mt piper energy recovery project: rdf feedstock report

MT PIPER ENERGY RECOVERY PROJECT

APPENDIX F MT PIPER RDF WASTE FEEDSTOCK REPORT

Mt Piper Energy Recovery Project: RDF Feedstock Report Sources and suitability of waste for RDF

___________________________________________________

Report for Re.Group and EnergyAustralia

ED 12947 26/11/2019

Mt Piper Energy Recovery Project: RDF Feedstock Report

Ricardo Confidential i

Ricardo Australia PTY Ltd

Customer: Contact:

Re.Group and EnergyAustralia Gavin Hull Ricardo Australia Pty 37 Merivale Street 4101 South Brisbane

t: +61 (0) 476 618064

e: [email protected]

Ricardo is certificated to ISO9001, ISO14001 and OHSAS18001

Confidentiality, copyright & reproduction

This RDF Feedstock Report is submitted by Ricardo Australia Pty Ltd. It may not be used for any other purposes, reproduced in whole or in part, nor passed to any organisation or person without the specific permission in writing of the Commercial Manager, Ricardo. Ricardo Australia Pty Ltd is a wholly owned subsidiary of Ricardo Investments Ltd (UK), the ultimate parent is Ricardo Plc. Ricardo Australia Pty Ltd was incorporated in April 2018.

Author:

David Woolford, Gavin Hull

Approved By:

David Woolford

Date:

26 November 2019

Ricardo Energy & Environment reference:

Ref: ED12947- Issue Number 3


Ricardo Confidential 2


Table of contents 1 Introduction ................................................................................................................ 6

2 Waste Origins ............................................................................................................. 7 2.1 New South Wales Waste Policy ........................................................................................ 7

Protection of the Environment Operations (Waste) Regulation 2005 ...................... 8 NSW Waste Avoidance and Resource Recovery Act 2001 ..................................... 8 NSW Energy from Waste Policy Statement 2015 .................................................... 9 Waste Classification Guidelines 2014 .................................................................... 10

2.2 Accessing Sources of Waste ........................................................................................... 11 2.3 Summary of constraints ................................................................................................... 11

3 Waste tonnages ....................................................................................................... 12 3.1 MSW Estimates ............................................................................................................... 12

Advanced Waste Treatment ................................................................................... 12 Waste by Local Government Areas ....................................................................... 12

3.2 C&I Waste Estimates ...................................................................................................... 16

4 Waste composition and RDF specification ............................................................ 18 4.1 MSW Composition ........................................................................................................... 18 4.2 C&I Waste Composition .................................................................................................. 19

Landfilled C&I waste ............................................................................................... 19 4.3 Conversion of Waste to RDF ........................................................................................... 21

RDF Specification ................................................................................................... 21 Comparator results ................................................................................................. 22 Process overview ................................................................................................... 23 Economic considerations ....................................................................................... 24

5 Conclusion ............................................................................................................... 25

Appendix 1 Waste to Energy Policy Statement Requirements ...................................... 26

Figure 1 Summary of MSW Waste Tonnages as a proportion of RDF requirements........................... 15 Figure 2 Summary of estimated C&I Waste Tonnages as a proportion of RDF requirements ............. 17 Figure 3 Typical composition of New South Wales Municipal Solid Waste stream .............................. 18 Figure 4 Suggested composition of MSW waste suitable for RDF production based on AWT residues

and RDF processing ............................................................................................................................. 19 Figure 5 Composition of C&I waste disposed, by weight .................................................................. 20 Figure 6 Composition of C&I eligible waste based on RDF processing ............................................... 20

Table 1 Resource recovery criteria for energy recovery facilities 10 Table 2 Eligible waste in Western Sydney Region for potential RDF production 13 Table 3 Eligible waste in Illawarra and Shoalhaven Region for potential RDF production 14 Table 4 Eligible waste in Southern Sydney Region for potential RDF production 14 Table 5 Eligible waste in Hunter Region for potential RDF production 15 Table 6 RDF characteristics by waste stream 21




Acronym Meaning

ARRT Advanced Resource Recovery Technology (SUEZ facilities only)

AWT Advanced Waste Treatment

C&I Commercial and Industrial

CSIRO Commonwealth Scientific and Industrial Research Organisation

EA Energy Australia

EfW Energy from Waste

EPA New South Wales Environment Protection Authority

ERP Energy Recovery Process

FOGO Food Organics and Garden Organics

GO Garden Organics only

LHV Lower Heating Value

MBT Mechanical Biological Treatment

MLA Metro Levy Area

MSW Municipal Solid Waste

MWOO Mixed Waste Organic Output

NCV Net Calorific Value

NSW New South Wales

POEO Protection of the Environment Operations

RDF Refuse derived fuel

RG Re.Group

SEARs Secretary’s Environmental Assessment Requirements

SSROC Southern Sydney Regional Organisation of Councils

tpa Tonnes per annum

WaRR Waste and Resource Recovery

WLRM Waste Less recycle More




Executive Summary Energy Australia (EA) and Re.Group (RG) are jointly investigating the feasibility of using Refuse Derived

Fuel (RDF) at the Mt Piper Power Station. The proposed concept involves firing RDF in a dedicated

boiler and integrating the produced steam into the existing plant’s steam system.

It is proposed that the RDF is produced by processing Municipal Solid Waste (MSW) and some

Commercial and Industrial waste (C&I) that would otherwise be disposed to landfill. The RDF is formed

through mechanical processing that removes unwanted items such as metals, glass and entrained

organic material.

Overall RDF throughput is between 150,000 – 250,000 tonnes per year at the thermal design range.

The NSW EfW policy requires that specific collection and processing systems are in place for any

source waste that specifically targets the removal of organics and prioritises recycling prior to any

energy recovery activity.

This study has identified in excess of 470,000 tonnes per annum of MSW and at least 865,000 tonnes

per annum of C&I suitable for RDF processing. A summary of the estimated waste available from MSW

and C&I sources is provided below and indicates the relative market scale of the RDF demand based

on the area analysed.

The policy and operational model for EfW in NSW favours the production of RDF for the following

reasons:

• Restrictions on the availability of waste, based on separate collections for organics,1 provides

waste with lower moisture content and a higher calorific value.

• RDF production provides flexibility across the market with suppliers able to develop

infrastructure to meet local demand, stimulate additional energy opportunities and potentially

exploit export market opportunities.

• Reduce waste to landfill.

1 Only LGA’s with food collections can send 100% of their waste for processing




There is a huge number of global reference facilities, using equipment from a large number of different

suppliers, that are configured to produce RDF to various specifications. It is our opinion that this

experience and equipment is readily transferable into this project.

Revenue is provided by a gate fee at the RDF processing facility. Processing costs for RDF production

are fixed by factors such as electricity, transportation and operational and maintenance requirements.

Disposal costs are fixed by gate fees at the thermal treatment plant. Any processing rejects that require

disposal to landfill will also attract a cost.

