An Inconvenient Truth – regulatory response ash to waste

An inconvenient distraction: A vexatious type can make it difficult for success and a friend points out ‘a difficulty’ and you find yourself in a position of lampoon. The issue is should what you report be directed or controlled. To illustrate we published, 13 December 2014, “Maybe the question is better put this way: Plants don’t need carbon, soils do. Biochar is but a hazardous waste from pyrolysis”. This was not a position statement; it was outlining a problem of perception promoted by deniers that you should think of it as an ash.

On 13 December 2014 we also wrote – “The quandary for most of us when we express our thoughts is we can be regarded as excessive or obsessive for seeking out an agenda”. In this story CO2Land org had an agenda – to make one aware. To be aware that moves were afoot overseas to have ash declared ‘waste’. The below the radar application if you want to make more of it.

What is difficult to accept is that the catalyst for this change was the coal fired power stations in the USA. The story unfolds as:

On 22 December 2014, http://www.wastedrive.com published that – Feds: Coal ash classified as solid waste – by Nicole Wrona. This followed a story published by Dina Cappiello The Associated Press on 20 December 2014 through the Casper Star Tribune. Outlining: “The Obama administration on Friday set the first national standards for waste generated from coal burned for electricity, treating it more like household garbage rather than a hazardous material.”

To directly quote wastedrive.com – on the affects of the new regulations:

Dive Brief:

  • New federal standards will categorize coal ash as a solid waste instead of considering it a hazardous material.
  • The classification was determined despite pushback from environmentalists. The regulations do not extend to shuttered power plants, but would apply to closed ash ponds where utilities are active.
  • States will continue to ensure standards surrounding the waste are followed. The federal government would have taken over enforcement had the decision turned out differently or if the waste had been dubbed “hazardous.”

Dive Insight:

  • The Environmental Protection Agency (EPA) said it would protect citizens from the risks associated with coal ash waste sites while pledging to hold corporations who operated ash waste sites accountable. The rules are expected to increase leak monitoring, control blowing dust, and to require companies to publicly release test results.
  • Waste Management had predicted a substantial amount of growth for the company if the rule were to be approved. The ash waste stream is larger than the waste stream currently handled by the company.

Recommended Reading:

Now back in Australia the Carbon Farming Initiative is sympathetic to bio char from pyrolysis. The difficulty is the regulations that are responded to by the EPA of each state. The question now is will this USA EPA ruling be followed in Australia? Will bio char too be cleared of any stigma of a perception either implied or express that it is an ash – should be leave this to experts?

It is not that simple. As we said previously what is needed to be truly progressive is the commitment to investigate the potential. Do we need a senate inquiry to get that moving? We see some wonderful benefits where multiple products could be extracted from just a simple classification change being the catalyst.

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Fit for Purpose – assumptions in MSW and WtE

End to end solution for treating Metropolitan Sewage and Waste (MSW) is a hot topic, and very much in the fore of forums for 2013. So enthusiastic are the players it is very difficult to differentiate the fact from the ideals. Look and you will see a lot of justification and more than adequate presentation of the material. What is more difficult is to get a clear indication of the capability and improvements over current practices.

The culprit may be assumptions, and they are widely used under management scenarios. If we define assumptions as a statement that is assumed to be true and from which a conclusion can be drawn. It might even be that as we rely more on big data an omission from the assumption can lead us to ignore the obvious. Take this example statement – Our machine can undercut all other in terms of power costs. Then if we find published a number of a competitors, but necessarily the same technology, we can quote that number and assume ours as similar or superior. Yet, as was said it is not the same technology.

Recently a post was read and it said in the US, under US Average Levelized Cost for Plants in the Annual Energy Outlook 2009 and 2010 and 2011, a typical generator running on Biomass has net requirement for a price of 11 c kWh to break even. Then came an assumption from the author that as these tables have no values for Advanced Plasma Conversion it is assumed a value of  $0.044/kwh is the value that you add for comparison. The difficulty is the published number for biomass is taken from experience and certain modeling under a list of data sources. The advanced plasma conversion unit was then part of a hypothetical assessment according to mathematical values that commence with an assumption, and will be correct until proven wrong. The fatal flaw in this is that facts are with the biomass and its testing included load scenarios and importantly it has a generator (that thing that produces electromotive force – electricity) attached. What is obscure is whether the Advanced Plasma Conversion unit is connected to a generator, or whether it needs one. For an investor this is a matter of concern, and for a professional in the industry it says embarrassing!

