soil amendment in accordance with The Coal Ash

Exemption 2014.

Should the ash not comply with the requirements of the EPA’s The Coal Ash Order, a Specific

Resource Recovery Order and Exemption will be applied for from the NSW EPA to enable the

beneficial reuse of ash in appropriate applications to ensure that human health and the environment

are protected at all times.

4 Material Transport As discussed, feedstock processing facilities will be strategically positioned within the supply chain.

These sites will process the feedstock to the specification required by Redbank and as defined under

our Specific Resource Recovery Order post approval.

Redbank will engage a fleet of B double configured semi-trailers; a combination of company owned

and subcontract driver will be engaged to transport the required feedstock to Redbank site.

The fleet will have a walking floor configuration to eliminate the need for tipping.

Through continued improvement and innovation, the B-Double Combination through unload

systems have a capacity of up to 170m3 and are designed to combine maximum durability with

industry leading minimum tare weights. During the unloading cycle, the front section of the trailer

locks into position with the rear section. The contents travel the length of the vehicle on the walking

floor mechanism and are deposited out the rear door into the bulk haul drive through receiving

hopper.

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5 Redbank Material Acceptance and Storage The new receival facility has been sized to accept the equivalent 850,000 tonnes of woody biomass

at a 25% moisture content per annum in

predominantly B Double rated semi-trailer

configurations averaging a payload of 42-44

tonnes per load.

It is envisioned deliveries will be accepted

between 6am and 6pm although there may

be the occasional out of hours delivery to meet operational needs.

The process of accepting and storing these materials will consist of two weighbridges. The

weighbridges will be placed on the entrance road and the exit road which will enable the accurate

gross weight and tare weights to be recording allowing for recording of woody biomass volumes

utilised on the site.

The waste woody biomass accepted will meet the EPA requirements for eligible fuel as defined in

the NSW EPA Eligible Waste Fuels Guideline and the requirements of our Specific Resource Recovery

Order which will be sought from the NSW EPA post-approval.

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1

Loaded Truck arrives on site

Proposed Materials Acceptance Flow Diagram

2

The gross weights is recorded

on the weighbridge software

3

The Driver is directed to the

tipping area

5

Feedstock is accepted and

unloaded

4

Feedstock is sampled

for QA/QC

Y/N

6

The tare weight is recorded on

the weighbridge software and

the driver exits the site

7

The trucks tips its

feedstock load into the

receival hopper

8

Feedstock is transported

via telescopic conveyors to

the storage area

11

Feedstock is transported

by Telescopic conveyors

direct to the Bulk Bin

Walking floorConveyor

Feeder

12

Walking floor feeder feeds

into the existing feedstock

conveyor circuit

10

Using a large wheel loader

the feedstock is fed into a

telescopic conveyor to be

fed into the drop down bin

9

Feedstock is stored in large

storage bays.

Estimate 4 days total use

storage 12,000M3

13

Redbank power station fixed

feedstock conveyor system

THE PROPOSED WOODY BIOMASS RECEIVAL PROCESS

1. Trucks will be programmed into the site to spread the access throughout the 12 hour

acceptance window, Redbank will have an entrance and an exit gate and traffic will flow

through the site in a forward motion.

2. All loads will be weighed and gross weight, source and transport company will be

recorded.

3. The driver will be directed to the tipping area and advised if that load will be sampled

for QA/QC purposes.

4. Materials will be sampled and an A&B sample produced. Sampling will be done by a

trained employee and will be assessed for:

a. Moisture content

b. Grading

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c. Contamination

5. Feedstock is accepted and driver proceeds to unload.

6. The driver enters the weigh-bridge, tare weights recorded and exits the site.

7. The truck tips its feedstock into the receival hopper 7where the feedstock is directed according to the needs

of the power station.

a. The feedstock will be transported by a series

of telescopic conveyors to the storage

stockpile area for recovery when required by

the power station, stock will be rotated to

ensure that no materials

are sitting on site for long periods, estimate

turned over every 4 days. (8-9).

b. A percentage of the feedstock will be

transported on an as needs basis by a series of

telescopic conveyors to the power station

receiving bin (11-12).

10. A large wheel loader will recover the stockpiled feedstock

and drop it into a feed hopper where the feedstock will

be transported to the bulk walking floor feed system.

11. The daily volume the plant will require for production will

be delivered via a series of telescopic conveyors to the

walking floor bulk loading bin.

12. The Walking floor bulk loading bin directs the materials

into the modified existing feedstock conveyor system.

7 Pictures are illustrative examples of the type of plant and equipment to be sourced

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5.1 Safety and Risk Management

5.2.1 Traffic flows

The vehicular traffic movements have been designed so that all heavy vehicles will enter the site via

the dedicated vehicle entry gate and move through the site in a forward motion. Delivery trucks will

drive onto and off the unloading bins in a forward direction to ensure there is no need for large

vehicles reversing into tipping bays. Trucks will exit via the dedicated exit gate.

5.2.2 Transport Fleet Configuration

The fleet will predominantly be B Double configuration walking floor unloaded vehicles for safe

unloading and will remove the need for large bodied vehicles to tip, eliminating the possibility of a

tipping accident.

5.2.3 Fire

The area where the stockpiles are situated has an existing sprinkler loop which would be retained

and thermal cameras will be installed and connected to the control room consoles which in turn will

operate the sprinkler loop.

This is an excerpt from the underground service illustrating the sprinkler loop on light blue.

Appendix 1

Verdant Earth Feedstock Production QA/QC

Hunter Energy QA/QG draft 1 23.11.20 UPDATE - edited 08/07/2021 Technology Group

Verdant Earth Redbank Power Station

Quality Assurance and Control Procedure for Receipt and Use of Waste

Woody Biomass

1. Purpose of Procedure

The purpose of this procedure is to define a standard approach for ensuring that the

quality of Waste Woody Biomass (WWB) received and used at the Verdant Earth Redbank

power station (hereinafter sometimes referred to as the work’s) meet the specified fuel

requirements and relevant statutory regulations and policies including the NSW EPA

Eligible Waste Fuel Guidelines.

Solid waste derived fuel is a general term used to describe any solid fuels processed

from waste materials to be utilised as a heat source in the fluidised bed at the Power

station. This includes fuels derived from the processing of feedstock derived from

forestry waste timbers, sawmilling residues and uncontaminated wood wastes (referred

to as Woody Waste Biomass).

2. Manufacturer Quality Control, Quality Assurance and Testing

Any manufacturer proposed to be engaged for the supply of WWB to the Power station

must meet certain pre-qualification criteria designed to give confidence that the

manufacturer can meet the requirements of the Procedure before any WWB is supplied

by that manufacturer on an ongoing basis to the Redbank power station. The

methodology for prequalifying of suppliers is provided in Appendix 2.

Each solid waste derived fuel manufacturer will be contractually required to maintain

an appropriate quality control/quality assurance (QA/QC) procedure to ensure that

fuels supplied to the Redbank power station meet the requirements of the Waste Woody

Biomass (WWB) Specification presented in Appendix 1 and the Procedure. These

manufacturer QA/QC procedures will define processes for controlling the quality of raw

materials received and the testing and processing stages to be followed to ensure

compliance with the WWB Specification and the Procedure.

The Manufacturer QA/QC procedures will be independently audited on an annual basis

in order to demonstrate that the Manufacturer is complying with these procedures. An

initial audit of the Manufacturer QA/QC system will be conducted prior to the

commencement of the supply of WWB to the power station by the supplier. The QA/QC

audits will be conducted in accordance with AS 19011-2014 Guidelines for Auditing

Management Systems.

Verdant Earth QA/QC 15/07/2021

3. Manufacturer Compliance with the NSW EPA’s Eligible Waste Fuel Guidelines

As per the NSW EPA’s Eligible Waste Fuel Guidelines, woody biomass to be combusted

by the Redbank Power Station to produce electricity will be sourced from waste

generated that meets the definition of an EPA approved eligible waste fuel as defined

in Section 3 of the policy:

• Biomass from agriculture;

• Forestry and sawmilling residues; and

• Uncontaminated wood waste.

Eligible waste fuels may be thermally treated using a range of treatment technologies,

provided a resource recovery order and exemption has been granted by the EPA. The

origin, composition and consistency of these wastes must ensure that emissions from

thermal treatment will be known and consistent over time.

Facilities proposing to use eligible waste fuels must meet the following criteria:

• Ability to demonstrate to the EPA that the proposed waste consistently meets

the definition of an EPA-approved eligible waste fuel;

• Confirm there are no practical, higher order reuse opportunities for the waste;

• Fully characterise the waste and/or undertake proof of performance; and

• Meet the relevant emission standards as set out in the Protection of the

Environment Operations (Clean Air) Regulation 2010.

Note that eligible waste fuels that also fall under the definition of a standard fuel as

defined in the Protection of the Environment Operations (Clean Air) Regulation 2010

would not need to meet the above criteria but will still require appropriate approval

for their use.

It is further noted that Verdant Earth will be required to apply for a Specific Resource

Recovery Order and Exemption in accordance with Clause 92(1)(b) of the Protection of

the Environment Operations (Waste) Regulation 2014 prior to the commence of the use

of these additional fuel types at the plant following issue of the planning consent.


4. Tracking and Checking of Fuel Deliveries

There will be an auditable chain of custody of WWB from the manufacturer’s facility to

the power station. Each vehicle load of WWB despatched from the supplier’s facility

will be assigned a transport certificate detailing the following:

• Delivery date;

• Time of departure;

• Description of WWB (e.g. forestry waste fuel, sawmilling residues or

uncontaminated wood waste);




On arrival at the power station each load of WWB will be weighed over a weighbridge

and the data recorded, detailing the following:

• Arrival date;

• Time of arrival;

• Description of WWB;




Each month a reconciliation will be made between the supplier/manufacturer delivery

data and the arrival data received at the Power station to confirm a match-up of

delivered and received loads. Any mismatch between delivered and received loads will

be investigated by the manufacturer and Verdant Earth.

At least one vehicle load of WWB per manufacturer will be visually inspected by suitably

trained Verdant Earth staff each day where deliveries are received. This visual check

will confirm, as far as practicable, that prohibited materials are not included in the

load.

Relevant staff will be trained in the QA/QC procedures outlined in this document,

including:

• The WWB specification;

• Identification of prohibited waste materials;

• Procedures for managing contaminated loads;

• Recording details of the inspection;

• Procedures for fuel acceptance and rejection; and

• Method for contact and communications with the relevant third parties where

required.


5. Receipt of WWB

Only deliveries of WWB from approved suppliers carrying the necessary transport

certificate, as defined above, will be permitted to be received and discharged into the

WWB storage and handling system at the Power station.

It is also noted that only fuel material which has been tested and validated as complying

with Verdant’s Specific Resource Recovery Order will be accepted at the site.

Furthermore, a register of pre-approved delivery vehicles will be maintained by Verdant

Earth and only such approved vehicles will be permitted to weigh-in at the power

station. Only drivers who have successfully completed the relevant site safety and

operations induction will be permitted to weigh-in and discharge WWB at the power

station.

On arrival of a load of WWB at the power station, the transport certificate will be

checked by site personnel or via an automatic check system prior to being discharged

into the WWB storage and handling system. automatic interlocks or barrier systems will

be installed to prevent discharge without prior authorisation.

Records of daily inspections will be maintained by the site.

In the case that the feedstock cannot be accepted at the Redbank power station (for

either legal or technical reasons) the vehicle will be directed to a dedicated quarantine

area for non-acceptable WWB and not discharged. For those loads not accepted, the

Manufacturer will be notified in writing and the load will be directed to return to the

supplier. The return of such loads will be the responsibility of the supplier.

The point of discharge of WWB from the delivery vehicle into the Redbank Power station

WWB storage and handling system will be monitored by video camera and the image

will be displayed in the central control room at the Power station. Where discharged

loads are observed or suspected to contain prohibited materials, this material will be

transferred to a designated quarantine area within the WWB storage building and not

transferred to the fluidised bed feed system unless the suspect material has been

checked and approved by site personnel.

Sufficient vacant storage capacity must be maintained within the WWB storage shed to

cater for the storage of up to 200 M3 of quarantined WWB.

Records of disputed loads will be included in a reject loads register and stored on site.

6. Storage and use of WWB

All acceptable WWB received and discharged at the Redbank power station will be

utilised directly into the power station or stored within the defined stockpile area.

Levels of materials within the storage area will be monitored by site personnel and if

necessary, deliveries from the manufacturer will be cancelled or restricted to ensure

the capacity of the area is not exceeded.

Sufficient spare capacity must be maintained within the storage area to receive

deliveries in transit from the supplier.


7. Additional Sampling and Testing of WWB

In addition to the ongoing sampling and testing outlined in Appendix 1 of this document,

for any new WWB type introduced to the Redbank power station, a series of

representative samples will be collected from the new WWB source for characterisation

of the fuel in terms of its composition and variability. Sampling and characterisation

will allow for an assessment of the WWB and its ability to conform to the fuel

specification prior to its use.

The testing and analysis will require that the source of the material fully complies with

the requirements of Verdant Earth’s Specific Resource Recovery Order, which will be

sought post-approval.

Twenty composite samples will be collected and analysed for all parameters specified

in Table A1.1 using the corresponding test methods (or equivalent as agreed with

Verdant Earth) for the purposes of characterisation. Sampling will be undertaken with

reference to EN14780:2011 “Solid Biofuels – Methods for sample preparation”.

A composite sample is defined as: a sample that combines four discrete sub-samples

of equal size into a single sample for the purpose of analysis.

8. Notification and Reporting

Redbank will keep a written record of the following for a period of minimum six years:

• The sampling plan required to be prepared under this procedure;

• All characterisation, routine and/or one-off sampling results in relation to the

WWB supplied;

• The quantity of WWB supplied; and

• The name and address of each person/manufacturer that supplied WWB to

Verdant Earth

Verdant Earth must provide, on request, the most recent characterisation and sampling

(whether routine or one-off or both) results for the WWB supplied. Verdant Earth must

notify the EPA within seven days of becoming aware of any material that does not meet

this specification having entered the Redbank power station.


Appendix 1

Part 1 – Waste Woody Biomass (WWB)

A1.1.1

The manufacturer is responsible for sampling and testing Waste Woody Biomass

feedstock in accordance with the requirements of this Agreement.