RDF suppliers are faced with financial drivers associated with the costs of processing MSW into RDF

or disposing the MSW to landfill. Therefore, any landfill levy will be integral to moving material away

from landfill and up the waste hierarchy into a different disposal facility. This report does not look to

forecast, or look at the advocacy of the landfill levy, however this will remain an important factor in the

cost benefit analysis for suppliers.

This report has not examined the financial models associated with the project to examine the flexibility

to offer a range of disposal gate fees to suppliers. There are however, a growing number of reference

facilities producing a range of feedstock (RDF/Solid Recovered Fuel (SRF)/Processed Engineered Fuel

(PEF)) that prove the concept of viability of engineering, procuring and operating a facility capable of

economically producing feedstock to specification.

The processing design used to produce RDF will vary from facility to facility. However, Quality Assurance and Quality Control processes, which have been developed, will need to be consistently applied to ensure fuel specifications is consistently met.




1 Introduction RG and EA are jointly investigating into the feasibility of using RDF for the Mt Piper Power Station

situated in the Central West of New South Wales (NSW). The facility is proposing to use steam from a

boiler in a dedicated plant, rather than blending the RDF with coal in the existing power station.

The project is believed to bring many benefits to the community by providing additional baseload power

and improving NSW waste management infrastructure for MSW and C&I waste that would otherwise

be disposed of to landfill.

This report presents a situational scan of the availability and suitability of waste feedstock for the project

and a high-level commentary on the technical and financial suitability of the processing technology. A

review of policy and operational constraints is included.

Whilst this paper seeks to addresses the Secretary’s Environmental Assessment Requirements

(SEARs)2 in context of the waste feedstock, it does not provide any comment on the waste types of

quantities generated during the construction or operation of the Mt Piper energy recovery process

(ERP).

Given the requirements of the NSW Energy from Waste Policy Statement (that defines waste eligibility

criteria, technical criteria, thermal criteria and resource recovery criteria), this report provides the initial

evidence base to confirm that the proposed project will comply with the designated requirements.

Waste to energy projects are a sensitive issue as highlighted by the 2018 senate inquiry3 and the

recommendations from the Legislative Council Energy from Waste Technology Inquiry established in

20174. Whilst the policy may be updated in the future, there is currently strict requirements regarding

the need for reference facilities and eligibility criteria which are dealt with in a separate Best Available

Technology report.5

The Project’s dedicated boiler has a nominal design capacity of 200,000 tonnes of RDF per year and

power generation of 30MW. In practice, it is the thermal capacity of the boiler that is fixed, rather than

the mass throughput. If the fuel is at the lower end of the design range for calorific value, then the

tonnage of fuel must increase to offset this, with a maximum tonnage of 250,400 tonnes per year, or

31.3 tonnes per hour. At the highest calorific value, the maximum tonnage reduces to 150,000 tonnes

per year, or 18.8 tonnes per hour. However, the design tonnage remains 200,000 tonnes per year, or

25 tonnes per hour. For the purposes of this RDF Feedstock Report the design figure has been used

as a best estimate to assess the impacts.

2 https://www.planningportal.nsw.gov.au/major-projects/project/11541

3

https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/WasteandRecycling/

Report

4 https://www.parliament.nsw.gov.au/committees/inquiries/Pages/inquiry-details.aspx?pk=2436#tab-

reportsandgovernmentresponses

5 Ricardo ED13034_BAT Assessment

https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.planningportal.nsw.gov.au%2Fmajor-projects%2Fproject%2F11541&data=02%7C01%7CTara.Vaughan%40ricardo.com%7Ca45648ff85f743480dec08d71a061fc9%7C0b6675bca0cc4acf954f092a57ea13ea%7C0%7C0%7C637006485922458081&sdata=34fLUeke2g3EYTIqwtYhZW220YUcz%2Fo0AoQQ9Wa%2FvKY%3D&reserved=0

https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/WasteandRecycling/Report

https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/WasteandRecycling/Report




2 Waste Origins The Mt Piper ERP will source waste in the form of pre-processed RDF from a combination of the MSW

and C&I sources. The RDF feedstock will be sourced from a number of suppliers, as most waste transfer

and processing facilities do not operate at the required annual tonnages. Using RDF from a mixed

supply base will require some blending of feedstocks introducing a potential risk to the consistency of

the RDF specification. To manage this, it will be necessary to provide a legal framework for delivery to

specification through a system of Fuel Supply Agreements with third parties to ensure a tight level of

control (see Section 4). There might be scope for consolidating RDF production into one large

processing plant to facilitate tighter control on RDF specification if feedstocks are too varied.

Ricardo recommends that RDF production will be most practical to implement at existing waste

management facilities, where the waste streams, tonnages and compositions are known and

understood. While not currently active, there are several facilities that have either already obtained

Development Consent or have assessed the viability to include RDF production as an ancillary process

to their existing operations (see Section 4.2). The project will rely on third parties constructing suitable

facilities and sufficient time to develop the skills and knowledge required to process waste streams into

an RDF specification. The developer would have to agree and monitor RDF specification and waste

sourcing as part of a fuel supply agreement, and also as part of the Quality Control process structured

to meet or exceed all policy and operation requirements. Ricardo have experience in the design,

construction, commissioning and operation of a number of different types of MRF facilities and our

experience and knowledge leads us to encourage the close management of this type of development

in order to ensure that facilities will be successfully constructed. Because the RDF producing facilities

are not yet constructed, it presents a compelling opportunity to influence the design and construction of

any facilities to meet the fuel supply agreements. Projects under development in the EU that require

RDF to specification now conduct due diligence deep into the supply chain to ensure fuel can be

supplied to specification and that existing infrastructure is capable of production for the duration of any

fuel supply agreement.

Mt Piper ERP will look to source waste from a wide catchment area, which will primarily be defined by

the Metro Levy Area (MLA) as this provides a comparable baseline disposal costs per tonne (based on

the Waste Levy at $143.20 per tonne (for the MLA in 2019/20 and subject to an annual CPI rise) for

landfill waste. Waste sources will also be constrained by travel time and the associated transport costs

however, this is influenced by the willingness of waste management companies to pay a premium for

landfill diversion and what existing capacity there is for back-hauling or for bulk transport. An example

is through the Veolia Clyde Transfer Terminal which handles up to 500,000 tonnes of MSW and C&I

waste per year and transporting this to the Woodlawn Bioreactor Landfill (20% of Sydney’s Putrescible

waste6) in Goulburn, approximately 200km by train. This presents significant backhaul capacity for

processed waste (from the MBT facility) and a potential RDF supply.

2.1 New South Wales Waste Policy

In NSW, there are key policy objectives outlined in the State’s waste legislation. 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. Effectively, alongside the POEO Act is

the NSW Waste Classification Guidelines which provide details and guidance in the classification of

waste into groups that pose similar risks to human health and the environment according to classes of

waste defined in the POEO Act.