Another major issue is the maturity of the solutions put forward for you to make a project decision.  At program level you can take liberties and shuffle as you need to, at a project level on time and on budget can be you nemesis if you make the wrong assumptions – as said earlier – assumptions are a management scenario. CO2Land org assumes four scenarios are possible for waste handling solutions. It can be put forward to consider: Business as Usual, Gasification, and Pyrolysis, Plasma conversion.

  1. Business as usual (BAU) is an option fast running out, and in areas of rapid urbanization and rapid growing economies the time has already arrived that it cannot continue, not just because of the carbon issues but because it is an economic cost. This does not discount the importance of carbon, but indicated that developing countries needs the resource recovery as much as it is in need to develop.
  2. Gasification is an effective incineration tool, and innovations are proving to be effective in optimizing syngas recovery and returning additional products from the process for agriculture and raw material recovery.
  3. Pyrolysis is also an incineration tool, albeit at higher temperatures with the added benefit of being able to produce syncrude and chars to order. The process needs to be well managed to avoid the possibility of producing dioxins.
  4. Plasma conversion has been around for some years and has chequed history as an incineration method. Two particular issues have dogged the traditional designs. High and constant power requirement, and not being able to control temperature and ionizing across the plasma bed. Considerable claims are being made of advances in the technology. Confidence is continuing to grow on the refinement of the equipment and a number of sites across the world are being implemented.

The Cost benefit of each scenario indicates:

  • Point one is clear – the high cost of resource recovery weighs heavily when the budget is restricted for an authority and they would promote BAU until an incentive was put forward.
  • Point two and three are relevant and in more recent times the marrying of the two according to need is seeing this technology develop into a useful cost effective solution and should be the method of choice in most instances for the next 7 to 8 years.  By this it is meant it is the best technology to implement for most scenarios now and into the future in that time frame and it useful life for many more.  It also has an advantage of being complimentary to most commercial activities, and the ability to be scalable as required.  The strong point potential is to return a number of waste materials, especially plastics to virgin materials.
  • Point four will be the technology of the future; it has the potential (ideal) and the hopeful expect an almost unending product potential from this technology. The next generation is expected to be approved and producible in around 5 years. The scale of the projects required to cover the capital costs is the biggest limiting factor for future projects.

In more detail is this information the current Waste to Energy scenario suggests the difficulty is with the techno-commercial format. That comparing apples with apples may not be possible. An example is given by 
William G. Acker (http://www.ackerandassociates.com) where he looked for Advanced Plasma Conversion tables in the U.S. Annual Energy Outlook 2009 and 2010 and 2011. In these tables there are no values for Advanced Plasma Conversion. So he then said he must assume that what was claimed by another company representative was a value added to the values. He himself then assessed the closest estimate to which the technology is closest to be the figure for Biomass. This is not his definitive position, all he asks is someone to provide a value to share that is more accurate. However, in the mean time we make the assumption it must be correct until refuted

Then CO2Land org decides to ask a question in a forum on Waste to Energy (WtE): “Excuse the confusion, a lot of justification and adequate presentation of the material is provided. What is not clear is the capability from the production of an energy source to the actual electromagnetic force. In other words: what are the source, type and cost of the generator machine? Or, is your Plasma machine also a generator of electrical power in its own right without the need for other equipment?  The response: Good question!  The discussion then centres on whether matters were assumed or simply relayed on what was actually said on the capacity and nothing more.  Being that capability was not addressed is not the domain of the engineers for not giving you correct info, or how confidential agreement might stop you providing information. It may well be a simple case of the enquirers having no idea on what to ask. They do not ask because it was not obvious or lost in techno-commercial format of the communications.