A1.1.2

The manufacturer will ensure appropriate procedures are developed and

implemented with the aim of qualifying the supply of WWB to Verdant Earth and

assuring that WWB meets the following requirements:

• pulp wood logs and heads and off-cuts from clearing carried out in

accordance with a private native forestry property vegetation plan or

forestry operations carried out in accordance with an integrated forestry

operations approval under Part 5B of Part A of the Forestry Act 2012;

• trees cleared as a result of thinning carried out in accordance with a

private native forestry property vegetation plan or an integrated forestry

operations approval;

• sawdust or other sawmill waste;

• uncontaminated wood waste includes pre-consumer manufacturing and

processing waste materials such as off-cuts, saw dust, wood shavings,

untreated packaging crates, untreated pallets and engineered timbers

made with urea formaldehyde or phenol formaldehyde resins only.

A1.1.3

The manufacturer will ensure that the results for each monthly composite sample

of WWB delivered under this agreement as sampled in accordance with Section

A1.3.1 and tested in accordance to standard methodologies denoted in Table

A1.2.1 complies with the Specification in Table A1.1.1.

A1.1.4

The Manufacturer must ensure that any testing of samples required by Verdant

Earth’s Specific Resource Recovery Order is undertaken by analytical laboratories

accredited by the National Association of Testing Authorities (NATA) or

equivalent testing standards.


Table A1.1.1 Proposed WWB specifications.

Note that Verdant Earth will work with the EPA to develop actual regulatory

limitations when applying for a Specific Resource Recovery Order (post approval).

A1.1.5

The Manufacturer is permitted for just two (2) of the gross calorific value or

moisture results in any of the twelve (12) consecutive monthly composite

samples to be outside the values specified in Table A1.1.1, however, any

such result must comply with the following limits:

• Gross calorific value ≥ 10.0 MJ/kg

• Total moisture content (as H20) ≤ 35.0% (m/m)


Part 2 - Quality Assurance for WWB

Table A1.2.1 WWB Analysis Methods

Fuel Characteristic / Parameter Test Method

Total Moisture Content CEN/TS 15414:2010

Ash Yield I.S. EN 15403:2011

Carbon, Hydrogen, & Nitrogen I.S. EN 15407:2011

Total Halides (Sulphur, Chlorine, Bromine, Iodine, & Fluorine) I.S. EN 15408:2011

Calorific Value (gross dry, gross wet & net wet) I.S. EN 15400:2011

Major Elemental Analysis (Oxides in Sample) I.S. EN 15410:2011

Trace Elemental Analysis (Heavy Metals Screen) I.S. EN 15411:2011

Particle Size Distribution – recommended to complete manually CEN/TS 15149-2

A1.2.1

The Manufacturer will have a written agreement with Verdant Earth regarding

any changes to the test methods and procedures for testing and sampling WWB

as specified in Tables A1.1.1 and A1.2.1 and Section A1.3.1 of this

document.

A1.2.2

The Manufacturer will ensure that testing of all parameters in Table A1.2.1

is undertaken according to the requirements and is conducted by a laboratory

certified to NATA or otherwise similar testing standards for the test

procedures specified above. This requirement does not apply to samples

tested as per Section A1.3.2 below.


Part 3 – Manufacturer Sampling

A1.3.1

The Manufacturer will sample each separate type of WWB supplied to the

Power station. The routine sampling frequency outlined herein assumes a

baseline WWB characterisation data set of at least 20 composite samples.

Prior to the use of any WWB, characterisation sampling must be undertaken

to assess the WWBs typical composition, variability and ability to conform to

the fuel specification. Further information on characterisation sampling is

provided in Section 7 of this document.

The routine sampling process will be as follows:

• Every new project, two composite samples (one primary and one

duplicate sample) will be collected from the WWB prior to despatch.

• Composite samples will be comprised of four discrete sub-samples of

equal size, into a single sample for the purposes of analysis.

• The samples will be taken from a belt conveyor, falling stream or truck.

• The monthly samples must be taken from a batch, truckload or stockpile

that has not been previously sampled for the purposes of assessing

compliance with the feedstock specification.

• Every composite sample will be sealed and labelled to preserve moisture

content.

• All samples collected during a month will be sent to an independent

NATA accredited laboratory for analysis.

• The samples will be prepared with consideration for the guidance

provided in EN14780:2011 “Solid Biofuels – Methods for sample

preparation”.

• The primary composite sample will be tested for all parameters specified

in Table A1.2.1 using the corresponding test methods (or equivalent as

agreed with Verdant Earth).

• The duplicate composite sample will be retained as a reference for a

period of 3 months and will be stored in a suitably labelled and sealed

container to preserve sample integrity.

A1.3.2

The Manufacturer will ensure that the particle size analysis is carried out on

a minimum weekly basis using a representative composite sample made up

from the samples taken during that week. The test results will be provided to

Verdant Earth by the next working day.

A1.3.3

The Manufacturer will agree with Verdant Earth on the details for final

procedures of sampling and testing WWB as part of Supplier’s QA/QC system.

Part 4 – Manufacturer Reporting


A1.4.1

The Manufacturer will ensure that tests for all specification parameters in

Table A1.1.1 are carried out on each monthly composite sample of WWB using

the test methods defined in Table A1.2.1. The Manufacturer will provide

Verdant Earth in writing with the individual monthly composite sample results

within 21 days of the collection of the last sample within the month.

A1.4.2

The manufacturer should provide written notification to Verdant Earth of any

exceedances of the limits provided in Table A1.1.1 as soon as reasonably

practicable. If an exceedance is reported for any material that has already

been received by Verdant Earth from the supplier, Verdant Earth will review

the causes of the exceedance with the supplier, with a view to the

manufacturer making changes to prevent further exceedances.

A1.4.3

If dispute as to the quality or specification of the WWB cannot be amicably

resolved between Verdant Earth and the manufacturer within 60 days, either

party may refer such dispute for determination by an Expert, such that the

Expert shall be agreed between the parties. Such person will act as Expert

and not arbitrator and make such determination as to the quality or

specification of the WWB within 20 days of appointment. The Expert’s

determination will be final and binding on both parties.


Appendix 2 – Manufacturer Capability Assessment

Company Name: ABN

Address: ACN

Post Code

Contact Name:

Phone No: Fax No Mobile No

Feedstock Material: Forestry Timbers Sawmill Waste UWW

If other is chosen please describe here

Capability Compliance Checklist Category Description Response Criteria Compliant Comments

Safety and Compliance

Verdant Earth Safety Management System

Sufficiently advanced to comply with the HE Contractor Safety Management requirements.

Y/N/NA

Insurance – Certificate of Currency Public Liability $20 million Motor Vehicle $20 million

Y/N/NA

Safety Management Plan Safety Management Plan developed reviewed and approved by HE. Not operating under HE Safety Management Plan

Y/N/NA

Environmental Management Plan Environmental Management Plan developed, reviewed and approved by HE. Not operating under HE Safety Management Plan.

Y/N/NA

Operational Risk assessment conducted

Full operational risk assessment conducted for the contract activities and evidenced by HE.

Y/N/NA


Category Description Response Criteria Compliant Comments

Manufacture and Storage Facilities

Location of facility Facility to be located with NSW ideally within 3 hours of Redbank

Y/N/NA

Size of facility – volume facility capable of producing

The facility must be capable of producing feedstock to meet the minimum volumes stipulated in the contract.

Y/N/NA

Specifications Must meet the requirements of the Verdant Earth’s Specific Resource Recovery Order

Y/N/NA

Licence to operate as a waste facility including feedstock fuel production.

Evidence of operating licence. Y/N/NA Licence Number

Experience or knowledge in sourcing raw materials and producing feedstock fuel

Evidence of experience or knowledge including operations in other regions/countries, key personnel’s experience etc.

Y/N/NA

Personnel

Organisational size/capacity Tier 1 waste organisation with support in place to meet the contract requirements.

Y/N/NA

Contract representative Key representative for all operational and commercial matters.

Y/N/NA

Volume and experience of personnel within the organisation.

Experience of key personnel in the WWB industry including processing capability.

Y/N/NA

Transport1

In house or sub-contract arrangement. If sub-contract is there a formal contract arrangement in place which demonstrates requirements from head contract.

The volume of vehicles must be available to meet the delivery requirements for the minimum volumes stipulated in the contract.

Y/N/NA

1 Verdant Earth may choose to undertake supply only agreements where transport will be arranged by the power station.


There must be adequate numbers of qualified drivers to meet the delivery


If sub-contract regular checking of processes and procedures to ensure continued compliance.

requirements for the minimum volumes stipulated in the contract. Sub-contract only – Evidence of a formal contract in place between the manufacturer and the Sub-contractor noting compliance must be as a minimum in accordance with the overarching VE/Manufacturer contract. Evidence of processes and procedures in place with the manufacturer to periodically ensure compliance of the sub-contractor to the requirements of the contract.

Y/N/NA

Delivery tracking capability Ability to produce and maintain delivery records to meet the requirements of the contract.

Y/N/NA

Vehicle configuration options Vehicles used must be in accordance with the contract and be capable of tipping into the VE storage facility.

Y/N/NA

Licenced to transport the goods Where required, the manufacturer must provide evidence that they or their sub-contractor are licenced to transport the goods.

Y/N/NA

Traffic management plan for the WWB processing facility

Evidence of a formal traffic management plan in place at the WWB facility to manage vehicle

Y/N/NA


movements and reduce human interaction with heavy vehicles

QA/QC ISO Accredited Evidence of accreditation Y/N/NA


Formal documented QA/QC policy in place including;

• Sampling regime

• Sample storage and tracking

• NATA accredited laboratory for testing

• Labelling and storing duplicate sample

• Logistics for samples to lab

Evidence of a formal QA/QC policy which complies with all QA/QC requirements in the contract and meets VE Specific Resource Recovery Order specifications.

Y/N/NA

Weekly particle size testing including

• Sampling regime

• Consolidation process

• Testing facilities

Evidence of formal process in place for the Manufacturer to conduct weekly particle size testing including recording, documenting and storing the results.

Y/N/NA

Daily monitoring on CV and moisture including

• Sampling

• Testing

• Testing equipment

Evidence of formal process in place for the manufacturer to conduct daily monitoring on CV and moisture including recording, documenting and storing the results.

Y/N/NA

Adherence to the conditions of the VE Redbank Power station – QA/QC Procedure for Receipt and Use of WWB

Written commitment to meet all the sampling, testing, reporting and other requirements provided in VE’s QAQC procedure

Y/N/NA

Type of fuel Meets the requirements of the VE Specific Resource Recovery Order specifications.

Y/N/NA



Adherence to Specification Evidence that the WWB produced by the manufacturer will meet the specifications in the contract including multiple samples and laboratory testing reports.

Y/N/NA

Reporting and Commercial

Retention and communication of testing and monitoring reports

Evidence of a system in place to store and retain all testing and monitoring records for the duration of the agreement and beyond.

Y/N/NA

Data management and accessibility of information.

Evidence of a formal process for managing data from testing and monitoring equipment and evidence of accessibility to meaningful reporting from this data.

Y/N/NA

Ongoing reports for compliance and delivery

Evidence of ability to develop and provide ongoing consistent reports for monthly reviews against compliance and delivery.

Y/N/NA

Commercial compliance including payment processes, remittance notes etc.

Ability to meet the minimum payment requirements and issue regular remittance advice regarding payments.

Y/N/NA

Continuous Improvement

Identification and analysis of costs for ongoing optimisation

Evidence of ongoing commitment to improving the overall process and product to optimise production.

Y/N/NA

Verification Print Signature Date

Check List prepared By:

Check List Verified By:

Appendix 2

EPA Energy from Waste Policy

NSW Energy from Waste Policy Statement | i

Environment Protection Authority

NSW Energy from Waste Policy Statement

NSW Energy from Waste Policy Statement | i

The paragraphs highlighted in yellow in this imprint page are instructions to assist you. Please delete the highlighted text before supplying the imprint page to Brand and Publishing. © 2021 State of NSW and the NSW Environment Protection Authority With the exception of photographs, the State of NSW and the NSW Environment Protection Authority (EPA) are pleased to allow this material to be reproduced in whole or in part for educational and non-commercial use, provided the meaning is unchanged and its source, publisher and authorship are acknowledged. Specific permission is required for the reproduction of photographs. Every effort has been made to ensure that the information in this document is accurate at the time of publication. However, as appropriate, readers should obtain independent advice before making any decision based on this information. The EPA shall not be liable for any damage which may occur to any person or organisation taking action or not on the basis of this publication. The following Creative Commons licence paragraph should be included for any EPA publication where the EPA owns, or has a relevant licence for, the copyright. All content in this publication is owned by the EPA and is protected by Crown Copyright, unless credited otherwise. It is licensed under the Creative Commons Attribution 4.0 International (CC BY 4.0), subject to the exemptions contained in the licence. The legal code for the licence is available at Creative Commons. The EPA asserts the right to be attributed as author of the original material in the following manner: © State of New South Wales and the NSW Environment Protection Authority 2021. Published by: NSW Environment Protection Authority 4 Parramatta Square 12 Darcy Street, Parramatta NSW 2150 Locked Bag 5022, Parramatta NSW 2124 Phone: +61 2 9995 5000 (switchboard) Phone: 131 555 (NSW only – environment information and publications requests) Fax: +61 2 9995 5999 TTY users: phone 133 677, then ask for 131 555 Speak and listen users: phone 1300 555 727, then ask for 131 555 Email: [email protected] Website: www.epa.nsw.gov.au Report pollution and environmental incidents Environment Line: 131 555 (NSW only) or [email protected] See also www.epa.nsw.gov.au ISBN 978 1 922447 52 4 EPA 2021P2938 June 2021

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mailto:[email protected]

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NSW Energy from Waste Policy Statement | ii

Definitions Eligible waste fuels Waste or waste-derived materials considered by the EPA to pose a low risk

of harm to the environment and human health due to their origin, low levels of contaminants and consistency over time.

Energy recovery facility A facility that thermally treats waste or waste-derived materials that do not meet the definition of an eligible waste fuel. These facilities must be able to demonstrate that they will be using current international best practice techniques.

Processing facility Facility undertaking genuine resource recovery operations, producing separate output material streams for reuse or recovery. Facility may be separate to, or on the same site as, an energy from waste facility.