The Protection of the Environment Regulation 2014 was developed after a review of the State’s waste

management framework and was delivered in 2014. This set out to improve the NSW EPA’s ability to

6 https://www.veolia.com/anz/our-services/our-facilities/transfer-stations/clyde-transfer-station




protect human health and the environment through key changes and amendments to thresholds for

environment protection licences and reforms to the waste levy system.

The Waste Avoidance and Resource Recovery Act 2001 (WaRR Act) is another key piece of legislation

which aims to ensure that waste management is undertaken in accordance with the waste hierarchy in

that resource management options occur in the following priority 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 NSW Energy from Waste Policy Statement sets out the policy framework and

overarching criteria that apply to facilities in NSW proposing to thermally treat either, or both, waste or

waste-derived materials for the recovery of energy and in doing so provides regulatory clarity to industry

and the community.

Overall, these legislative and policy tools guide waste management and resource recovery practices

across the state and outline requirements for waste infrastructure development, processing and

disposal.

Protection of the Environment Operations (Waste) Regulation 2005

While the POEO Act outlines the framework to protect human health and the environment from the

misuse of waste the Waste Regulation outlines requirements of waste tracking, transportation and

exemption of waste classifications. Regarding EfW facility development, the application of the

Regulation includes specifications for resource recovery exemptions on certain waste materials

produced. Under Clause 51A of the regulation if it can be demonstrated that any waste material

produced from preparation of RDF for land application i.e. organics, (a list of current exemptions is

available on the NSW EPA’s website7) is fit-for-purpose and poses minimal risk of harm to the

environment then it may be considered for a resource recovery exemption.

The Regulation sets out the requirements for the transportation and receiving of waste and details how

waste would be treated, stored, used, disposed and handled on site. It also addressed the potential

impacts associated with these issues, including current and future offsite waste disposal methods to

address environmental impacts of waste.

NSW Waste Avoidance and Resource Recovery Act 2001

The WaRR Act promotes waste reduction and best use of resources in NSW as a priority, promoting

waste avoidance and resource recovery to achieve a continual reduction in waste generation. The

WaRR Act includes provisions for the development of a State-wide strategy and programs, promotes

extended producer responsibility for the lifecycle of a product and for industry actions to reduce waste.

With the prioritisation of waste avoidance, and the use of the strategy by Councils and Industry to set

waste management efforts and targets, there are restrictions on the sources of MSW and C&I waste for

feedstock. The Act gives rise to the WaRR Strategy which outlines the following targets:

• By 2021–22, reduce the rate of waste generation per capita.

• By 2021–22, increase recycling rates for:

o municipal solid waste from 52% (in 2010–11) to 70%.

o commercial and industrial waste from 57% (in 2010–11) to 70%.

7 https://www.epa.nsw.gov.au/your-environment/recycling-and-reuse/resource-recovery-framework/current-orders-and-

exemption




• By 2021–22, increase the waste diverted from landfill from 63% (in 2010–11) to 75%.

The aims of the Act encourage and drive councils and industry to increase resource recovery, diversion

of waste from landfill and seek to minimise waste disposal via landfill. The Mt Piper ERP option is able

to contribute to the third target above - 75% diversion from landfill target for 2020-21.

An implication for any RDF supply options are that all activities should be undertaken consistently with

aims, objectives and guidance in the WaRR Act. All measures implemented to ensure consistency with

the Act are to be identified and documented and reported in the Environmental Impact Assessment.

NSW Energy from Waste Policy Statement 2015

The NSW Energy from Waste Policy Statement (EfW Policy Statement) outlines the policy framework

and technical criteria that apply to facilities proposing to recover energy from waste in NSW. The scope

of the policy statement covers all facilities undertaking the thermal treatment of any waste, or waste-

derived materials, where thermal treatment means the processing of wastes by combustion, thermal

oxidation, thermal or plasma gasification, pyrolysis and torrefaction. The statement is a two-tiered risk-

based framework where 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.

The accompanying Eligible Waste Fuels Guideline 2016 should be read in conjunction with the NSW

Energy from Waste Policy Statement which lists the following segregated waste streams that are eligible

waste fuels:

• biomass from agriculture.

• forestry and sawmilling residues.

• uncontaminated wood waste.

• recovered waste oil.

• organic residues from virgin paper pulp activities.

• landfill gas and biogas.

• source-separated green waste (used only in processes to produce char).

• tyres (used only in approved cement kilns).

The Eligible Waste Fuels guideline details the definitions of eligible waste fuels including any additional

conditions of each eligible fuel source, characterisation and testing requirements and guidance on

resource recovery order or exemption conditions and applications.

For Mt Piper ERP it is proposed that RDF production will comprise of general mixed waste from MSW

and C&I sources. As such under the EfW Policy Statement any 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 facility8 (a summary of these requirements can be found in

Appendix 1, under technical and thermal efficiencies).

Key elements of the EfW Policy statement are to:

• Ensure minimal risk of harm to human health and the environment, which is primarily

achieved through standards applied at the EfW facility, specifying combustion conditions and

requiring ‘best available technology’ is used for emissions control;

• Ensure ‘higher order’ waste management options are not undermined, which is primarily

achieved through the introduction of Resource Recovery Criteria that restrict the maximum

8 Detailed in Section 4 of the EfW Policy Statement




percentage of the waste stream that can be directed to energy recovery, based on the type of

waste and style of collection system used.

The EfW Policy Statement recognises that the thermal treatment of waste provides an opportunity to

recover the embodied energy within waste, offset the use of non-renewable energy sources and avoid

methane emissions from landfill. However, these outcomes are contingent on ensuring that any energy

recovery proposals represent the most efficient use of the resource and are achieved with no increase

in the risk of harm to human health or the environment. The statement outlines the criteria for source

separation and types of waste streams considered in sourcing feedstock for EfW facilities as outlined

in Table 1.

There is also scope for sourcing waste residues from:

• MRF processing of up to a maximum of 10% by input weight.

• Organics processing facilities, up to a maximum of 5% by weight for garden organics and 10%

by weight for food only or food and garden organics.

The EfW Policy Statement further details the requirement to outline procedures to control inputs

including contingency measures if inappropriate or contaminated materials are identified which apply

to the Mt Piper proposed development (see Section 4.3.3).

Table 1 Resource recovery criteria for energy recovery facilities9

Mixed Wastes

Waste Stream Processing facility % residual waste allowed for energy

recovery

Mixed municipal waste

(MSW)

Facility processing mixed MSW 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


council has separate collection systems

for dry recyclables and garden waste

Up to 40% by weight of the waste stream



council has a separate collection system

for dry recyclables



Mixed Commercial and

industrial waste (C&I)

Facility processing mixed C&I waste Up to 50% by weight of the waste stream


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 processing facility

Mixed Construction and

demolition waste (C&D) Facility processing mixed C&D waste



Waste Classification Guidelines 2014

Waste Classification Guidelines provide direction on identifying and categorising waste according to

assigning material into groups that pose similar risks to the environment and human health. The

guidelines outline classification groups and enable waste to be managed according to that classification.