In the quest for comparing apples to apples, and ignoring that baseline quotes may be flawed. To compare the possible in WtE from our view (to which we will assume you will be at odd. Information supplied illustrated:

A hearth gasifier with a reciprocating low Btu engine and conventional generator can be leased in Australia with an operating cost of 8.2cents per kilowatt-hours, with a 25,000 hours maintenance requirement. These costs are worked assuming a 1MW net unit and economies of scale suggest lower costs for larger units. If I combine the capability of the unit with a pyrolysis retort and produce syncrude and biochar, the offset pricing suggest a decrease in generation capacity will result, but the operating costs will settle at around 5 cents a kWh. The number will vary according to the feedstock quality.

Very recently an indicative quote that asked for capacity to handle MSW with1750 kcal as feedstock and input 300 tonnes per day for using advanced plasma conversion. What would be the project cost? The answer came back in the order of  $6.5m plus the cost of shredder activity and generator sets required – that is the cost to add capability is not in the cost mix.  The difficulty now is the assumption that must be made in the numbers.

In another example of a project where the project is not only proposed, is financed (and currently on hold to commence), is again supplied by William G Acker, of the MSW Plasma Gasification Facility for St. Lucie, Florida. This facility would use 686 ton per day of MSW and would produce 22 MW Gross and 18 MW Net of electricity. The installed cost came to $190,000,000. Amortized the project over 30 years with the Levelized Capital Cost alone (no maintenance cost, no labor cost etc.) comes to $0.0922 per kWh. If we add labor and maintenance costs the total may be ‘assumed’ to be around $0.14 per kWh. Then we must consider the money made for taking the waste off the hands of communities, or business that are paying to, landfill it we then could subtract around $0.03 per kWh from the operating cost resulting in $0.11 per kWh.

This results in CO2Land org asking: Will the actual plasma price to generate electricity please stand!  So we know without assumption forming the core costing criteria a project cost is capable of producing electricity for approximately 11 Cents per kWh, and the example hearth gasifier somewhere from 4.4 to 11 cents per kWh. Albeit other examples might swing wildly towards higher costs depending on the operating and technology vintage.  That said there is no doubt that given time and R&D plasma conversion in whatever form will be the way forward. In other examples plasma systems are doing OK for the job required, but academia and those in the industry say it is some way off being perfected and as efficient as it should be.

If we go back to the influence of assumptions the problem for the industry is that laboratory results and mathematical equations don’t often become reality, as not everything is scalable. In the mean time it is “danger danger, Will Robertson” as borrowed from ‘lost in space’ which was entertaining series a little while back. We also need to be fully aware of the smoke and mirrors approach that do a wonderful job with customers who are not normally that knowledgeable.

Another factor of our times is that despite each supplier wanting to win each job, they are fighting for funds within an economy where funds requiring $50M or more are highly competitive. In these instances those projects where the technology is still to be proven it will take second place to those known to do the job.

Evidence of uncertainty in the accuracy of a useful lifecycle may lead you to consider that you might want to lease the plant, it could be a lower risk in these times. The more popular in these circumstances are suggested as those that offer an operational lease rather than a financial risk.

We trust that has covered off on the choices – if you feel too much assumption is made or if you know better – please show yourself!

Closing 21 Feb – excluded

Closing 21 Feb 2013, Community Renewable Energy Projects: Message  – Innovations excluded and technology chosen must be commercial. This is despite many innovators being able to prove an environmental benefit at least cost.  It is not a new issue it is a matter that is a symptom of measures providing a pathway regardless of the evidence. Albeit, justification for this approach can be found by some oblique reference to some far away story.

As the Lawrence Berkeley National Laboratory explains “One of the most serious (and valid) criticisms of subsidies for “renewable” energy is that they heighten the perception (but not the reality) that wind and solar are less expensive and more energy efficient than conventional fuels”.

If we single out the NSW Renewable Energy Precincts Program and the expression of interest for funding the wording says “EOIs will only be accepted for projects proposing to use renewable energy technologies that are commercially available and have been demonstrated in operation at a similar scale generation capacity for 12 months or more. Solar photovoltaic technology and wind are the two most common, and commercially available, renewable energy technologies. Most CRE projects internationally use one of these two technologies”. This is interesting as world wide, and in Australia, there are technologies that offer a better power capacity ratio. It is also interesting that in Australia at least one public entity has taken legal action to restrict (Suppression) the opportunity for a commercial opportunity with alternative renewable energy. When the reference is made to power capacity ratio it simply means – coal fired can be replaced by this technology as base load. It should also be said at a lower cost than wind and solar. AKA – cost benefit is superior.