Resource recovery order and exemption

Resource recovery orders and exemptions are issued by the EPA under Part 9 of the Protection of the Environment Operations (Waste) Regulation 2014 and exempt a person from the various waste regulatory requirements that apply to the use of a waste fuel (e.g. waste disposal licensing, levy payments, etc.). The exemptions apply to waste fuels determined by the EPA to be fit-for-purpose, genuine energy recovery opportunities.

Thermal treatment According to Schedule 1 of the Protection of the Environment Operations Act 1997, thermal treatment means the processing of waste by burning, incineration, thermal oxidation, gasification, pyrolysis, plasma or other thermal treatment processes.

Waste As defined in the dictionary of the Protection of the Environment Operations Act 1997.

NSW Energy from Waste Policy Statement | 1

1. Introduction The Environment Protection Authority (EPA) recognises that the recovery of energy and resources from the thermal processing of waste has the potential, as part of an integrated waste management strategy, to deliver positive outcomes for the community and the environment. Energy from waste can be a valid pathway for residual waste where:

• further material recovery through reuse, reprocessing or recycling is not financially sustainable or technically achievable

• community acceptance to operate such a process has been obtained. In NSW, two key policy objectives are enshrined in the state’s waste legislation. Firstly, the Protection of the Environment Operations Act 1997 (POEO Act) sets the framework to ensure that human health and the environment are protected from the inappropriate use of waste. Secondly, the Waste Avoidance and Resource Recovery Act 2001 (WaRR Act) aims to ensure that consideration of resource management options occurs in the following order: 1. avoidance of unnecessary resource consumption 2. resource recovery (including reuse, reprocessing, recycling and energy recovery) 3. disposal. Where waste cannot be avoided or products reused, various recovery technologies are available to maximise resource efficiencies and increase the sustainability of our communities, businesses and industries. The EPA has applied the following overarching principles to waste avoidance and recovery:

• higher value resource recovery outcomes are maximised • air quality and human health are protected • ‘mass burn’ disposal outcomes are avoided • scope is provided for industry innovation. The thermal treatment of waste provides an opportunity to recover the embodied energy from waste, offset the use of non-renewable energy sources, and avoid methane emissions from landfill. However, these outcomes depend on ensuring that any energy recovery proposals represent the most efficient use of the resource and the risks of harm to human health or the environment are adequately managed. Clean air is fundamental to everyone's wellbeing: poor air quality can be particularly critical to the health of children and chronically ill and older people, as well as affecting the natural environment and amenity of communities. To ensure emissions are adequately mitigated, facilities proposing to recover energy from waste will need to meet current international best practice techniques, particularly regarding:

• process design and control • emission control equipment design and control • emission monitoring with real-time feedback to the controls of the process. The NSW Energy from Waste Policy statement sets out the policy framework and overarching criteria that apply to facilities in NSW proposing to thermally treat waste or waste-derived materials for the recovery of energy. In doing so, it provides regulatory clarity to industry and the community.

http://www.epa.nsw.gov.au/legislation/Actsummaries.htm#poeo

http://www.epa.nsw.gov.au/legislation/Actsummaries.htm#waarra


2. Energy recovery framework and scope The NSW Energy from Waste Policy statement outlines the policy framework and technical criteria that apply to facilities proposing to recover energy from waste in NSW.

Scope of the policy statement The scope of the policy statement covers all facilities undertaking the thermal treatment of any waste1 or waste-derived materials, where thermal treatment means the processing of wastes by combustion, thermal oxidation, thermal or plasma gasification, pyrolysis and torrefaction. Where a thermal process, such as pyrolysis or gasification, produces a gas for subsequent combustion (for example, a syngas), the facility where that gas is combusted will also be subject to this framework. However, there are some thermal treatment applications that fall outside the scope of this policy statement. The following facilities are excluded as they are not considered to be undertaking genuine energy recovery:

• incineration facilities for the destruction of waste • facilities for the thermal treatment of contaminated soil • facilities proposing the thermal treatment of unprocessed mixed waste streams • facilities proposing the thermal treatment of waste that has been exhumed from landfills • facilities proposing the thermal treatment of hazardous waste materials. Other facilities excluded from this policy statement include those that are undertaking a form of thermal treatment to which the technical or resource recovery criteria in the statement are not relevant or for which other regulatory frameworks already apply, namely:

• thermal processes where there is no change in the chemical composition of the waste • transport fuels produced from waste • autoclaving processes • biological processes, such as anaerobic digestion and composting of waste.

Policy framework The definition of waste covers a range of materials that vary in their origin, composition, contamination and risk profile. The EPA recognises that a framework that facilitates a risk-based approach to the recovery of energy from waste will deliver certainty for industry, the community and the environment. This policy statement establishes a two-tiered framework, separating the requirements for low-risk wastes proposed for thermal treatment from all other wastes. Waste or waste-derived materials that pose a minimal risk of harm to human health and the environment due to their origin, low levels of contaminants and consistency over time will be categorised as eligible waste fuels and listed in the policy statement. As information about certain waste and waste-derived streams improves, the EPA will review the eligible waste fuels list from

1 As defined in the Protection of the Environment Operations Act 1997


time to time. Further information regarding the requirements to be met by eligible waste fuels is available in Section 3 of this policy statement. Facilities proposing to thermally treat any waste or waste-derived materials that are not listed as an eligible waste fuel must meet the requirements of an energy recovery facility. Further information regarding the requirements for energy recovery facilities is available in Section 4 of this policy statement.

Public consultation and the good neighbour principle Regardless of whether a facility plans to go ahead with a proposal under Section 3 or 4 of this policy statement, it will be essential that proponents provide effective information and public consultation about energy from waste proposals. As proposals progress from the concept to detailed development assessment stage, proponents should engage in a genuine dialogue with the community and ensure that planning consent and other approval authorities are provided with accurate and reliable information. The operators of an energy from waste facility will need to be ‘good neighbours’ – particularly if near a residential setting but also where there are workers in other facilities. This would apply to waste deliveries and operating hours, but most importantly with respect to readily available information about emissions and resource recovery outcomes.


3. Eligible waste fuels Eligible waste fuels are those that are considered by the EPA to pose a low risk of harm to human health and the environment due to their origin, composition and consistency. The following wastes are categorised by the EPA as eligible waste fuels: 1. biomass from agriculture 2. forestry and sawmilling residues 3. uncontaminated wood waste 4. recovered waste oil 5. organic residues from virgin paper pulp activities 6. landfill gas and biogas 7. source-separated green waste (used only in processes to produce char) 8. tyres (used only in approved cement kilns). The EPA may update the list of eligible waste fuels from time to time. Eligible waste fuels may be thermally treated using a range of treatment technologies, provided a resource recovery order and exemption has been granted by the EPA. The origin, composition and consistency of these wastes must ensure that emissions from thermal treatment will be known and consistent over time. Facilities proposing to use eligible waste fuels must meet the following criteria:

• ability to demonstrate to the EPA that the proposed waste consistently meets the definition of an EPA-approved eligible waste fuel

• confirm there are no practical, higher order reuse opportunities for the waste • fully characterise the waste and/or undertake proof of performance meet the relevant emission standards as set out in the Protection of the Environment Operations (Clean Air) Regulation 2010. Note: Eligible waste fuels that also fall under the definition of a standard fuel as defined in the Protection of the Environment Operations (Clean Air) Regulation 2010 would not need to meet the above criteria but will still require appropriate approval for their use. Further details are provided in the EPA’s Eligible Waste Fuels Guidelines. These include how to apply for a resource recovery order and exemption for the use of an eligible waste fuel and definitions for each of the listed eligible waste fuels.

https://www.epa.nsw.gov.au/licensing-and-regulation/legislation-and-compliance/acts-administered-by-the-epa/regulation-summaries#poeoca

https://www.epa.nsw.gov.au/licensing-and-regulation/legislation-and-compliance/acts-administered-by-the-epa/regulation-summaries#poeoca


4. Energy recovery facilities Any facility proposing to thermally treat a waste or waste-derived material that is not a listed eligible waste fuel (Section 3) must meet the requirements to be an energy recovery facility. If the facility is proposing to thermally treat a combination of eligible and other waste fuels, it will be subject to the requirements of an energy recovery facility. Energy recovery facilities refer to facilities that thermally treat waste-derived materials that fall outside the low-risk ‘eligible waste fuels’ definition. These facilities must therefore show they will be using current international best practice techniques, particularly regarding:

• process design and control • emission control equipment design and control • emission monitoring with real-time feedback to the controls of the process • arrangements for the receipt of waste • management of residues from the energy recovery process. These considerations ensure that air pollution is appropriately mitigated. Energy recovery facilities must use technologies that are proven, well understood and capable of handling the expected variability and type of waste feedstock. This must be demonstrated through reference to fully operational plants using the same technologies and treating like waste streams in other similar jurisdictions. As well as using current best practice techniques, energy recovery facilities must ensure that they meet the following technical, thermal efficiency and resource recovery criteria.

Technical criteria An energy recovery facility processing wastes other than ‘eligible waste fuels’ must satisfy all the technical requirements below, regardless of whether the facility is existing or purpose-built and the waste input is the sole feedstock or a fuel for co-firing.

Plant design and operation The gas resulting from the process should be raised, after the last injection of combustion air, in a controlled and homogenous fashion and even under the most unfavourable conditions to a minimum temperature of 850°C for at least two seconds (as measured near the inner wall or at another representative point of the combustion chamber). If the waste fuel fed to the primary (first) combustion chamber has a content of more than 1% of halogenated organic substances, expressed as chlorine, the temperature should be raised to 1,100°C for at least two seconds after the last injection of air. The total organic carbon (TOC) or loss on ignition (LOI) content of the slag and bottom ashes must not be greater than 3% or 5%, respectively, of the dry weight of the material. Waste feed interlocks are required to prevent waste from being fed to the facility when the required temperature has not been reached either at start-up or during operation. The EPA will set operating conditions in environment protection licences for all approved energy recovery facilities.


Emission standards Energy recovery facilities must achieve emission performance consistant with best practice. Energy recovery facilities must be designed and operated to ensure they achieve air emissions no greater than the standards prescribed in Table 1.

Table 1 Emission standards for energy recovery facilities

Pollutant Concentration1 Averaging period

Solid particles (total) 20 mg/m3 One hour or the minimum sampling period specified in the relevant test method, whichever is the greater

Type 1 and 2 substances in aggregate2

0.3 mg/m3 One hour or the minimum sampling period specified in the relevant test method, whichever is the greater

Mercury 0.04 mg/m3 One hour or the minimum sampling period specified in the relevant test method, whichever is the greater

Cadmium and thallium (total) 0.02 mg/m3 One hour or the minimum sampling period specified in the relevant test method, whichever is the greater

Dioxins and furans 0.1 ng/m3 One hour or the minimum sampling period specified in the relevant test method, whichever is the greater

Sulphur dioxide (SO2) 100 mg/m3 One hour

Oxides of nitrogen (NOx) (as NO2 equivalent)

250 mg/m3 One hour

Carbon monoxide (CO) 80 mg/m3 One hour

Hydrogen chloride (HCl) 50 mg/m3 One hour

Hydrogen fluoride (HF) 4 mg/m3 One hour

Volatile organic compounds (VOCs) 20 mg/m3 One hour

Ammonia 5 mg/m3 24 hours Notes 1) Expressed at dry, 273 K, 101.3 kPa and 11 % oxygen 2) As defined in the Protection of the Environment Operations (Clean Air) Regulation 2010

The EPA may set additional emission limits or conditions in the environment protection licence for approved energy recovery facilities. This may include, but is not limited to, limits for additional pollutants or additional and more stringent limits for pollutants in Table 1. Additional limits will be applied to address a project specific risk, and/or promote reduced average emissions and continuous improvement.


Process monitoring There must be continuous measurements of the operational parameters listed in Table 2. This process monitoring data must be held by the proponent for a period of three years.

Table 2 Operational parameter monitoring requirements for energy recovery facilities

Operational parameter Location Frequency

Temperature Representative points in the combustion chamber and the discharge stack

Continuous

Oxygen content Discharge stack Continuous

Moisture content Discharge stack Continuous

Pressure Discharge stack Continuous

Proof of performance (POP) As part of the environment protection licence conditions of all energy recovery facilities, the EPA will require operators to complete proof of performance (POP) testing to demonstrate compliance with air emissions standards. Proponents must provide a commissioning plan during the environment protection licence application stage, detailing the POP emission testing that will be undertaken.

Emissions monitoring Following successful plant commissioning, including POP testing, the EPA will require operators to undertake ongoing monitoring to demonstrate compliance with air emission standards. The minimum emissions monitoring requirements are listed in Table 3. The EPA may set more stringent monitoring requirements in conditions of the environment protection licence, including but not limited to continuous monitoring of additional pollutants, where feasible monitoring techniques become available.

Table 3 Minimum emissions monitoring requirements for energy recovery facilities

Pollutant Unit of measure Frequency

Oxides of nitrogen (NOx) mg/m3 Continuous

Carbon monoxide (CO) mg/m3 Continuous

Solid particles (Total) mg/m3 Continuous

Total organic compounds mg/m3 Continuous

Hydrogen chloride (HCl) mg/m3 Continuous

Hydrogen fluoride (HF)1 mg/m3 Continuous

Sulphur dioxide (SO2) mg/m3 Continuous

Ammonia mg/m3 Continuous2

Type 1 and 2 substances in aggregate

mg/m3 Every three months

Mercury mg/m3 Every three months

Cadmium and Thallium (Total) mg/m3 Every three months

Polycyclic aromatic hydrocarbons (PAH)

mg/m3 Every three months for the first 12 months of operation. Two measurements per year after that.


Pollutant Unit of measure Frequency

Dioxins and furans ng/m3 Every three months for the first 12 months of operation. Two measurements per year after that.

Carbon dioxide (CO2) mg/m3 Continuous

Nitrous Oxide (N2O) mg/m3 Continuous2

Notes 1) The continuous measurement of HF may not be required if treatment stages for HCl are used which ensure that

the emission limit value for HCl is not being exceeded. 2) Or as otherwise agreed to by written notice from the EPA

Emissions reporting To the extent practicable validated emission monitoring data must be made available publicly through an online portal in near real time. Emission monitoring data must be made available to the EPA in real time graphical publication and a weekly summary of continuous monitoring data and compliance with emissions limits published on the internet.

Air emission modelling assessment An air quality impact assessment must be completed according to the Approved Methods for the Modelling and Assessment of Air Pollutants in NSW.