These guidelines provide information to assist in the description of the classes and quantities of the

waste that is identified to be thermally treated at the facility. This requirement will need to be addressed

in any supplier agreements and embedded in the Quality Assurance process.

9 Adapted from the NSW Energy from Waste Policy Statement 2015




2.2 Accessing Sources of Waste

Available waste feedstock suitable for RDF production are defined in the EfW Policy Statement (see

Section 2.1.3) however to access these sources operators of RDF producing facilities will also have to

evaluate their relative ‘social licence’ to operate. Existing facilities will have to balance a new RDF

offtake with current operations whereas new facilities will have to integrate the EfW benefits from

scratch. As project proposals progress from feasibility to detailed development assessment, genuine

engagement and dialogue with the community and stakeholders should be entered into to make certain

any such planning consent and other approval authorities are provided with accurate and reliable

information. Community consultation and the ‘good neighbour principle’ extends to aspects of operation

including waste deliveries and operating hours as well as emissions and resource recovery outcomes.

The approach taken for the Mt Piper ERP specifically targets supply options that have already sought

high resource recovery outcomes, such as:

• Pre-sorted municipal solid waste with organic components removed.

• Pre-sorted Commercial and Industrial Waste.

Where such waste streams are currently landfilled the recovery of energy has both environmental

benefits and a greater opportunity for social license. It is important that these benefits are communicated

across the supply chain and the industry partners that will be producing and supplying RDF.

2.3 Summary of constraints

Policy, resource recovery and technical constraints have been reviewed for the development and

operation of the proposed Mt Piper facility. Identified risks and opportunities include:

Policy

Conforming to NSW Energy from Waste Policy Statement

2015

Risks

Unexpected policy changes and regulatory updates impacting future markets

Opportunities

Separate collections improve environmental benefits of RDF supplyImprove market confidence

Improved social license

Clarity for stakeholders (waste suppliers)

Resource Recovery

Resource recovery priorities in accordance

with WaRR Act 2001, prioritising higher order

recovery

Risks

Reducing total amount of waste available

Introduction of competing treatment technologies

Opportunities

Higher quality supply

More favourable disposal option comparative to landfill

Technical

Processing requirements to achieve facility

specification

Risks

Processing becomes inefficient or redundant

May require additional investment to meet future specification

Lead to an RDF product with CV values outside operational limits

Opportunities

Additional recovery through removal of recoverable material i.e. metals and entrained organics

Improved capture and controlled disposal of unaccepted materials such as hazardous or radioctive materials and explosives etc.




3 Waste tonnages The estimated input tonnages for the Mt Piper ERP are 200,000 tonnes per year at a Net Calorific Value

(NCV) of 15MJ/kg for the RDF supplied. The supply of RDF can be increased to a maximum of 250,000

tonnes per year to meet the plants energy demands if the NCV is lower than 15 MJ/kg.

The anticipated mix of eligible waste will be 50% MSW and 50% C&I waste by tonnes, this will be

sourced from a number of aggregation points or waste management facilities, the exact blend of waste

will be dependent on the quality of supply from any or all of these sources.

All RDF waste sources identified in Sections 3.1 and 3.2 are eligible waste fuels as set out in the EfW

Policy Statement (see Section 2.1.3).

To estimate the potential supply of waste for RDF production Re.Group will prioritise locations in the

Greater Sydney area, but this can extend northwards to the Hunter, to the Illawarra south of Sydney

and the Central Tablelands.

3.1 MSW Estimates To capitalise on sources of eligible waste fuels, Re.Group will prioritise lower order waste fractions,

those where resource recovery has already been maximised, such as the reject stream from existing

Advance Waste Treatment facilities such as MBT. This will be supplemented with new fuel processing

and preparation facilities able to access MSW waste from collections that utilise source segregation

and is managed through existing transfer facilities. Whilst discussion have been had with various parties

none of the processors or LGA’s below have committed to the project.

Advanced Waste Treatment

There are two Advanced Waste Treatment facilities in the Western Sydney Region.

• Global Renewables, UR-3R facility, Eastern Creek (MBT) operated under contract to SUEZ as

an ARRT facility,

• SUEZ, SAWT facility, Kemps Creek (MBT)

And from outside the region, servicing Sydney Metro, Illawarra and Hunter Councils:

• Veolia, Woodlawn MBT facility, Woodlawn

• SUEZ ARRT facility, Spring Farm (Mechanical pre-treatment area for removal of Non-organics,

organics sent to Kemps Creek)

• SUEZ ARRT facility, Raymond Terrace (MBT)

Based on commercial in confidence discussions with operators of existing AWTs in the western Sydney

region, we understand there was at least 150,000 tonnes of AWT reject material available for RDF

production that currently goes to landfill in the western Sydney region in 2018/19. Changes to the

exemption process associated with mixed waste derived organic outputs (MWOO), which took effect

from October 2018, are likely to have increased the residual from existing AWTs that could potentially

be considered for production into RDF.

Waste by Local Government Areas Sydney Metro councils are divided into a series of Regional Organisation of Councils (ROC). Ricardo

has previously modelled waste projections for three of the four ROC’s listed below and has estimates

of the eligible MSW from 2020/21 for the member councils. The total annual waste tonnages are based

on data submitted by each LGA to the EPA as part of the WARR survey. Future forecasts for 2020/21




waste tonnages have been calculated from projected household growth10 and a rolling average of the

waste generated per household. These are detailed in the following tables. The proportion of total waste

considered suitable for RDF is based on the applicable collection system used by each council and the

associated Resource Recovery Criteria in the NSW EfW Policy.

Western Sydney Region

Western Sydney is the nearest area for sourcing waste for RDF supply with a rapidly growing

population, diminishing landfill capacity and significant existing waste infrastructure. Based on existing

data sources11, an assessment of the available waste across the Western Sydney ROC has been

conducted and summarised in Table 2. All councils included are in the MLA.

Table 2 Waste in Western Sydney Region suitable for potential RDF production12

Councils

Applicable

Collection /

treatment

Services

2020/21 Total

Waste (tonnes

per year)

RDF

Suitable

Waste

(tonnes per

year)

Blacktown

Blue Mountains

Cumberland

Fairfield

Hawkesbury

Liverpool

Parramatta

Penrith

The Hills

AWT

GO

GO & AWT

AWT

GO

GO

GO

FOGO & AWT

GO

Kerbside

General Waste

collection (MSW)

415,500 160,000

Council owned landfills are in operation in the Blue Mountains and Hawkesbury, there is one privately

operated putrescible landfill operated by Suez at Lucas Heights accepting waste from The Hills.

Cumberland sends waste to Woodlawn Bioreactor Landfill via Clyde Transfer Station and Penrith send

their organics depleted waste to SUEZ Kemps Creek Landfill (non-putrescible).

Illawarra and Shoalhaven Region

The councils in the Illawarra and Shoalhaven region have three landfills at Shellharbour, Shoalhaven

and Wollongong. These landfills have between less than 15 years capacity at current disposal rates

and are operated to conserve future capacity, as such the introduction of FOGO service in Shellharbour

and Kiama and the push for AWT in Shoalhaven are to extend their operational life. Further diversion

for energy recovery, if economical, may be a desirable option for this region. All councils are in the MLA.