It is difficult to understand why a ‘community’ program is directing a bias in this way towards wind & solar. CO2Land org feels this is a shame because more than a few communities would be able to scratch together sufficient green waste and other biomass resources to run a genuine base load or peak lopping plant, from what is waste with the added advantage of also having very useful co-products and creating more permanent local employment.

It follows that local government have obligations for services and various industry is within the boundaries they manage. Industry does two things: 1) They tend to consume more of the fuel resources available in the geographical area, and 2) Produce waste that is often toxic or hazardous in the environment.

In a growing trend around the world (being a reference was made in the NSW REP EOI), and since 1980, as far as CO2Land org can see, major industry is increasingly looking at methods for recovering the fuel value from many wastes.

CO2Land org can identify some of the different methods to do so and each is superior in their own way, and certainly make use of existing problems of waste and remove much of the need for virgin material in the products they offer. The point is made – not one product such as electricity generation of wind and solar, but also other products that make up the needs of society.

To give examples: Gasification, Pyrolysis, Plasma conversion are increasingly being piloted or in production in other parts of the world. Not surprising is that many of the leading work was from Australia, then ‘discovered’ by America, India, China and other countries determined to solve their resource and waste problems. If you were to argue it is cost that is the problem. As a single product produced wind and solar can argue they the high ground. “But consider this case of cement kilns converting waste: The ash in waste fuels becomes part of the cement product in a cement kiln, this system is one of the very few that actually consumes all of the waste material – both organic and inorganic turning all of the waste into product – no ash, no change in emissions and no impact on product quality”. Patent Number 8268073 System and method for making cement and cement derived therefrom

Inventors: Burton J. Kunik, James C. Berns, David G. Gossman

More recently, engineered fuels (Synfuels) are carrying on to advance the latest step in the process that started over 30 years ago. Some might even recall or have read that in World War 2 years the need to ‘invent’ devices to get the family car around as fuel was rationed. The new advances present the real potential for using a wider variety of waste materials, including treated medical wastes, to consume waste materials instead of coal and other natural resource based fuels in the manufacturing process.

Then there is products from the treatment of medical waste including sharps: Embodiments of this invention provide methods for converting a used healthcare material including a complex mixture of components including pulp materials, polymer materials, metal materials, and/or other material such as ceramic materials, ash materials, etc. directly into a burnable fuel, Without the need for component separation. Patent Number 8163045 Method and system of making a burnable fuel Inventors: Burton J. Kunik, James C. Berns, David G. Gossman

Still struggling in Australia is Real Power Systems. Peter and Kerry Davies have built a considerable amount of bench testing conducted (circa 2009 to now) and are successfully testing, including onsite pilots of their gasifier and pyrolysis retort and this success continues to lead to product identification not previously considered. They started being most interested in bio-char production for agricultural purposes, and the range of fuels that can produce and the range of waste they can treat under various water saturation condition is striking. And, they can produce syngas, synfuel, syncrude and have solved problems such as “Cavitation Phenomenon at the Reactor Chamber” that plaqued or was the reason for more expensive offering in the field.

If you can consider the cost savings when compared with traditional fuels it can be enormous. The environmental saving through the use of engineered fuels (syfuels) is a significant reduction of GHG emissions. So much so that engineered fuels, are getting overseas regulatory approvals and are meeting EPA definitions for “sufficiently processed”.

We are saying we should compare complimentary and alternative solutions to our energy problems, and being we should be very conscious of the traps involved in the development of technology, It can be very hard to stay focused when development is proving there is so much flexibility and opportunity in direction.

Possibly this is why the 21 Feb 2013 closing EOI has chosen to stay focused on wind and solar, but then something more needs to be done in keeping with the developments and as such building on advances to ensure uniform characteristics can be judged to gain a higher level of understanding and open whole new avenues for applications of otherwise problematic materials. What could be better than the local government waste dump having onsite production capability of syncrude made from waste tetra packs and plastics? it does make things oddly enough, a tad more difficult…but not impossible.