Thermal efficiency criteria This policy statement is restricted in its scope to facilities that are designed to thermally treat waste for the recovery of energy rather than as a means of disposal. The net energy produced from thermally treating that waste, including the energy used in applying best practice techniques, must therefore be positive. To meet the thermal efficiency criteria, facilities must demonstrate that at least 25% of the energy generated from the thermal treatment of the material will be captured as electricity (or an equivalent level of recovery for facilities generating heat alone). Energy recovery facilities must also demonstrate that any heat generated by the thermal processing of waste is recovered as far as practicable. This includes use of waste heat for steam or electricity generation or for process heating of combined heat and power schemes.

Resource recovery criteria The EPA considers energy recovery to be a complementary waste management option for the residual waste produced from material recovery processes or source-separated collection systems. This policy statement’s objectives in setting resource recovery criteria are to:

• promote the source separation of waste where technically and economically achievable • drive the use of best practice material recovery processes • ensure only the residual from genuine resource recovery operations are eligible for use as a

feedstock for an energy recovery facility. Energy recovery facilities may only receive feedstock from waste processing facilities or collection systems that meet the criteria outlined in Tables 4 and 5.

https://www.epa.nsw.gov.au/your-environment/air/industrial-emissions/modelling-assessing-air-emissions/approved-methods-modelling-assessing-air-pollutants

https://www.epa.nsw.gov.au/your-environment/air/industrial-emissions/modelling-assessing-air-emissions/approved-methods-modelling-assessing-air-pollutants


Proponents wishing to use waste or waste-derived materials for energy recovery that are not defined in Tables 4 or 5 must contact the EPA to discuss their proposal. The EPA will consider these on a case-by-case basis according to the energy from waste considerations outlined in this policy statement and the principles set out in the POEO Act and WaRR Act.

Table 4 Resource recovery criteria for energy recovery facilities – mixed waste streams

Mixed waste stream Processing facility % residual waste allowed for energy recovery

Mixed municipal waste (MSW) Facility processing mixed MSW waste where a council has separate collection systems for dry recyclables and food and garden waste

No limit by weight of the waste stream received at a processing facility

Facility processing mixed MSW waste where a council has separate collection systems for dry recyclables and garden waste

Up to 40% by weight of the waste stream received at a processing facility

Facility processing mixed MSW waste where a council has a separate collection system for dry recyclables


Mixed commercial and industrial waste (C&I)

Facility processing mixed C&I waste


Facility processing mixed C&I waste where a business has separate collection systems for all relevant waste streams

No limit by weight of the waste stream received at a processing facility

Mixed construction and demolition waste (C&D)

Facility processing mixed C&D waste


Residuals from source-separated materials

Source-separated recyclables from MSW

Facility processing source- separated recyclables from MSW


Source-separated garden waste Facility processing garden waste Up to 5% by weight of the waste stream received at a processing facility

Source-separated food waste (or food and garden waste)

Facility processing source- separated food or source- separated food and garden waste



Table 5 Resource recovery criteria for energy recovery facilities – separated waste streams

Separated waste stream Feedstock able to be used at an energy recovery facility

Waste wood Residual wood waste sourced directly from a waste generator e.g. manufacturing facility

Textiles Residual textiles sourced directly from a waste generator

Waste tyres End-of-life tyres

Biosolids Used only in a process to produce a char for land application

Source separated food and garden organics

Used only in a process to produce a char for land application

Notes The EPA may consider increases to the maximum allowable percentage of residuals from facilities receiving mixed municipal and commercial and industrial waste where a facility intends to use the biomass component from that process for energy recovery, rather than land application. The facility must be able to demonstrate they are using best available technologies for material recovery of that stream. Waste streams proposed for energy recovery should not contain contaminants such as batteries, light bulbs or other electrical or hazardous wastes. Bio-char or char materials produced from facilities using mixed waste streams will not be able to be considered for land application as a soil amendment or improvement agent. The C&I ‘no limit’ category is likely to apply only to mixed waste collected from single generators of large volumes of waste (e.g. supermarkets) or precinct-based businesses (e.g. shopping centres). Proponents will need to demonstrate that each entity generating waste has effective and operating collection systems for all waste streams they generate that have reuse or recycling opportunities (e.g. paper/cardboard collection; organic collection; and residual waste collection). Proponents wishing to use the C&I ‘no limit’ category will need to contact the EPA to determine the eligibility of each entity.

Appendix 3

Eligible Waste Fuels Guidelines

www.epa.nsw.gov.au



Guidelines

© 2016 State of NSW and Environment Protection Authority

With the exception of photographs, the State of NSW and Environment Protection Authority are pleased to allow this material to be reproduced in whole or in part for educational and non-commercial use, provided the meaning is unchanged and its source, publisher and authorship are acknowledged. Specific permission is required for the reproduction of photographs.

The Environment Protection Authority (EPA) has compiled these guidelines in good faith, exercising all due care and attention. No representation is made about the accuracy, completeness or suitability of the information in this publication for any particular purpose. The EPA shall not be liable for any damage which may occur to any person or organisation taking action or not on the basis of this publication. Readers should seek appropriate advice when applying the information to their specific needs.

All content in this publication is owned by the EPA and is protected by Crown Copyright, unless credited otherwise. It is licensed under the Creative Commons Attribution 4.0 International (CC BY 4.0), subject to the exemptions contained in the licence. The legal code for the licence is available at Creative Commons.

The EPA asserts the right to be attributed as author of the original material in the following manner: © State of New South Wales and the Environment Protection Authority 2016.

Published by:

Environment Protection Authority 59 Goulburn Street, Sydney NSW 2000 PO Box A290, Sydney South NSW 1232 Phone: +61 2 9995 5000 (switchboard) Phone: 131 555 (NSW only – environment information and publications requests) Fax: +61 2 9995 5999 TTY users: phone 133 677, then ask for 131 555 Speak and listen users: phone 1300 555 727, then ask for 131 555 Email: [email protected] Website: www.epa.nsw.gov.au

Report pollution and environmental incidents Environment Line: 131 555 (NSW only) or [email protected] See also www.epa.nsw.gov.au

ISBN 978 1 76039 618 3 EPA 2016/0756 December 2016

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iii

Contents

Introduction ......................................................................................................................... 1

Background .................................................................................................................... 1

Scope and application .................................................................................................... 1

Definitions....................................................................................................................... 2

Part 1 – Eligible waste fuels ................................................................................................ 3

Definitions of eligible waste fuels .................................................................................... 3

Part 2 – Additional criteria for eligible waste fuels ........................................................... 7

Waste hierarchy.............................................................................................................. 7

Chemical and physical homogeneity of the waste........................................................... 7

Quality assurance ........................................................................................................... 7

Compliance with emission limits ..................................................................................... 8

Changes to emission standard requirements .................................................................. 8

Part 3 – Regulatory framework for the use of waste as fuel ............................................. 9

Definition of waste and its application to waste fuels ...................................................... 9

Resource recovery orders and exemptions..................................................................... 9

Part 4 – Applying for a resource recovery order or exemption ...................................... 10

Eligible waste fuel application – required format ........................................................... 11

Part 5 – Characterisation requirements ........................................................................... 13

Amended sampling and testing requirements ............................................................... 13

Test methods ................................................................................................................ 15

Related documents ........................................................................................................... 16

Contacts for further advice ............................................................................................... 16


1

Introduction

Background

This document should be read in conjunction with the NSW Energy from Waste Policy Statement, which allows for certain low risk wastes or waste-derived materials to be thermally treated. These low risk wastes are referred to in the NSW Energy from Waste Policy Statement as eligible waste fuels.

This document consists of five parts:

1. Eligible waste fuels 2. Additional criteria for eligible waste fuels 3. Regulatory framework for the use of waste as fuel 4. Applying for a resource recovery order and/or exemption 5. Characterisation requirements.

Any facility proposing to thermally treat a waste or waste-derived material that is not a listed eligible waste fuel must meet the requirements of an Energy Recovery Facility and use current international best practice techniques. In these cases, proponents should refer to Section 4 of the NSW Energy from Waste Policy Statement and the Energy Recovery Facility Guidelines.

Scope and application

These guidelines only relate to the list of eligible waste fuels outlined in the NSW Energy from Waste Policy Statement.

Some eligible waste fuels may also be standard fuels as defined in clause 31 of the Protection of the Environment Operations (Clean Air) Regulation 2010 (Clean Air Regulation). Standard fuels are defined as any unused and uncontaminated solid, liquid or gaseous fuel that is:

a. a coal or coal-derived fuel (other than any tar or tar residues), or

b. a liquid or gaseous petroleum-derived fuel, or

c. a wood or wood-derived fuel, or

d. bagasse.

Standard fuels that are also eligible waste fuels still require appropriate approvals for their use. The EPA will assess applications for eligible waste fuels that are also standard fuels on a case by case basis.

http://www.epa.nsw.gov.au/wastestrategy/energy-from-waste.htm





2

Definitions

Agriculture Farming, including cultivation of the soil for the growing of crops and the rearing of animals to provide food, wool and other products.

Anaerobic digestion Anaerobic digestion is a biological process that occurs when organic matter is decomposed by bacteria in the absence of oxygen (i.e. anaerobically). As the bacteria decompose the material, methane and carbon dioxide are produced.

Eligible waste fuel Waste or waste-derived materials considered by the EPA to pose a low risk of harm to the environment and human health due to their origin, low levels of contaminants and consistency over time.

Processing facility A facility undertaking bona fide resource recovery operations producing separate output material streams for reuse or recovery. The facility may be separate to or on the same site as an energy from waste facility.

Resource recovery exemption

A resource recovery exemption includes conditions for the use of the exempt waste as a fuel or in a thermal treatment process. The exemption may include specifications of how to use the exempt waste fuel, record-keeping and other requirements.

Resource recovery exemptions are issued by the EPA that exempt a person from the various waste regulatory requirements that apply to the use of a waste fuel (e.g. waste disposal licensing, levy payments, etc.). The exemptions apply to waste fuels the EPA determines to be fit-for-purpose, bona fide energy recovery opportunities.

Resource recovery order

A resource recovery order is issued to the generator and/or processor of the exempt waste fuel. The resource recovery order includes conditions that the generator/processor must meet to supply the waste as a fuel or in a process of thermal treatment. Orders may include specifications such as record-keeping, reporting and other requirements for the exempt waste.

Thermal treatment In accordance with Schedule 1 of the Protection of the Environment Operations Act 1997, thermal treatment means the processing of waste by burning, incineration, thermal oxidation, gasification, pyrolysis, plasma or other thermal treatment processes.

Waste As defined in the Dictionary of the Protection of the Environment Operations Act 1997 and the Protection of the Environment Operations (Waste) Regulation 2014.


3

Part 1 – Eligible waste fuels

Eligible waste fuels are those the EPA considers to pose a low risk of harm to the environment and human health due to their origin, composition and consistency. These are listed in this part and in Section 3 of the NSW Energy from Waste Policy Statement. The EPA may update the list of eligible waste fuels from time to time.

Facilities proposing to use eligible waste fuels must meet the following criteria:

1. be able to demonstrate to the EPA that the proposed waste consistently meets the definition of an EPA approved eligible waste fuel

2. ensure there are no practical, higher order reuse opportunities for the waste 3. fully characterise the waste and/or undertake proof of performance (where required),

and 4. meet the relevant emission standards as set out in the Clean Air Regulation.

The listing of a waste or waste-derived material as an eligible waste fuel does not constitute an approval to use that material at a particular facility. Proponents must first apply to the EPA for a resource recovery order and exemption in accordance with Part 4 of these guidelines.

Definitions of eligible waste fuels

Section 3 of the NSW Energy from Waste Policy Statement lists the wastes categorised by the EPA as eligible waste fuels. These wastes are defined below.

1. Biomass from agriculture

Definition

Weeds, plant or crop residues that are free of any physical contaminants, produced directly from agricultural practices; for example, non-putrescible natural organic fibrous materials and organic residues from harvest activities. These residues may include fibres, roots, stalks, stubble, leaves, seed pods, nut shells and some waste from agricultural processing such as cotton and cane trash.

Additional information

The EPA notes that this material may contain pesticide or herbicide residues. The risks presented by these residues will be assessed as part of the resource recovery order and exemption application.

This definition excludes:

waste material from processing dairy products or beverages

waste from the production of food, and

dead animals, animal parts, pelts, manure and animal bedding, e.g. cage and barn poultry litter.

2. Forestry and sawmilling residues

Definition

Uncontaminated, organic fibrous wood residues and natural wood wastes that result from forestry and sawmilling operations such as, heads, tree thinnings, sawmill sawdust, shavings, chips, bark and other offcuts.

Sawmilling operations are the primary processing of round wood into non-round wood products such as planks, boards, beams and other cut and processed wood products.


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Forestry and sawmill residue materials must be demonstrated to have no risk of contamination; for example, there must be no presence of treated, preserved, lacquered, glued, laminated or coated timber or wood products.

Native forest biomaterial is specifically prohibited from use for electricity generation in accordance with the Protection of the Environment Operations (General) Regulation 2009. The Regulation exempts some native forest residues from forestry operations authorised by a private native forestry property vegetation plan, integrated forestry operations approval or an invasive native species order.

Native forest biomaterial

The use of native forest biomaterial for electricity generation is regulated through the Protection of the Environment Operations (General) Regulation 2009, clauses 96 to 98. These clauses expressly prohibit the use of native forest biomaterials in electricity generation, but also provide exemptions for certain types of native vegetation or woody waste from the definition of native forest biomaterials.

The material exempted from the definition is able to be burned for the purpose of electricity generation. Native forestry biomaterial can be used in electricity generation if it is:

invasive native species cleared in accordance with property vegetation plans that have been approved under the Native Vegetation Act 2003 or an invasive native species order under the Native Vegetation Regulation 2013

pulp wood logs and heads and off-cuts from clearing carried out in accordance with a private native forestry property vegetation plan or forestry operations carried out in accordance with an integrated forestry operations approval under the Forestry Act 2012

trees cleared as a result of thinning carried out in accordance with a private native forestry property vegetation plan or an integrated forestry operations approval.

More information can be found at www.epa.nsw.gov.au/licensing/natforestbiofuel.htm

3. Uncontaminated wood waste

Definition

Wood waste that is generated in primary and secondary manufacturing processes at facilities with demonstrated quality control over the uncontaminated wood waste stream.