10 Future household projects sources from the Australia Bureau of Statistics

11 WSROC Options Study 2014-15 Jacobs 2016

12 Ricardo data model based on NSW EPA WARR data




Table 3 Waste in Illawarra and Shoalhaven Region suitable for RDF production13

Councils Applicable Collection / treatment

Services 2020/21 Total Waste (tonnes per year)

RDF Suitable Waste (tonnes per year)

Kiama FOGO

Kerbside General Waste collection (MSW)

109,300 51,500

Shellharbour FOGO

Shoalhaven AWT

Wollongong GO

Wingecarribee GO

Southern Sydney Region

The Councils in Southern Sydney currently manage 20% of all NSW waste. The following summary

provided in Table 4 is based on 2020/21 waste projections report in the Southern Sydney Regional

Organisation of Councils (SSROC) Regional Waste and Resource Recovery Strategy. All councils are

in the MLA.

Table 4 Waste in Southern Sydney Region suitable for RDF production14

Councils

Applicable

Collection /

treatment

Services

2020/21 Total

Waste (tonnes

per year)

RDF

Suitable

Waste

(tonnes per

year)

Bayside

Burwood

Canterbury Bankstown

Canada Bay

City of Sydney

Georges River

Inner West

Randwick City

Sutherland Shire

Waverley

Woollahra

Most

councils

operate a

GO

collection

Kerbside General

Waste collection

(MSW)

399,600 159,000

The SSROC WARR Strategy identified only two disposal options for the region, Suez, Lucas Heights

Landfill which is expected to be operational until 2037 or Veolia’s Woodlawn15 Bioreactor landfill

adjacent to the MBT facility which could take waste until 2047 and beyond. Avoidance of operational

and commercial risks with such a duopoly presents an opportunity for RDF production as an alternative

disposal route for eligible waste.

Hunter Region

The councils in the Hunter Region operate a total of 6 landfill sites likely to be operational in 2020/21.

Port Stephens is the only council that sends waste for treatment at the SUEZ ARRT facility in Raymond

13 Ricardo data model based on NSW EPA WARR data

14 SSROC WARR Strategy 2014-2017-2021

15 Woodlawn in Approximately 250km from central Sydney and is service by rail




Terrace. Cessnock, Lake Macquarie, Newcastle and Port Stephens are in the MLA, Dungog, Maitland,

Muswellbrook, Singleton and Upper Hunter are in the Regional Levy Area (RLA).

Table 5 Waste in Hunter Region suitable for RDF production

Councils Applicable Collection / treatment

Services

Total Waste (2020/21) tonnes per year

Eligible Waste fuels (tonnes per year)

Cessnock GO

Kerbside General Waste collection (MSW) MLA

170,900 97,100

Lake Macquarie FOGO

Maitland GO

Newcastle GO

Port Stephens AWT

Dungog No organics

Muswellbrook GO Kerbside General Waste collection (MSW) RLA

17,000 5,700 Singleton GO

Upper Hunter Shire No organics

Summary of MSW Estimates

Based on the estimates of wastes suitable for RDF production across the four regions set out in Table

2-5 there is potentially 470,00016 projected tonnes per year in 2020/21. There is an additional 104,80017

tonnes of clean-up waste projected for 2020/21, in Western Sydney alone, that can also be sent for

processing and RDF production.

To source 50% of the ERP’s RDF from MSW sources would require securing 21% of the available

waste feedstock in the areas analysed. In reality this could be achievable by working with 3 to 4 specific

sources. The likelihood of additional councils wishing to divert a proportion of waste to achieve better

recovery rates is also highly likely as experienced with the capacity demand across the AWT sector.

Figure 1 Summary of MSW Waste Tonnages as a proportion of RDF requirements

16 Ricardo Model from NSW EPA WARR data and the SSROC WARR Strategy 2014-2017-2021

17 Ricardo Model for WSROC




3.2 C&I Waste Estimates

C&I tonnage data exists at a State level, however there is very little data available at a more granular

level as this isn’t regularly reported by the EPA and waste management sector operates across LGA

boundaries.

It is estimated that 1.53 million tonnes of C&I waste were disposed of to landfills in the regulated areas

of NSW in 2017-1818 and has seen a decline since 201519. Of this amount, 77% was disposed in the

Metropolitan Levy Area (formerly Sydney Metropolitan Area and Extended Regulated Area) 6% in the

Regional Levy Area (formerly Regional Regulated Area) and 18% in the Non-Regulated Area. This

indicates that there is minimum of 865,000 tonnes of C&I derived eligible waste in the MLA.

The most current estimate of the NSW C&I recycling rate (2012/13) is 61%20. This gives an estimated

total C&I annual generation of 4.7million tonnes. Other estimates of 2015 C&I generation have been

calculated at 5.7million tonnes per year21. The introduction of the Queensland waste levy in 2019/20

Queensland is also set to stabilise the NSW C&I market with less waste exported to Queensland for

disposal.

Several major C&I resource recovery facilities were proposed and have been granted funding through

the Waste Less Recycle More (WLRM) program, including three very large C&I processing facilities

proposed for the Western Sydney (Veolia, Dial-a-Dump and Resource Co). The WLRM funded facilities

have the potential to divert over 390,00022 tonnes per year of C&I waste from landfill, from a total of 1.6

million of throughput capacity. Of the projects proposed the materials diverted to RDF supply comprised

88,000 tonnes per year.

In a study commissioned by the NSW EPA and completed by KMH Environmental in 201523, it was

estimated an additional 494,000 tonnes per year of energy recovery capacity would be need in 2020/21.

Independent investigations and discussion with the major C&I waste contractors have indicated that

approximately 800,000 tonnes per year of eligible C&I waste are available for RDF production, see

Figure 2.

18 NSW EPA Waste Avoidance and Resource Recovery Strategy Progress Report 2017-18 EPAhttps://www.epa.nsw.gov.au/-

/media/epa/corporate-site/resources/recycling/19p1690-warr-strategy-progress-report-2017-

18.pdf?la=en&hash=89CD40E994CC383F6A1E23512714FD3FF5C69C6C

19 NSW EPA (2016). Data Unit Waste Contribution Monthly Reports. Unpublished data

20 NSW EPA (2016) NSW Generation Summary 2012-13 v0.3 (unpublished)

21 KMH (2015). NSW Resource Recovery Infrastructure Needs Analysis. Unpublished data.

22 Source: NSW EPA WLRM Infrastructure Data for Major Resource Recovery, Organics, Resource Recovery Facility Expansion

and Enhancement and Priority Waste grantees

23 Source: KMH Environmental (2015) NSW Resource Recovery Infrastructure Needs Analysis




Figure 2 Summary of estimated C&I Waste Tonnages as a proportion of RDF requirements




4 Waste composition and RDF specification

4.1 MSW Composition

Typically, the overall composition of MSW generated by residents does not vary significantly however,

with the introduction of alternative collection schemes designed to reduce both the recyclable and

organic content there could be some significant differences between LGA’s. A reduced organic content

can help produce a higher specification RDF as there is a natural reduction in the moisture content that

can have the effect of increasing CV. Conversely, the removal of recyclate such as card and plastic

will reduce CV. The production of RDF to a specification can be complex, however the net effect of

both policies outlined above is to reduce the overall volumes of MSW to process into RDF, which

provides suppliers a narrower window of tolerance within the original waste stream from which to

produce fuel.