Uncontaminated wood waste includes pre-consumer manufacturing and processing waste materials such as off-cuts, saw dust, wood shavings, untreated packaging crates, untreated pallets and engineered timbers made with urea formaldehyde or phenol formaldehyde resins only.

Demonstrated control refers to both the generation and collection of the waste material. The facility must have robust quality assurance and/or quality control (QA/QC) procedures, a well-controlled chain of custody for the raw materials, generation of waste and collection systems. Facilities with control of their waste stream must also have comprehensive knowledge and control of the sources of waste, the original input materials, as well as knowledge and control of potential contaminants.

Uncontaminated wood waste excludes:

post-consumer waste

wood waste extracted from mixed waste streams, such as construction and demolition waste

http://www.epa.nsw.gov.au/licensing/natforestbiofuel.htm


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anything defined as a source separated green waste

treated timber

painted or coated wood and most engineered wood products.

Uncontaminated wood waste does not include wood waste recovered from highly variable streams, such as mixed municipal solid waste or construction and demolition waste, due to their potential to contain a large number of chemical and physical contaminants over time. Applicants wanting to pursue the use of this material as a fuel should refer to Section 4, Energy recovery facilities, of the NSW Energy from Waste Policy Statement.

Treated timber means wood treated with water, solvent and/or oil-borne preservatives. This includes but is not limited to copper chromium arsenic (CCA), light organic solvent preservative (LOSP), creosote and envelope treatments for preservation, insecticides and fungal treatments.

4. Recovered waste oil

Definition

Used oil that is recycled back into lower grade oils for combustion as a start-up fuel. This may include vegetable and/or mineral oils.


The quality of waste oil, and therefore any potential contaminants present, can vary significantly depending on the original use of the oil, as well as any processing and/or treatment it has undergone.

For a facility to use waste oil, it will need to meet specifications set by the EPA for quality and consistency of the waste oil over time. Risks presented by contaminants will be assessed as part of individual resource recovery order and exemption applications.

5. Organic residues from virgin paper pulp activities

Definition

Solid organic waste such as cellulose fibres, fibre bundles and minor quantities of sand, mud and fine grit from pulping and screening operations.


This material will be assessed on a case by case basis, and potential requirements or controls for the use of this material will be considered using a risk-based approach. The assessment will take into account the processing techniques, types of treatment and, if applicable, the chemicals used.

This definition excludes any:

organic residues or any percentage of organic residues from processes using waste cardboard or paper (recycled paper)

organic residues derived from any processes involving chlorine; this refers to both elemental and total chlorine.

6. Landfill gas and biogas

Definition

Gas generated during anaerobic digestion, either naturally in the decomposition of organic waste materials contained in landfills, or in an anaerobic digester.

Examples of organic waste streams for an anaerobic digester include: municipal wastewater treatment, industrial wastewater treatment, food waste digestion and agricultural waste (e.g. manure, crop).


6


The level of contaminants in these gases can vary significantly depending on the source characteristics. Treatment requirements will depend on the source characteristics and the technologies using the gas/es. Treatment can include physical, chemical and biological processes to remove water, particulates and contaminants from the gas. The EPA will assess these conditions as part of a resource recovery order and exemption application.

7. Source separated green waste

Definition

Garden vegetation and plant materials that are segregated at the point of generation and collected as a separate material stream for processing; for example, garden organics from arborist operations, commercial gardening operations, council garden waste kerbside collections and public drop-off collections. This includes materials such as branches, grass, leaves, plant trimmings, tree stumps and bark.


Source separated green waste is an eligible waste fuel only when it is used in a thermal process to produce char (such as pyrolysis) for land application. Char materials produced from mixed waste streams will not be eligible for land application.

Proponents wanting to use source separated green waste in a thermal process must demonstrate robust QA/QC procedures, ensuring that the green waste is uncontaminated with physical contaminants such as plastics and treated, painted or coated timbers.

Source separated green waste does not include:

green waste extracted from mixed waste streams, such as construction and demolition waste

material from the clean-up of illegal dumping

material classified as agricultural biomass or uncontaminated wood waste.

8. Tyres

Definition

Used, rejected or unwanted tyres, including shredded tyres, tyre pieces, or tyre crumb containing at least 98% tyre material.


Tyres are an eligible waste fuel only when used as fuel in an approved cement kiln. An approved cement kiln has development consent for use of a non-standard fuel, and an environment protection licence (EPL) with conditions allowing the use of tyres as a fuel source within the kiln.

Notes

1. As information about certain waste and waste-derived streams improves, the EPA will review the eligible waste fuels list from time to time.

2. Chars are not specifically listed in Section 3 as an eligible waste fuel. This is due to the range of contaminants that may be concentrated in char made from waste. Chars are likely to be considered for use as an eligible waste fuel only where they are produced solely from the listed eligible waste fuels in Section 3. Char made from other waste materials may be considered on a case by case basis after analysis of the materials used and produced, demonstration of the process and proof of performance.


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Part 2 – Additional criteria for eligible waste fuels

This section outlines the additional criteria that proponents should consider before applying for a resource recovery order and exemption for a waste material listed as an eligible waste fuel in Section 3 of the NSW Energy from Waste Policy Statement.

Waste hierarchy

The NSW waste regulatory framework ensures that all resource management options are considered, in accordance to the waste hierarchy, in the following order:

1. avoidance of unnecessary resource consumption 2. reuse and recycling 3. energy recovery 4. treatment of waste 5. disposal.

Figure1. Hierarchy of waste management options from most preferable to least preferable

The thermal treatment of waste provides an opportunity to recover the embodied energy from waste, offset the use of non-renewable energy sources and avoid methane emissions from landfill. Applicants must ensure that the proposed use of an eligible waste fuel for energy recovery is consistent with this hierarchy.

Chemical and physical homogeneity of the waste

The overarching principle of the eligibility of a waste as an eligible waste fuel is that it should pose a minimal risk of harm to the environment and human health due to its origin, low levels of contaminants and consistency over time. The proponent must consider the consistency of the proposed waste fuel to ensure its potential environmental impact will not vary over time.

Quality assurance

The EPA strongly encourages the development of specifications against which the material will be assessed and QA/QC programs to ensure the ongoing consistency and quality of the


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material over time. Specifications should help ensure that the materials to be used are well-characterised and of a consistent quality.

Compliance with emission limits

A facility that proposes to use an eligible waste fuel must currently be meeting all relevant emission standards as required under the facility’s EPL and the Clean Air Regulation. The Clean Air Regulation prescribes standards for certain groups of plant and premises to regulate industries’ air impurity emissions, as well as monitoring and other measures protecting and maintaining air quality in NSW.

The EPA will not consider applications for a resource recovery order and exemption to use an eligible waste fuel at existing facilities that are not achieving compliance with their relevant emission standards.

Changes to emission standard requirements

A proposal to use eligible waste fuels will trigger a review of a facility’s emissions limits and controls. This may result in new emissions groups and limits being applied to the facility using the eligible waste fuel (in accordance with clause 33 of the Clean Air Regulation).

A facility changing fuels, experiencing fuel feedstock variation, or changing procedures for the supply and processing of eligible waste fuels, may result in changes to the facility’s emissions limits, planning consent or EPL conditions.

Proponents should consider whether the use of an eligible waste fuel will cause changes in air emissions, potentially triggering more stringent emission standard requirements; that is, moving from a lower group to a higher group. Proponents may be required to demonstrate compliance with EPL conditions and the Clean Air Regulation, as determined by the fuel and thermal treatment processes.


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Part 3 – Regulatory framework for the use of waste as fuel

This section outlines the regulatory framework for the use of waste or waste-derived materials as fuel in NSW.

Definition of waste and its application to waste fuels

The Protection of the Environment Operations Act 19971 and associated Protection of the Environment Operations (Waste) Regulation 2014 (the Waste Regulation) include in their definition of waste any processed, recycled, reused or recovered substance produced wholly or partly from waste that is used as fuel.

All eligible waste fuels or waste-derived materials to be used as fuel, regardless of the type or amount of processing they have undergone, are captured as waste and must meet relevant waste regulatory requirements, such as the need to hold an EPL or pay the waste levy.

The EPA can exempt a person from certain waste regulatory requirements. These exemptions are known as resource recovery orders and exemptions and provide both significant responsibility and the benefit of being ‘excused’ from some of the legal obligations relating to energy recovery or the thermal treatment of waste.

Resource recovery orders and exemptions

Under clauses 92 and 93 of the Waste Regulation, orders and exemptions that are issued to allow the use of a waste material as an eligible waste fuel are known as resource recovery orders and exemptions.

Resource recovery orders – conditions for generators and processors

Resource recovery orders include conditions which generators and processors of waste must meet to supply the waste for land application, use as fuel or in connection with a process of thermal treatment. They may include specifications, record-keeping, reporting and other requirements. All resource recovery orders are made under clause 93 of the Waste Regulation. Generators and processors of exempt waste will be informed of the conditions of an order either in writing or by a notice in the NSW Government Gazette and by publication on the EPA website.

Resource recovery exemptions – conditions for consumers

Resource recovery exemptions contain the conditions which consumers must meet to apply waste to land, or use the waste as fuel or in connection with a process of thermal treatment outside certain requirements of the waste regulatory framework. They may include requirements on how to reuse or apply the waste, and record-keeping, reporting and other requirements. All resource recovery exemptions are made under clauses 91 and 92 of the Waste Regulation. Consumers will be informed of the conditions of an applicable exemption either in writing or by notice in the NSW Government Gazette and by publication on the EPA website.

1 Refer to the Dictionary in the Act.

http://www.epa.nsw.gov.au/wasteregulation/orders-exemptions.htm

http://www.epa.nsw.gov.au/wasteregulation/poeo-reg-2014.htm

http://www.epa.nsw.gov.au/wasteregulation/orders-exemptions.htm

http://www.epa.nsw.gov.au/wasteregulation/poeo-reg-2014.htm


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Part 4 – Applying for a resource recovery order or exemption

Proponents seeking resource recovery orders and exemptions for the use of waste material/s as eligible waste fuel must submit an application in the format required by the EPA as outlined below.

Applications will not be considered unless they provide all the information stipulated in this part. The EPA may request further information from the proponent to inform its decision.

Applications to use agricultural biomass must include information regarding sprays and fertilisers applied to the crops or material, and any potential impacts of spray drift.

Applications to use uncontaminated wood waste must include information about quality control and assurance processes throughout the supply chain that address contamination and control of the waste stream.

Applications to use forestry and sawmilling residues must include information about sprays or treatment that the waste would have been subject to, including fire retardants.

Applications to use source separated green waste must include information about the supply pathway of green waste, and quality control and assurance processes in the supply chain that address contamination and control of the waste stream.

All applications should be addressed to:

Manager Waste Strategy and Innovation NSW Environment Protection Authority PO Box A290 SYDNEY SOUTH NSW 1232

Or by email to: [email protected]

Notes

1. The EPA will only consider applications where the proponent has consulted with the appropriate consent authority or can demonstrate that the development consent permits the use of these materials as fuel at that facility.

2. Proponents should consult with local government and/or the consent authority regarding development consents and approvals, as modifications to an existing development consent or new consents may be required.

3. The EPA may request further information from the proponent to inform its decision. 4. Proponents are strongly encouraged to discuss their proposal with the EPA prior to

commencing work on an application. Proponents are also advised to consult, where necessary, with other relevant consent authorities regarding the proposal prior to submitting an application.

For any queries or to discuss your proposal, please contact the EPA’s Waste Strategy and Innovation Section on 131 555.



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Eligible waste fuel application – required format

1. Proponent(s) details

1.1 Applicant’s details including: name, address, phone number, the ACN and/or ABN of the proponent

1.2 If using a representative, the representative or consultant’s details

1.3 If the application is on behalf of another person, please provide the contact details of that person, including an ACN and/or ABN

Note: This section should identify the person who will be able to provide answers to any enquiries for further general or technical information. This person may be a consultant or representative of the applicant. In this case, the applicant should provide a letter authorising a representative or consultant to act on their behalf, ensuring they have the necessary skills, knowledge and authority to discuss the matters listed in these guidelines with the EPA.

2. Background information on the waste material

2.1 Description of the waste

2.2 What is the source of the waste or waste-derived material?

2.3 What processes has the material undergone? Including mechanical, chemical and biological description of the process, treatments, storage, transport, and any sample results

2.4 What is the expected volume and consistency of the material to be supplied over time?

3. Development consent and approvals

3.1 Details of development consent status, whether a request for development consent has been submitted, is in progress or has been obtained

3.2 Provide all development consent application documents with the application

4. Site management and quality control

4.1 Where is the facility?

4.2 Is the proposed facility licensed by the EPA?

4.3 What is the facility’s environment protection licence (EPL) number?

4.4 What quantity of eligible waste fuel will be stored and used at the facility?

4.5 How is the material going to be stored at the facility?

4.6 What procedures are in place to manage the input and output quality of the material over time?

4.7 What contingency plans exist for the receipt of waste during shutdown or failed delivery?

5. Characterisation of the waste material

5.1 What is the chemical composition of the material?

5.2 What are the typical properties or characteristics of the material?

5.3 What is the calorific value and combustion efficiency of the material?

5.4 What are the properties of the material that make it suitable for its proposed use?

Note: In addition to the analyses listed in Table 1 below, the applicant must outline whether the eligible waste fuel contains or potentially contains specific physical contaminants such as asbestos, pesticides, radioactive substances, plastics, glass, metal or any other physical contaminants. If these materials are likely to be present, they should be reported with appropriate management protocols or testing results.


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6. Higher order reuse opportunities

6.1 How is the material currently being managed (e.g. landfilled, other reuse, recovery option)?

6.2 Demonstrate that there are no practical, higher order reuse opportunities for the waste in the region

7. Characterisation of residual ash, wastes or by-products

7.1 What is the chemical composition of the material’s residual ash, wastes or by-products?

7.2 What are the typical properties or characteristics of the residual ash wastes or by-products?

7.3 What is the intended use or disposal avenues for the ash wastes or by-products?

8. Information on potential air impacts

8.1 What is the current concentration of air emissions from the emission unit?

8.2 Do the current air emissions comply with the relevant regulatory requirements in the Protection of the Environment Operations (Clean Air) Regulation 2010 (the Clean Air Regulation)?

8.3 What will be the concentration of air emissions from the emission unit when using the proposed eligible waste fuel and how do they compare to the existing fuel?

8.4 Are principal air toxics present in the waste material or expected in the air emissions?

8.5 Will the emissions comply with all relevant regulatory requirements in the Clean Air Regulation?

8.6 Has an air quality impact assessment for the facility been carried out having regard to potential air pollutants? What were the results?

8.7 What air monitoring is proposed to be carried out?

9. Specifications and standards

9.1 Has a specification been developed for the proposed fuel material?

9.2 Does the material meet, or is it required to meet any existing specifications or standards?

9.3 Are there any agreements between the producer and the user of the waste-derived material to ensure the material is ‘fit for purpose’?

9.4 What, if any, quality assurance/quality control (QA/QC) systems are in place to ensure consistency of calorific value, contaminant levels, quality and quantity of supply over time?

Notes

1. Standard fuels: In some cases, if the proposed material meets the definition of a standard fuel (as defined in clause 31 of the Clean Air Regulation) not all eligible waste fuel criteria will apply. The EPA will determine the information required on a case by case basis. Proponents are strongly encouraged to discuss their proposal with the EPA prior to commencing work on an application.

2. Proof of performance: As part of the application the EPA may require proponents to undertake proof of performance (POP) trials and emissions monitoring to demonstrate compliance with air emissions standards, before resource recovery orders and/or exemptions are issued.


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Part 5 – Characterisation requirements

As part of the application process outlined in Part 4, proponents may be required to undertake a chemical characterisation of their material in order for the EPA to be able to complete an assessment of the waste. Proponents should seek advice from the EPA before undertaking any sampling or testing.

Where the EPA advises that a chemical assessment is required, the proponent must ensure the waste material has undergone testing for the chemical contaminants in Table 1 for a minimum of 20 composite samples.

Samples must be analysed at a laboratory accredited for the relevant tests by the National Association of Testing Authorities Australia (NATA) or an equivalent accreditation body. The test methods used to obtain all data should be specified as part of the chemical characterisation.

Proponents should seek appropriate expertise in the completion of chemical assessments.

Amended sampling and testing requirements

The risk posed by some waste types may vary, so in some instances the EPA may agree to an amended sampling and testing regime rather than that outlined in this part. Proponents should discuss their proposal with the EPA before commencing work on a resource recovery exemption application, to confirm the sampling and testing requirements.

The following chemicals must be measured and assessed. Dry mass means that the samples are dried to a constant weight at ~100 degrees Celsius.


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Table 1: Chemical concentrations/material characteristics to be tested

No. Chemical/attributes Detection limit Units for reporting

1 Antimony ~ 2 mg/kg on a dry mass basis

2 Arsenic ~ 2 mg/kg on a dry mass basis

3 Beryllium ~ 0.1 mg/kg on a dry mass basis

4 Boron ~ 5 mg/kg on a dry mass basis

5 Cadmium ~ 0.5 mg/kg on a dry mass basis

6 Cobalt ~ 2 mg/kg on a dry mass basis

7 Copper ~ 2 mg/kg on a dry mass basis

8 Chromium ~ 2 mg/kg on a dry mass basis

9 Lead ~ 2 mg/kg on a dry mass basis

10 Manganese ~ 2 mg/kg on a dry mass basis

11 Molybdenum ~ 1 mg/kg on a dry mass basis

12 Nickel ~ 2 mg/kg on a dry mass basis

13 Selenium ~ 3 mg/kg on a dry mass basis

14 Tin ~ 2 mg/kg on a dry mass basis

15 Vanadium ~ 1 mg/kg on a dry mass basis

16 Zinc ~ 2 mg/kg on a dry mass basis

17 Total organic carbon ~ 0.1 % by weight on a dry mass basis

18 Total nitrogen ~ 0.1 % by weight on a dry mass basis

19 Total chlorine ~ 100 mg/kg on a dry mass basis

20 Total fluorine ~ 100 mg/kg on a dry mass basis

21 Total sulfur ~ 100 mg/kg on a dry mass basis

22 Mercury ~ 0.1 mg/kg on a dry mass basis

23 Volatile organics Various mg/kg ‘as received’ (do not dry)

24 Moisture content ~ 0.1 % by weight

25 Calorific value ~ 0.5 MJ/kg ‘as received’

26 Ash content ~ 0.1 % by weight


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Test methods

Test methods for measuring chemicals 1–16 in Table 1 require:

sample splitting and size reduction (may not be required)

sample digestion using USEPA 3051A (or an equivalent method)

analysis using USEPA 6010C (or an equivalent method)

reporting as mg/kg dry weight.

Test methods for measuring total organic carbon (no.17 in Table 1) require analysis using methods 6B2 or 6B3 in Rayment & Lyons (2011), Soil Chemical Method – Australasia (or an equivalent method).

Test methods for measuring total nitrogen (no.18 in Table 1) require analysis using semi-micro Kjeldahl method 7A2 in Rayment & Higginson (1992), Australian Laboratory Handbook of Soil and Water Chemical Methods (or an equivalent method).

Test methods for measuring total chlorine and fluorine (nos.19–20 in Table 1):

appropriate sample preparation such as Australian Standard 1038 (or an equivalent method)

analysis using a method that determines total concentrations such as Australian Standard 1038 (or an equivalent method).

Test methods for measuring total sulfur (no.21 in Table 1) require analysis using method 10A1 in Rayment & Higginson (1992), Australian Laboratory Handbook of Soil and Water Chemical Methods (or an equivalent method).

Test methods for measuring mercury (no.22 in Table 1) require:

sample pre-treatment (if required) using a separate moisture test so a calculated dry weight can be determined

cold-vapour atomic absorption spectroscopy (sample preparation and analytical method) using USEPA 7471B (or an equivalent method)

reporting as mg/kg dry weight.

Test methods for measuring volatile organics (no.23 in Table 1) require:

analysis using method 501 (Volatile Organics) in Schedule B (3): Guideline on Laboratory Analysis of Potentially Contaminated Soils, National Environment Protection (Assessment of Site Contamination) Measure 1999 (or an equivalent analytical method)

reporting as mg/kg by individual chemical or ‘limit of detection’ if not detected.

Test methods for measuring characteristics 24–26 require:

appropriate sample preparation as required by Australian Standard 1038 (or equivalent analytical method)

analysis using a method that determines moisture or ash content and gross calorific values such as Australian Standard 1038 (or equivalent method).


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Related documents

Related documents include:

NSW Energy from Waste Policy Statement

Energy Recovery Facility Guidelines.

The EPA website www.epa.nsw.gov.au will have the most recent versions of all relevant policies and guidelines.

Contacts for further advice

Waste Strategy and Innovation Section NSW Environment Protection Authority 59 Goulburn Street, Sydney NSW 2000 PO Box A290, Sydney South NSW 1232

Phone: (02) 9995 5000 Phone: 131 555 (environment information and publications requests) TTY users: phone 133 677 then ask for 131 555 Speak and listen users: phone 1300 555 727 then ask for 131 555

Fax: (02) 9995 5999

Email: [email protected]





Appendix 4

Ash from Burning Biomass Order and Exemption 2014

www.epa.nsw.gov.au 1

Resource Recovery Order under Part 9, Clause 93 of the Protection of the Environment Operations (Waste) Regulation 2014

The ash from burning biomass order 2014

Introduction This order, issued by the Environment Protection Authority (EPA) under clause 93 of the Protection of the Environment Operations (Waste) Regulation 2014 (Waste Regulation), imposes the requirements that must be met by suppliers of ash to which ‘the ash from burning biomass exemption 2014’ applies. The requirements in this order apply in relation to the supply of ash for application to land as a soil amendment.

1. Waste to which this order applies 1.1. This order applies to ash. In this order, ash means the waste generated by

burning biomass from agriculture, forestry and sawmilling residues, uncontaminated wood waste and/or organic residues from virgin paper pulp activities.

2. Persons to whom this order applies

2.1. The requirements in this order apply, as relevant, to any person who supplies ash that has been generated, processed or recovered by the person.

2.2. This order does not apply to the supply of ash to a consumer for land application at a premises for which the consumer holds a licence under the POEO Act that authorises the carrying out of the scheduled activities on the premises under clause 39 ‘waste disposal (application to land)’ or clause 40 ‘waste disposal (thermal treatment)’ of Schedule 1 of the POEO Act.

3. Duration

3.1. This order commences on 24 November 2014 and is valid until revoked by the EPA by notice published in the Government Gazette.

4. Generator requirements

The EPA imposes the following requirements on any generator who supplies ash.

Sampling requirements

4.1. On or before supplying ash, the generator must:

4.1.1. Prepare a written sampling plan which includes a description of sample preparation and storage procedures for the ash.

4.1.2. Undertake sampling and testing of the ash as required under clauses 4.2 and 4.3 below.

2 www.epa.nsw.gov.au

4.2. Where the ash is generated as part of a continuous process, the generator must undertake the following sampling:

4.2.1. Characterisation of the ash by collecting 20 composite samples of the waste and testing each sample for the chemicals and other attributes listed in Column 1 of Table 1. Each composite sample must be taken from a batch, truckload or stockpile that has not been previously sampled for the purposes of characterisation. Characterisation must be conducted for ash generated and processed during each 2-year period following the commencement of the continuous process; and

4.2.2. Routine sampling of the ash by collecting either 5 composite samples from every 1000 tonnes (or part thereof) processed or 5 composite samples every year (whichever is the lesser); and testing each sample for the chemicals and other attributes listed in Column 1 of Table 1 other than those listed as ‘not required’ in Column 3. Each composite sample must be taken from a batch, truckload or stockpile that has not been previously sampled for the purposes of routine sampling. However, if characterisation sampling occurs at the same frequency as routine sampling, any sample collected and tested for the purposes of characterisation under clause 4.2.1 may be treated as a sample collected and tested for the purposes of routine sampling under clause 4.2.2.

4.3. Where the ash is not generated as part of a continuous process, the generator must undertake one-off sampling of a batch, truckload or stockpile of the ash, by collecting 10 composite samples from every 1000 tonnes (or part thereof) processed and testing each sample for the chemicals and other attributes listed in Column 1 of Table 1. The test results for each composite sample must be validated as compliant with the maximum average concentration or other value listed in Column 2 of Table 1 and the absolute maximum concentration or other value listed in Column 4 of Table 1 prior to the supply of ash.

Chemical and other material requirements

4.4. The generator must not supply ash to any person if, in relation to any of the chemical and other attributes of the ash:

4.4.1. The concentration or other value of that attribute of any sample collected and tested as part of the characterisation or the routine or one-off sampling of the ash exceeds the absolute maximum concentration or other value listed in Column 4 of Table 1, or

4.4.2. The average concentration or other value of that attribute from the characterisation or one-off sampling of the ash (based on the arithmetic mean) exceeds the maximum average concentration or other value listed in Column 2 of Table 1, or

4.4.3. The average concentration or other value of that attribute from the routine sampling of the ash (based on the arithmetic mean) exceeds the maximum average concentration or other value listed in Column 3 of Table 1.

4.5. The absolute maximum concentration or other value of that attribute in any ash supplied under this order must not exceed the absolute maximum concentration or other value listed in Column 4 of Table 1.


Table 1

Column 1 Column 2 Column 3 Column 4

Chemicals and other attributes

Maximum average concentration for characterisation

(mg/kg ‘dry weight’ unless otherwise specified)

Maximum average concentration for

routine testing

(mg/kg ‘dry weight’ unless otherwise

specified)

Absolute maximum concentration


specified)

1. Mercury 0.5 Not required 1

2. Cadmium 0.5 0.5 1

3. Lead 50 Not required 100

4. Arsenic 10 10 20

5. Chromium (total)

50 50 100

6. Copper 50 20 100

7. Molybdenum 5 Not required 10

8. Nickel 30 30 60

9. Selenium 5 Not required 10

10. Zinc 100 100 200

11. Boron Not required Not required 60

12. Electrical Conductivity

1

NA NA NA

13. pH1 NA NA NA

1. Note that while limits are not included for electrical conductivity and pH these must be tested in each sample and records kept of results.

Test methods

4.6. The generator must ensure that any testing of samples required by this order is undertaken by analytical laboratories accredited by the National Association of Testing Authorities (NATA), or equivalent.

4.7. The generator must ensure that the chemicals and other attributes (listed in Column 1 of Table 1) in the ash it supplies are tested in accordance with the test methods specified below or other equivalent analytical methods. Where an equivalent analytical method is used the detection limit must be equal to or less than that nominated for the given method below.

4.7.1. Test method for measuring the mercury concentration: 4.7.1.1. Analysis using USEPA SW-846 Method 7471B Mercury in

solid or semisolid waste (manual cold vapour technique), or an equivalent analytical method with a detection limit < 20% of the stated maximum average concentration in Table 1, Column 2 (i.e. < 0.1 mg/kg dry weight).

4.7.1.2. Report as mg/kg dry weight.

4.7.2. Test methods for measuring chemicals 2 - 10: 4.7.2.1. Sample preparation by digesting using USEPA SW-846

Method 3051A Microwave assisted acid digestion of sediments, sludges, soils, and oils.

4.7.2.2. Analysis using USEPA SW-846 Method 6010C Inductively coupled plasma - atomic emission spectrometry, or an equivalent analytical method with a detection limit < 10%


of stated maximum concentration in Table 1, Column 2 (i.e. 1 mg/kg dry weight for lead).


4.7.3. Test methods for measuring the boron concentration: 4.7.3.1. Water soluble boron using a calcium chloride extractable

method. Rayment, G.E. and Higginson, F.R. 1992. Method 12C1 or 12C2. In Australian laboratory handbook of soil and water chemical methods, Inkata Press, Australia (or an equivalent analytical method with a detection limit for hot water soluble boron or calcium chloride extractable boron < 10% of stated total concentration).


4.7.4. Test methods for measuring the electrical conductivity and pH: 4.7.4.1. Sample preparation by mixing 1 part ash with 5 parts

distilled water. 4.7.4.2. Analysis using Method 103 (pH) and 104 (Electrical

Conductivity) in Schedule B (3): Guideline on Laboratory Analysis of Potentially Contaminated Soils, National Environment Protection (Assessment of Site Contamination) Measure 1999 (or an equivalent analytical method).