A typical NSW MSW waste stream is outlined in Figure 2. This has between 35-45%24 food organics

and 7-15% garden organics by weight. This can be reduced to between 20-30% by weight with the

introduction of a FOGO collection.

Figure 3 Typical composition25 of New South Wales Municipal Solid Waste stream

Waste rejects from the AWT processes are altered further with significant removal of recyclable

materials, organics and moisture. For the purposes of this feedstock evaluation the composition is

24 But can be in excess of 50%

25 NSW EPA WARR survey data from 2014-15. Based on audit data from all council submission in the Metro Levy Area (a audit

of 8806 bins)

Total Paper and Paper

Products, 21%

Food Organics, 38%

Garden & Other Organics,

15%

Total Glass, 3%

Total Plastics, 10%

Total Ferrous, 2%

Total Non-Ferrous, 1%

Total Hazardous,

1%

Total Building Waste, 2% Total Earth

Based, 3%

Total E-waste, 1% Total

Miscellaneous, 3%




summarised in Figure 4. The following elements will need to be removed from this stream to minimise

ash levels:

Removal of entrained organics (a reduction of compostable organics to approximately 16%)

• Removal of glass

• Removal of ferrous and non-ferrous metals

• Removal of fines and inert materials

• Removal of Waste Electrical and Hazardous materials

Figure 4 Suggested composition of MSW waste suitable for RDF production based on AWT residues and

RDF processing26

Processing plants will need to understand the composition and characterisation of the input waste

stream to ensure plants are designed with a mass balance removal that meets the end specification

required by the Mt Piper ERP. Any bulking from multiple processing plants will be inherently challenging

as feedstock requires a control point before thermal treatment to ensure quality control.

4.2 C&I Waste Composition

General C&I compositional data exists at a state level however there is very little data available at a

more granular level as the market operates across LGA boundaries.

Landfilled C&I waste

Figure 4 shows an estimate of the overall composition of the C&I waste disposed in NSW. The main

components are garbage bags, other material (mainly residual from waste processing and MRF

residual), wood and masonry. Most of the wood is treated timber and most of the plastic is plastic film.

The garbage bags contain primarily food, plastic and paper.

26 Source: Suggested composition based on Ricardo waste characterisation feedstock data model

Paper, 35%

Plastic, 30%Glass, 0%

Ferrous, 0%

Non-Ferrous, 0%

Organic (Compostables),

17%

Other Organic, 10%

Earth Based, 0%

Miscellaneous, 8%

Waste Electronic, 0%

Hazardous, 0%




Figure 5 Composition of C&I waste disposed, by weight27

For the purposes of this feedstock evaluation the composition summarised in Figure 6 has been

adapted based on previously modelled C&I waste profiles that Ricardo has developed for other clients

based on economic profiles and NSW C&I Waste generation factors. This is also aligned to that

observed from confidential client data and varied from the above profile by the following factors:

• Removal of entrained organics (a reduction of compostable organics to approximately 7%)28.

• Removal of inert material and fines.

• Opening of garbage bags and reallocation of waste to materials categories

Figure 6 Composition of C&I eligible waste based on RDF processing29

27 Source: NSW EPA (2014) Disposal based audit of the commercial and industrial waste

28 The shredding of bagged waste liberates materials for removal and processing, thus significantly changing the baseline

composition

29 Source: Ricardo C&I data model base 2017/18 economic profiles and 2014/15 NSW C&I Waste generation factors

Paper, 38%

Plastic, 27%Glass, 2%

Ferrous, 1%

Non-Ferrous, 1%

Organic (Compostables),

7%

Other Organic, 4%

Earth Based, 3% Miscellaneous, 14%

Waste Electronic, 0%

Hazardous, 0%




4.3 Conversion of Waste to RDF

RDF Specification

It is proposed by the proponents that the RDF is recovered by processing municipal solid waste and

commercial waste that would otherwise be disposed to landfill to the specification with characteristics

shown in the following table:

Table 6 RDF characteristics by waste stream MSW RDF (50%) Commercial RDF (50%) Range Units

Moisture 32% 25% 10 - 35 %w as received

Ash 12.5% 12.5% 10 - 20 %w dry basis

Volatile Matter 80.0% 80.0% 75 - 90 %w dry basis

CV (net or LHV) 14 16 10 - 18 GJ/t as received

The process used to create the RDF may vary from facility to facility, however the broad approach will

be to remove unwanted small organic, inert fractions and metals. RDF production through mechanical

treatment has the natural effect of drying the RDF and reducing moisture. Depending upon moisture

levels, further drying of the fuel can be undertaken, however this can increase cost of production and

therefore requires careful technical and economic assessment. Regional variance also exists when

considering the removal of recyclate30 during collection and again will require technical assessment to

ensure that removal of high CV recyclate (such as cardboard or plastics) from the fuel will not have a

diminishing effect on the combustion characteristics. It is completely routine to then have a final sizing

phase for the RDF to ensure it is plant compliant and this can involve either single, or a series of multiple

shredders.

The estimated RDF compositions given in Figure 4 and Figure 6 have been used to calculate the

Moisture, Ash and Net Calorific Value by waste materials as set out in the RDF specification. Ricardo

has compared a range of analyses31, the 2015 Commonwealth Scientific and Industrial Research

Organisation (CSIRO) data was selected given that they strike an appropriate compromise between

geographical location of study, based on collected samples and being most recent.

Based on the assumed compositional range given in Figure 4 and Figure 6 it is Ricardo’s opinion that

an RDF produced would meet the specification with the following criteria:

• Moisture – c. 28 % by weight

• Ash – c. 10 % by weight

• NCV – c. 14 MJ/kg

This analysis is based on assumed materials composition32 and an independent materials

characterisation analysis and provides an indication of the expected characteristics of the feedstock at

this early stage of project development and definition. This is no substitution for sampling and testing

of specific and identified eligible waste sources. This analysis should come in the form of detailed

compositional analysis and in-depth characteristics analysis, which will underpin the sizing basis

previously mentioned in this report. Compositional analysis will allow for more detailed engineering

30 Recyclate describes recyclable materials that are both accessible and entrained i.e. not accessible in the waste mix.

31 Several are client confidential but also, a 2015 CSIRO study based on waste auditing undertaken in Brisbane, QLD.

32 This composition is similar to that sighted in client confidential data for the post treatment AWT reject stream.




around likely mass balance flows within any processing plant, whilst characterisation of feedstock will

allow alignment with detailed engineering of combustion and clean-up systems.