4.7.4.3. Report electrical conductivity in deciSiemens per metre (dS/m).

Notification

4.8. On or before each transaction, the generator must provide the following to each person to whom the generator supplies the ash:

• a written statement of compliance certifying that all the requirements set out in this order have been met;

• a copy of the ash from burning biomass exemption, or a link to the EPA website where the ash from burning biomass exemption can be found; and

• a copy of the ash from burning biomass order, or a link to the EPA website where the ash from burning biomass order can be found.

Record keeping and reporting

4.9. The generator must keep a written record of the following for a period of six years:

• the sampling plan required to be prepared under clause 4.1.1;

• all characterisation, routine and/or one-off sampling results in relation to the ash supplied;

• the quantity of the ash supplied; and

• the name and address of each person to whom the generator supplied the ash.

4.10. The generator must provide, on request, the most recent characterisation and sampling (whether routine or one-off or both) results for ash supplied to any consumer of the ash.

4.11. The generator must notify the EPA within seven days of becoming aware that it has not complied with any requirement in clause 4.1 to 4.7.


5. Definitions

In this order:

application or apply to land means applying to land by:

• spraying, spreading or depositing on the land; or

• ploughing, injecting or mixing into the land; or

• filling, raising, reclaiming or contouring the land.

composite sample means a sample that combines five discrete sub-samples of equal size into a single sample for the purpose of analysis.

consumer means a person who applies, or intends to apply, ash to land.

continuous process means a process that produces ash on an ongoing basis.

generator means a person who generates the ash.

transaction means:

• in the case of a one-off supply, the supply of a batch, truckload or stockpile of ash that is not repeated.

• in the case where the supplier has an arrangement with the recipient for more than one supply of ash the first supply of ash as required under the arrangement.

Manager Waste Strategy and Innovation


(by delegation)


Notes

The EPA may amend or revoke this order at any time. It is the responsibility of each of the generator and processor to ensure it complies with all relevant requirements of the most current order. The current version of this order will be available on www.epa.nsw.gov.au

In gazetting or otherwise issuing this order, the EPA is not in any way endorsing the supply or use of this substance or guaranteeing that the substance will confer benefit.

The conditions set out in this order are designed to minimise the risk of potential harm to the environment, human health or agriculture, although neither this order nor the accompanying exemption guarantee that the environment, human health or agriculture will not be harmed.

Any person or entity which supplies ash should assess whether the material is fit for the purpose the material is proposed to be used for, and whether this use may cause harm. The supplier may need to seek expert engineering or technical advice.

Regardless of any exemption or order provided by the EPA, the person who causes or permits the application of the substance to land must ensure that the action is lawful and consistent with any other legislative requirements including, if applicable, any development consent(s) for managing operations on the site(s).

The supply of ash remains subject to other relevant environmental regulations in the POEO Act and Waste Regulation. For example, a person who pollutes land (s. 142A) or water (s. 120), or causes air pollution through the emission of odours (s. 126), or does not meet the special requirements for asbestos waste (Part 7 of the Waste Regulation), regardless of this order, is guilty of an offence and subject to prosecution.

This order does not alter the requirements of any other relevant legislation that must be met in supplying this material, including for example, the need to prepare a Safety Data Sheet. Failure to comply with the conditions of this order constitutes an offence under clause 93 of the Waste Regulation.


Resource Recovery Exemption under Part 9, Clauses 91 and 92 of the Protection of the Environment Operations (Waste) Regulation 2014

The ash from burning biomass exemption 2014

Introduction

This exemption:

• is issued by the Environment Protection Authority (EPA) under clauses 91 and 92 of the Protection of the Environment Operations (Waste) Regulation 2014 (Waste Regulation); and

• exempts a consumer of ash from certain requirements under the Protection of the Environment Operations Act 1997 (POEO Act) and Waste Regulation in relation to the application of that waste to land, provided the consumer complies with the conditions of this exemption.

This exemption should be read in conjunction with ‘the ash from burning biomass order 2014’.

1. Waste to which this exemption applies

1.1. This exemption applies to ash that is, or is intended to be, applied to land as a soil amendment.

1.2. Ash means the waste generated by burning biomass from agriculture, forestry and sawmilling residues, uncontaminated wood waste and/or organic residues from virgin paper pulp activities.

2. Persons to whom this exemption applies

2.1. This exemption applies to any person who applies, or intends to apply, ash to land as set out in 1.1.

3. Duration

3.1. This exemption commences on 24 November 2014 and is valid until revoked by the EPA by notice published in the Government Gazette.

4. Premises to which this exemption applies

4.1 This exemption applies to the premises at which the consumer’s actual or intended application of ash is carried out.


5. Revocation

5.1. The ash from burning uncontaminated wood, timber, forestry residues or paper exemption 2006 and The ash from burning bagasse and cane trash exemption 2006 which commenced on 1 December 2006 are revoked from 24 November 2014.

6. Exemption

6.1. Subject to the conditions of this exemption, the EPA exempts each consumer from the following provisions of the POEO Act and the Waste Regulation in relation to the consumer’s actual or intended application of ash to land as a soil amendment at the premises:

• section 48 of the POEO Act in respect of the scheduled activities described in clauses 39 and 42 of Schedule 1 of the POEO Act;

• Part 4 of the Waste Regulation;

• section 88 of the POEO Act; and

• clause 109, 110 and 114 of the Waste Regulation.

6.2. The exemption does not apply in circumstances where ash is received at the premises for which the consumer holds a licence under the POEO Act that authorises the carrying out of the scheduled activities on the premises under clause 39 ‘waste disposal (application to land)’ or clause 40 ‘waste disposal (thermal treatment)’ of Schedule 1 of the POEO Act.

7. Conditions of exemption

The exemption is subject to the following conditions:

7.1. At the time the ash is received at the premises, the material must meet all chemical and other material requirements for ash which are required on or before the supply of ash under ‘the ash from burning biomass order 2014’.

7.2. The ash can only be applied to land as a soil amendment.

7.3. The application rate must be equal to or less than the agronomic rate for the most limiting factor.

7.4. The consumer must incorporate the ash into the topsoil.

7.5. The consumer must keep a written record of the following for a period of six years:

• the quantity of any ash received; and

• the name and address of the supplier of the ash received.

7.6. The consumer must make any records required to be kept under this exemption available to authorised officers of the EPA on request.

7.7. The consumer must apply ash to land within a reasonable period of time after its receipt.

8. Definitions

In this exemption:

application to land means applying to land by:





consumer means a person who applies, or intends to apply, ash to land.



(by delegation)


Notes

The EPA may amend or revoke this exemption at any time. It is the responsibility of the consumer to ensure they comply with all relevant requirements of the most current exemption. The current version of this exemption will be available on www.epa.nsw.gov.au

In gazetting this exemption, the EPA is not in any way endorsing the use of this substance or guaranteeing that the substance will confer benefit.

The conditions set out in this exemption are designed to minimise the risk of potential harm to the environment, human health or agriculture, although neither this exemption nor the accompanying order guarantee that the environment, human health or agriculture will not be harmed.

The consumer should assess whether or not the ash is fit for the purpose the material is proposed to be used for, and whether this use will cause harm. The consumer may need to seek expert engineering or technical advice.

Regardless of any exemption provided by the EPA, the person who causes or permits the application of the substance to land must ensure that the action is lawful and consistent with any other legislative requirements including, if applicable, any development consent(s) for managing operations on the site.

The receipt of ash remains subject to other relevant environmental regulations in the POEO Act and Waste Regulation. For example, a person who pollutes land (s. 142A) or water (s. 120), or causes air pollution through the emission of odours (s. 126), or does not meet the special requirements for asbestos waste (Part 7 of the Waste Regulation), regardless of having an exemption, is guilty of an offence and subject to prosecution.

This exemption does not alter the requirements of any other relevant legislation that must be met in utilising this material, including for example, the need to prepare a Safety Data Sheet (SDS).

Failure to comply with the conditions of this exemption constitutes an offence under clause 91 of the Waste Regulation.

Appendix 5

Ash from Coal Ash Order and Exemption 2014


Resource Recovery Order under Part 9, Clause 93 of the Protection of the Environment Operations (Waste) Regulation 2014

The coal ash order 2014

Introduction This order, issued by the Environment Protection Authority (EPA) under clause 93 of the Protection of the Environment Operations (Waste) Regulation 2014 (Waste Regulation), imposes the requirements that must be met by suppliers of coal ash and blended coal ash to which ‘the coal ash exemption 2014’ applies. The requirements in this order apply in relation to the supply of coal ash and blended coal ash for application to land in line with the uses described in ‘the coal ash exemption 2014’.

1. Waste to which this order applies

1.1. This order applies to coal ash and coal ash blended with other materials (blended coal ash). In this order, coal ash means coal combustion products (CCPs), fly ash or furnace bottom ash from burning Australian black coal. This does not include brine conditioned or treated ash.

2. Persons to whom this order applies

2.1. The requirements in this order apply, as relevant, to any person who supplies coal ash or blended coal ash that has been generated, processed or recovered by the person.

2.2. This order does not apply to the supply of coal ash or blended coal ash to a consumer for land application at a premises for which the consumer holds a licence under the POEO Act that authorises the carrying out of the scheduled activities on the premises under clause 39 ‘waste disposal (application to land)’ or clause 40 ‘waste disposal (thermal treatment)’ of Schedule 1 of the POEO Act.

3. Duration

3.1. This order commences on 24 November 2014 and is valid until revoked by the EPA by notice published in the Government Gazette.

4. Generator requirements

The EPA imposes the following requirements on any generator who supplies coal ash.

Sampling requirements

4.1. On or before supplying coal ash, the generator must:


4.1.1. Prepare a written sampling plan which includes a description of sample preparation and storage procedures for the coal ash.

4.1.2. Undertake sampling and testing of the coal ash as required under clauses 4.2 and 4.3 below. The sampling must be carried out in accordance with the written sampling plan and Australian Standard 1141.3.1-2012 Methods for sampling and testing aggregates – Sampling – Aggregates (or equivalent).

4.2. Where coal ash is generated for land application as a soil amendment for the growing of vegetation the generator must undertake the following sampling and analysis:

4.2.1. Where <1000 tonnes of coal ash is generated per year, the coal ash must be sampled by taking 3 composite samples per year. Each sample must be tested for analytes 5 and 12 in Table 1 according to test method 4.8.4 and 4.8.3.

4.2.2. Where >1000 tonnes of coal ash is generated per year, the coal ash must be sampled by taking 3 composite samples per year and an additional 1 composite sample for every 1000 tonnes or part thereof generated. Each sample must be tested for analytes 5 and 12 in Table 1 according to test method 4.8.4 and 4.8.3.

4.3. Where the coal ash is generated for use as an engineering material and is generated as part of a continuous process, the generator must undertake the following sampling:

4.3.1. Characterisation of the coal ash by collecting 20 composite samples of the waste and testing each sample for the chemicals and other attributes listed in Column 1 of Table 1. Each composite sample must be taken from a batch, truckload or stockpile that has not been previously sampled for the purposes of characterisation. Characterisation must be conducted for coal ash generated and processed during each 2-year period following the commencement of the continuous process; and

4.3.2. Routine sampling of the coal ash by collecting either 5 composite samples from every 10,000 tonnes (or part thereof) processed or 5 composite samples every 3 months (whichever is the lesser); and testing each sample for the chemicals and other attributes listed in Column 1 of Table 1 other than those listed as ‘not required’ in Column 3. Each composite sample must be taken from a batch, truckload or stockpile that has not been previously sampled for the purposes of routine sampling. However, if characterisation sampling occurs at the same frequency as routine sampling, any sample collected and tested for the purposes of characterisation under clause 4.3.1 may be treated as a sample collected and tested for the purposes of routine sampling under clause 4.3.2.

4.4. Where the coal ash is generated for use as an engineering material and is not generated as part of a continuous process, the generator must undertake one-off sampling of a batch, truckload or stockpile of the coal ash, by collecting and testing 10 composite samples from every 4,000 tonnes (or part thereof) generated and testing each sample for the chemicals and other attributes listed in Column 1 of Table 1.

Chemical and other material requirements

4.5. The generator must not supply coal ash to any person if, in relation to any of the chemical and other attributes of the coal ash:


4.5.1. The concentration or other value of that attribute of any sample collected and tested as part of the characterisation or the routine or one-off sampling of the coal ash exceeds the absolute maximum concentration or other value listed in Column 4 of Table 1, or

4.5.2. The average concentration or other value of that attribute from the characterisation or one-off sampling of the coal ash (based on the arithmetic mean) exceeds the maximum average concentration or other value listed in Column 2 of Table 1, or

4.5.3. The average concentration or other value of that attribute from the routine sampling of the coal ash (based on the arithmetic mean) exceeds the maximum average concentration or other value listed in Column 3 of Table 1.

4.6. The absolute maximum concentration or other value of that attribute in any coal ash supplied under this order must not exceed the absolute maximum concentration or other value listed in Column 4 of Table 1.

Table 1

Column 1 Column 2 Column 3 Column 4

Chemicals and other attributes

Maximum average concentration for characterisation


specified)

Maximum average concentration for

routine testing


specified)

Absolute maximum concentration

(mg/kg ‘dry weight’ unless otherwise specified)

1. Mercury 0.5 Not required 1

2. Cadmium 0.5 0.5 1

3. Lead 25 25 50

4. Arsenic 10 Not required 20

5. Boron 75 Not required 150 for engineering uses

60 for soil amendment

6. Chromium (total)

25 25 50

7. Copper 20 Not required 40

8. Molybdenum 10 Not required 20

9. Nickel 25 25 50

10. Selenium 10 10 20

11. Zinc 35 35 70

12. Electrical Conductivity

1 NA NA NA for engineering uses

4dS/m for soil amendment

13. pH* in non-cementitious mixes

2 7 to 12.5 7 to 12.5 6 to 13

14. pH in cementitious mixes

NA NA NA

1Note: while thresholds are not provided for electrical conductivity this must be tested and a record kept of the results. 2Note: The ranges given for pH are for the minimum and maximum acceptable pH values in the coal ash.


Test methods

4.7. The generator must ensure that any testing of samples required by this order is undertaken by analytical laboratories accredited by the National Association of Testing Authorities (NATA), or equivalent.

4.8. The generator must ensure that the chemicals and other attributes (listed in Column 1 of Table 1) in the coal ash it supplies are tested in accordance with the test methods specified below or other equivalent analytical methods. Where an equivalent analytical method is used the detection limit must be equal to or less than that nominated for the given method below.

4.8.1. Test method for measuring the mercury concentration: 4.8.1.1 Analysis using USEPA SW-846 Method 7471B Mercury in

solid or semisolid waste (manual cold vapour technique), or an equivalent analytical method with a detection limit < 20% of the stated maximum average concentration in Table 1, Column 2 (i.e. < 0.1 mg/kg dry weight).

4.8.1.2 Report as mg/kg dry weight.

4.8.2. Test methods for measuring chemicals 2 - 11: 4.8.2.1 Sample preparation by digesting using USEPA SW-846

Method 3051A Microwave assisted acid digestion of sediments, sludges, soils, and oils.

4.8.2.2 Analysis using USEPA SW-846 Method 6010C Inductively coupled plasma - atomic emission spectrometry, or an equivalent analytical method with a detection limit < 10% of stated maximum average concentration in Table 1, Column 2 (i.e. 2.5 mg/kg dry weight for lead).


4.8.3. Test methods for measuring the electrical conductivity and pH: 4.8.3.1 Sample preparation by mixing 1 part coal ash with 5 parts

distilled water. 4.8.3.2 Analysis using Method 103 (pH) and 104 (Electrical

Conductivity) in Schedule B (3): Guideline on Laboratory Analysis of Potentially Contaminated Soils, National Environment Protection (Assessment of Site Contamination) Measure 1999 (or an equivalent analytical method).

4.8.3.3 Report electrical conductivity in deciSiemens per metre (dS/m).

4.8.4. Test method for measuring boron in coal ash for land application as a soil amendment: 4.8.4.1 Water soluble boron using a calcium chloride extractable

method 12C1 or 12C2 in Rayment, G.E. and Lyons D.J. 2011 Soil Chemical Methods - Australasia, CSIRO Publishing (or an equivalent analytical method with a detection limit for water soluble boron <10% of the stated absolute maximum).



Notification

4.9. On or before each transaction, the generator must provide the following to each person to whom the generator supplies the coal ash:


• a copy of the coal ash exemption, or a link to the EPA website where the coal ash exemption can be found; and

• a copy of the coal ash order, or a link to the EPA website where the coal ash order can be found.


4.10. The generator must keep a written record of the following for a period of six years:

• the sampling plan required to be prepared under clause 4.1.1;

• all characterisation, routine and/or one-off sampling results in relation to the coal ash supplied;

• the quantity of the coal ash supplied; and

• the name and address of each person to whom the generator supplied coal ash.

4.11. The generator must provide, on request, the most recent characterisation and sampling (whether routine or one-off or both) results for coal ash supplied to any processor or consumer of the coal ash.

4.12. The generator must notify the EPA within seven days of becoming aware that it has not complied with any requirement in clause 4.1 to 4.8.

5. Processor requirements

The EPA imposes the following requirements on any processor who supplies blended coal ash.

5.1. The processor may blend the coal ash with materials that are the subject of a Resource Recovery Exemption and Resource Recovery Order if that material complies with all of the chemical and other material requirements under its Resource Recovery Order, and is able to be applied to land under its Resource Recovery Exemption for the following purpose(s) described in clauses 5.2.1 to 5.2.3.

5.1.1. as a soil amendment for the growing of vegetation;

5.1.2. in cementitious mixes such as concrete; and

5.1.3. in non-cementitious mixes such as an engineered fill in earthworks or for roadmaking activities as follows:

(a) pipe bedding material,

(b) selected backfill adjacent to structures,

(c) road pavement, base and sub-base structures,

(d) composite filler in asphalt pavements,

(e) rigid and composite pavement structures,

(f) select layers which act as working platforms at the top of earthworks,

(g) fill for reinforced soil structures (including geo-grid applications).


5.2. Where the pH of the coal ash received is below 6 and it is intended to be supplied for use in non-cementitious mixes, the processor must undertake the following before supplying the coal ash to a consumer for use as in 5.1.3:

5.2.1. blend the coal ash at a rate of 20% or less with lime, natural quarried rock, coal washery rejects, recovered railway ballast, crushed concrete, blast furnace slag, steel furnace slag and/or electric arc furnace slag; and

5.2.2. sample the mix by taking the same number of samples as required to be taken under clause 4.3 or 4.4 and testing the pH of those samples. The test results for each composite sample must be validated as compliant with the requirements listed in row 13 of Table 1.

Notification

5.3. On or before each transaction, the processor must provide the following to each person to whom the processor supplies the blended coal ash:


• a copy of the coal ash exemption, or a link to the EPA website where the coal ash exemption can be found; and

• a copy of the coal ash order, or a link to the EPA website where the coal ash order can be found.


5.4. The processor must keep a written record of the following for a period of six years:

• the quantity of any coal ash received from the generator and the generator’s name and address;

• the quantity of any blended coal ash supplied; and

• the name and address of each person to whom the processor supplied the blended coal ash.

5.5. The processor must provide, on request, the most recent characterisation and sampling (whether routine or one-off or both) results for coal ash that it received from the generator.

6. Definitions

In this order:

brine conditioned ash means coal ash that has been conditioned or treated with brine concentrator waste from process water treatment.

application or apply to land means applying to land by:




blast furnace slag means material that meets the chemical and other material requirements for blast furnace slag which are required on or before supply of blast furnace slag under ‘The blast furnace slag order 2014’

cementitious mixes means either coal ash or blended coal ash which has been mixed with general purpose cement, lime and other activators for use in bound applications, where the materials must be chemically bound together.


composite sample means a sample that combines five discrete sub-samples of equal size into a single sample for the purpose of analysis.

consumer means a person who applies, or intends to apply, coal ash or blended coal ash to land.

continuous process means a process that produces coal ash on an ongoing basis.

crushed concrete means waste concrete that has been processed into an engineered material, and meets the conditions of a resource recovery exemption.

electric arc furnace slag means material that meets the chemical and other material requirements for electric arc furnace slag which are required on or before supply of electric arc furnace slag under ‘The electric arc furnace slag order 2014’

non-cementitious mixes means either coal ash or blended coal ash that is not mixed with general purpose cement, lime and other activators or used in bound applications. non-processing supplier means a person who supplies, causes, or permits the supply of cementitious mixes to a consume and who does not undertake any processing of coal ash.

processor means a person who processes, mixes, blends, or otherwise incorporates coal ash into blended coal ash for supply to a consumer.

steel furnace slag means material that meets the chemical and other material requirements for steel furnace slag which are required on or before supply of steel furnace slag under ‘The steel furnace slag order 2014’

transaction means:

• in the case of a one-off supply, the supply of a batch, truckload or stockpile of coal ash that is not repeated.

• in the case where the supplier has an arrangement with the recipient for more than one supply of coal ash the first supply of coal ash as required under the arrangement.



(by delegation)


Notes

The EPA may amend or revoke this order at any time. It is the responsibility of each of the generator and processor and to ensure it complies with all relevant requirements of the most current order. The current version of this order will be available on www.epa.nsw.gov.au

In gazetting or otherwise issuing this order, the EPA is not in any way endorsing the supply or use of this substance or guaranteeing that the substance will confer benefit.

The conditions set out in this order are designed to minimise the risk of potential harm to the environment, human health or agriculture, although neither this order nor the accompanying exemption guarantee that the environment, human health or agriculture will not be harmed.

Any person or entity which supplies coal ash should assess whether the material is fit for the purpose the material is proposed to be used for, and whether this use may cause harm. The supplier may need to seek expert engineering or technical advice.

Regardless of any exemption or order provided by the EPA, the person who causes or permits the application of the substance to land must ensure that the action is lawful and consistent with any other legislative requirements including, if applicable, any development consent(s) for managing operations on the site(s).

The supply of coal ash remains subject to other relevant environmental regulations in the POEO Act and Waste Regulation. For example, a person who pollutes land (s. 142A) or water (s. 120), or causes air pollution through the emission of odours (s. 126), or does not meet the special requirements for asbestos waste (Part 7 of the Waste Regulation), regardless of this order, is guilty of an offence and subject to prosecution.

This order does not alter the requirements of any other relevant legislation that must be met in supplying this material, including for example, the need to prepare a Safety Data Sheet. Failure to comply with the conditions of this order constitutes an offence under clause 93 of the Waste Regulation.


Resource Recovery Exemption under Part 9, Clauses 91 and 92 of the Protection of the Environment Operations (Waste) Regulation 2014

The coal ash exemption 2014

Introduction

This exemption:

• is issued by the Environment Protection Authority (EPA) under clauses 91 and 92 of the Protection of the Environment Operations (Waste) Regulation 2014 (Waste Regulation); and

• exempts a consumer of coal ash or blended coal ash from certain requirements under the Protection of the Environment Operations Act 1997 (POEO Act) and Waste Regulation in relation to the application of that waste to land, provided the consumer complies with the conditions of this exemption.

This exemption should be read in conjunction with ‘the coal ash order 2014’.

1. Waste to which this exemption applies

1.1. This exemption applies to coal ash and coal ash blended with other materials (blended coal ash) that is, or is intended to be, applied to land as an engineering material.

1.2. Coal ash means coal combustion products (CCPs), fly ash or furnace bottom ash from burning Australian black coal. This does not include brine conditioned or treated ash.

2. Persons to whom this exemption applies

2.1. This exemption applies to any person who applies, or intends to apply, coal ash or blended coal ash to land as set out in 1.1.

3. Duration

3.1. This exemption commences on 24 November 2014 and is valid until revoked by the EPA by notice published in the Government Gazette.

4. Premises to which this exemption applies

4.1 This exemption applies to the premises at which the consumer’s actual or intended application of coal ash or blended coal ash is carried out.


5. Revocation

5.1. The coal ash exemption 2013 which commenced on 18 April 2013 and the fly ash and bottom ash from burning NSW or Queensland coal exemption 2006 which commenced on 1 December 2006 are revoked from 24 November 2014.

6. Exemption

6.1. Subject to the conditions of this exemption, the EPA exempts each consumer from the following provisions of the POEO Act and the Waste Regulation in relation to the consumer’s actual or intended application of coal ash or blended coal ash to land as an engineering material at the premises:

• section 48 of the POEO Act in respect of the scheduled activities described in clauses 39 and 42 of Schedule 1 of the POEO Act;

• Part 4 of the Waste Regulation;

• section 88 of the POEO Act; and

• clause 109, 110 and 114 of the Waste Regulation

6.2. The exemption does not apply in circumstances where coal ash or blended coal ash is received at the premises for which the consumer holds a licence under the POEO Act that authorises the carrying out of the scheduled activities on the premises under clause 39 ‘waste disposal (application to land)’ or clause 40 ‘waste disposal (thermal treatment)’ of Schedule 1 of the POEO Act.

7. Conditions of exemption

The exemption is subject to the following conditions:

7.1. At the time the coal ash or blended coal ash is received at the premises, the material must meet all chemical and other material requirements for coal ash or blended coal ash which are required on or before the supply of coal ash or blended coal ash under ‘the coal ash order 2014’.

7.2. Coal ash and blended coal ash can only be applied to land:

7.2.1. as a soil amendment for the growing of vegetation,

7.2.2. in cementitious mixes such as concrete, and

7.2.3. in non-cementitious mixes such as an engineered fill, stabiliser, filter or drainage material or as a sand substitute as follows:

(a) pipe bedding material,

(b) selected backfill adjacent to structures,

(c) road pavement, base and sub-base structures,

(d) composite filler in asphalt pavements,

(e) rigid and composite pavement structures,

(f) select layers which act as working platforms at the top of earthworks,

(g) fill for reinforced soil structures (including geo-grid applications).

7.3. In cementitious mixes, the consumer can only apply coal ash or blended coal ash to land where it complies with a relevant specification or Australian Standard or supply agreement.

7.4. In non-cementitious mixes the consumer can only apply coal ash or blended coal ash to land where it:


7.4.1. complies with the relevant specification or Australian Standard or complies with supply agreement/s, or

7.4.2. complies with a development consent that specifically considers the use of coal ash, and

7.4.3. is not applied in or beneath water including groundwater.

7.5. The consumer must keep a written record of the following for a period of six years:

• the quantity of any coal ash and blended coal ash received; and

• the name and address of the supplier of the coal ash and blended coal ash received.

7.6. The consumer must make any records required to be kept under this exemption available to authorised officers of the EPA on request.

7.7. The consumer must apply coal ash to land within a reasonable period of time after its receipt.

8. Definitions

In this exemption:

application to land means applying to land by:




cementitious mixes means either coal ash or blended coal ash which has been mixed with general purpose cement, lime and other activators for use in bound applications, where the materials must be chemically bound together.

consumer means a person who applies, or intends to apply, coal ash or blended coal ash to land.

non-cementitious mixes means either blended coal ash or coal ash that is not blended with general purpose cement, lime and other activators or used in bound applications. non-cementitious mixes means either coal ash or blended coal ash that is not mixed with general purpose cement, lime and other activators or used in bound applications.



(by delegation)


Notes

The EPA may amend or revoke this exemption at any time. It is the responsibility of the consumer to ensure they comply with all relevant requirements of the most current exemption. The current version of this exemption will be available on www.epa.nsw.gov.au

In gazetting this exemption, the EPA is not in any way endorsing the use of this substance or guaranteeing that the substance will confer benefit.

The conditions set out in this exemption are designed to minimise the risk of potential harm to the environment, human health or agriculture, although neither this exemption nor the accompanying order guarantee that the environment, human health or agriculture will not be harmed.

The consumer should assess whether or not the coal ash is fit for the purpose the material is proposed to be used for, and whether this use will cause harm. The consumer may need to seek expert engineering or technical advice.

Regardless of any exemption provided by the EPA, the person who causes or permits the application of the substance to land must ensure that the action is lawful and consistent with any other legislative requirements including, if applicable, any development consent(s) for managing operations on the site.

The receipt of coal ash remains subject to other relevant environmental regulations in the POEO Act and Waste Regulation. For example, a person who pollutes land (s. 142A) or water (s. 120), or causes air pollution through the emission of odours (s. 126), or does not meet the special requirements for asbestos waste (Part 7 of the Waste Regulation), regardless of having an exemption, is guilty of an offence and subject to prosecution.

This exemption does not alter the requirements of any other relevant legislation that must be met in utilising this material, including for example, the need to prepare a Safety Data Sheet (SDS).

Failure to comply with the conditions of this exemption constitutes an offence under clause 91 of the Waste Regulation.

Redbank Power Station QA/QC, Supply Chain and Material ...

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