Ricardo has reviewed other commercial in confidence analysis, which indicates a consistent NCV of

between 14-18 MJ/kg. But again, this information requires further technical due diligence to provide

reassurance.

Comparator results

In addition to the modelled results, Ricardo also reviewed a range of other MSW NCVs from previous

Australian and Global studies. However, these are based on total MSW i.e. without the removal of

entrain organics, and typically have an NCV of between 8-10 MJ/kg, which is in line with our

expectations.

It is important to note that NCVs are very closely linked to waste composition, so taking analogies from

other countries or geographies needs to be undertaken carefully and introduces uncertainty to the

estimate.

Other CVs included:

• 7.9 MJ/kg (CSIRO study for Brisbane MSW, undertaken in Wet season, approx. 31% food and

garden organics);

• Japan (8.2–9.0 MJ/kg), 2012 – CSIRO study reference

• Korea (8.16–11.92 MJ/kg), 2013 – CSIRO study reference

• UK (9.22 MJ/kg), 2008 – CSIRO study reference

• USA (9.2 ± 0.96 MJ/kg),1980) – CSIRO study reference

The Brisbane figure is quite low, but by the author’s admission this study was undertaken in the wet

season, and as such the composition (and calorific values used) may be unusually low due to high

moisture content and a higher proportion of garden waste that might be expected in Brisbane in that

season.

Comparator results are indicative however are not suitable substitutions from actual composition and

characterisation data from waste streams targeted. It is therefore appropriate to select a combustion

process which is capable of safely operating across a range of fuel characteristics, and to ensure

appropriate testing and monitoring regimes are applied at the source of the RDF to ensure the total fuel

supply is within design parameters. These will need to be confirmed via sampling of specific fuel

production facilities, which the proponent has committed to undertake (see Section 4.3.3)




Process overview

The process used to create RDF may vary from facility to facility however the broad approach (with

initial QA/QC procedures provided in italics below) from creation to use will be guided by the following

process:

Supplier Quality Control, Assurance and Testing should be undertaken at all facilities where RDF is

sourced. It is expected that RDF will be sourced from numerous existing facilities in Greater Sydney,

although other sources may be used if these are developed and meet required quality and control

mechanisms. Aligned with global good practice we would expect supplier QA/QC procedures to be

discussed and developed and be included within any fuel supplier agreements. We would also expect

independent auditing of facilities to ensure compliance with the law and commercial agreements that

are in place. This would include testing and sampling methodology, storage and transportation

arrangements and also any other third-party reliance such as feedstock contracts that supply waste into

the RDF production facility.

Supplier feed stock compliance with the NSW EfW Policy will also be reviewed prior to any supply of

material. This includes compliance with waste sources and collection systems that comply with the

waste stream and source separation criteria outlined in the statement. Various sourcing of RDF input

will not impact operations due to the requirement that all input materials meet quality control and testing

and be derived from sources consistent with the NSW EfW Policy.

The pre-processing and sorting of waste would vary from facility to facility and according to waste

stream, however all material would be required to meet output specification. Pre-sorting and sorting of

waste processes are diverse and can be informed by a range of variables and ensuring that pre-

processing requirements meet required specifications and are informed by mass balance analysis,

equipment selection, understanding reference plants and the influence and specifications of supplier

equipment. An example of the pre-sorting process is currently undertaken at Global Renewables UR-

3R facility where municipal waste is sorted using the inherent properties of the material such as size,

shape and density into three main categories through the use of shredders, trommels and screens, the

categories are recyclables, organics, and non-recyclable inorganic materials. The recyclables go

through sorting and cleaning processes to be ready to be sold as recyclables. The remaining fraction is

classed as suitable for RDF production. The UR-3R technology is consistent with the waste hierarchy

philosophy towards achieving a waste less society as it allows waste that would otherwise be disposed

to be recycled or recovered. This process also supports waste reduction and reuse initiatives run by

councils and community groups.

Supplier quality control, assurance and

testing

Supplier compliance

with NSW EfW Policy and contract

development

Pre processing and sorting of

waste according to

fuel specification

Compaction and

transportation of RDF

Transportation of RDF

including tracking and checking of

waste deliveries

Receipt and storage of RDF

Additional sampling,

testing and use

Monitoring and reporting




The proposed processing will be suitable for the Steinműller Babcock Environment (SBE) system

providing quality control procedures are in place for material size and CV. Fuel specification and CV

range of the preferred SBE system include:

• The lump size and weight of any single pieces are assumed as follows:

o Non massive pieces below 1000 * 500 * 500 mm.

o Massive pieces below 500 * 200 * 200 mm

o Weight < 50 kg of individual item (MSW, Biomass).

• Design is a feedstock of RDF with an average heating value of 9 to 18 MJ/kg

• Must be thoroughly mixed and homogenised.

This is a complex area and will need to be developed to ensure agreed processes and procedures are

adopted and followed, segregation and retention of sampling batches is carefully controlled and

recorded, and enough space is provided for this to take place. It is invariable that reject loads will also

arrive at the plant and therefore technical and commercial arrangements are put in place to manages

such loads, as is common practice globally.

Pre-processing and testing by the supplier normally takes place at their premises and should be in

accordance with industry norms. It is expected that these costs will be reflected within the supply price.

It is not normal for suppliers to allow third-party reliance upon their own testing and sampling, which is

generally configured to their own requirements to assist in producing fuel to specification.

It is recommended that all fuel supply agreements include specific testing and sampling requirements

consistent with the nature of the feedstock, the type of processing, and the technical risks of the RDF

preparation and combustion.

If 100% of feedstock is not contracted, then additional arrangements will need to be arranged for ‘spot

tonnage’ that is supplied on short term contracts.

Compaction and Transportation

Loads of RDF are to be compacted and transported via road. While there will be some capacity at the

Mt Piper facility to accept baled RDF material this is outlined as a non-preferred option and will be

accepted only as a reserve feedstock line. It is intended that there is an auditable chain of custody in

the transportation of RDF from the supplier’s facility to the Mt Piper Power Station Site.

Receipt and Storage

Only deliveries received from approved RDF suppliers should be permitted to be received and

discharged into the storage and handling system at the Mt Piper site. The storage of RDF on site to be

in approved conditions reflective of approved location, amount and capacity of the site.

Economic considerations

Economic considerations to be given to the viability of the facility include:

Capacity including the overall proposed capacity of the facility. It has been determined on initial

calculations that the facility would become economically viable at the processing capacity of 200,000

tonnes per year of fuel and 30 MWe.

How RDF is handled and transported is guided by the following working assumptions: the proposed

scale of the facility and capacity of RDF, that the facility can accept material from more than 4 suppliers

(from within the Greater Sydney Region) and that compacting the material for transport is a more

commercially viable option than baling the material. Compacting material can alter supply and delivery

techniques into the combustion chamber and therefore consideration needs to be given to bulk density

allowances. We would expect daily delivery limits for each supplier, agreed methods of transportation

and delivery times that are strictly adhered to as normally set out in planning conditions.




Projected Gate Fees will need to be competitive with current landfill and levy costs33 and take into

consideration capital repayment costs of waste processing facilities constructed to produce RDF,

processing costs, sampling and testing, auditing and transportation. There is an active RDF and Solid

Recovered Fuels (SRF) market developing and costs associated with both will need consideration as

this facility requires an RDF with higher NCV than traditional MSW. SRF is typically a processed fuel

with a higher NCV than RDF and subsequently has a different value supply chain. MSW is not easily

processed into a higher NCV RDF (if ever on its own without C&I mixing) and therefore will not be of

interest to those producing SRF, which is generally produced from C&I streams. However, C&I streams

may need to be targeted to increase the level of NCV of the MSW derived RDF to ensure an NCV at

commensurate levels. However, the design range of the ERP also allows for the processing of RDF at

the lower end of the NCV range.

Contamination of feedstock is a commercial, economic and technical consideration of project viability.

Contamination of the feedstock can greatly impact the project and potentially impact and/or damage

infrastructure. Maintaining delivered fuel to specification is normally dealt with via contractual

mechanisms such as fuel supply agreements. These agreements generally set out supply tonnages,

daily delivery allowance, input specification, period of supply, testing and sampling methodology and

rates and process for remediation on supply of fuel out of specification which can result in financial

penalties and possible termination of supply. While less handling of feedstock would generally

correspond to a cheaper processing cost per tonne for a supplier the potential negative economic

impact of contamination is managed by ensuring a quality and consistent feedstock through contracts

and sound sampling and testing controls. These procedures are not unique to the Mt Piper project and

are well used globally.

5 Conclusion This study has identified in excess of 470,000 tonnes per annum of MSW and at least 800,000 tonnes

per annum of C&I suitable for RDF processing.

The policy and operational model for EfW in NSW favours the production of RDF for the following

reasons:

• Restrictions on the availability of waste, based on separate collections for organics, provides

waste with lower moisture content and a higher calorific value.

• RDF production provides flexibility across the market with suppliers able to develop

infrastructure to meet local demand, stimulate additional energy opportunities and potentially

exploit export market opportunities.

• Reduce waste to landfill.

There is a huge number of global reference facilities, using equipment from many different suppliers,

that are configured to produce RDF to various specifications. It is our opinion that this experience and

equipment is readily transferable into this project.

A growing number of reference facilities producing a range of feedstock (RDF/Solid Recovered Fuel

(SRF)/Processed Engineered Fuel (PEF)) that demonstrate the concept of viability of engineering,

procuring and operating a facility capable of economically producing feedstock to specification.

33 Currently levy set at $143.60 per tonne in the Metropolitan Levy Area




Appendix 1 Waste to Energy Policy Statement Requirements

An energy recovery facility processing wastes other than ‘eligible waste fuels’ must satisfy all of the below requirements, regardless of whether the facility is an

existing or purpose-built facility and the waste input is the sole feedstock or a fuel for co-firing.

NSW Waste to Energy Statement

Requirement

Compliance Opportunities

Ge

ne

ral C

rite

ria

Social license to operate- public consultation and the good neighbour principle

• Demonstration of effective information and public consultation about energy from waste proposal. • Demonstration of genuine dialogue with the community and ensure that planning consent and other approval authorities are provided with accurate and reliable information. • Demonstration of operation under the ‘good neighbour’ principle in application to waste deliveries and operating hours but most importantly with respect to readily available information about emissions and resource recovery outcomes.

Evidence that the facility meets current international best practice techniques in the following areas: • 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

• Demonstration of how facility will be operated and perform at best practice standards including how waste will be received, stored and processed (as a material input and outputs) through plans, procedures, diagrams and other documents: • Quality assurance and quality criteria protocols for managing contamination and risks • Provide clear and accurate information on the aMt (tonnes) of wastes received onsite, including unprocessed, processed and output materials • Specifically address contingency procedures for contaminated waste, rejected loads and supply failures

Facility information to demonstrate that the technologies chosen are: • proven • well understood; and • capable of handling the expected variability and type of waste feedstock Must have reference to fully operational plants using the same technologies and treating like waste streams in other similar jurisdictions.

• Reference to fully operational plants using the same technologies and treating like waste streams in other similar jurisdictions.




Te

ch

nic

al C

rite

ria

The temperature of the gas 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).

Demonstrate compliance with time and temperature requirements through process descriptions, diagrams, technical details to demonstrate compliance NOTE: torrefaction and pyrolysis processing temperatures are lower than other thermal processes. In these situations the emissions to air from the facility must meet these temperatures to manage risks to the environment and human health.

If a waste has a content of more than 1% of halogenated organic substances, expressed as chlorine, the temperature should be raised to 1100°C for at least 2 seconds after the last injection of air.

Demonstrate compliance with time and temperature requirements through process descriptions, diagrams, technical details to demonstrate compliance NOTE: torrefaction and pyrolysis processing temperatures are lower than other thermal processes. In these situations the emissions to air from the facility must meet these temperatures to manage risks to the environment and human health.

Satisfy at a minimum the requirements of the Group 6 emission standards within the Protection of the Environment Operations (Clean Air) Regulation 2010

Air quality impact assessment (AQIS) addressing emission points and fugitive emissions

Evidence of continuous measurements of NOx, CO, particles (total), total organic compounds, HCl, HF and SO2 Continuous measurement data (as seen above) 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

• Demonstrate how continuous measurement will be undertaken • Diagrams, drawings, equipment specifications, technical details, outline how data will be collated and accessed • Demonstrate how data will be made available in real time • Demonstrate how weekly summaries will be published on the internet for public access

Continuous measurements of the following operational parameters: • temperature at a representative point in the combustion chamber; • concentration of oxygen • pressure and temperature in the stack • water vapour content of the exhaust gas

• Demonstrate how continuous measurement will be undertaken • Diagrams, drawings, equipment specifications, technical specifications and details or equipment and to be used, outline how data will be collated and accessed

Monitoring and reporting to be conducted and held by the proponent for a period of three years

• Demonstrate through procedures, processes and record keeping tools

Proof of performance (POP) trials to demonstrate compliance with air emissions standards

• Details of POP trials including a plan, timelines, processes, management, monitoring, responsibilities and reporting • Detailed information on the commissioning period of the facility, including but not limited to equipment testing, start-up fuel and operating conditions.

Requirement (following successful POP trials) for at least two measurements per year of heavy metals, polycyclic aromatic hydrocarbons, and chlorinated dioxins and furans

• Demonstrate how the six monthly and three-monthly measurements will be undertaken




One measurement at least every three months shall be carried out for the first 12 months of operation. If and when appropriate measurement techniques are available, continuous monitoring of these pollutants will be required.

• Diagrams, drawings, equipment specifications, technical specifications and details or equipment and to be used, outline how results will be

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.

• Demonstrate expected TOC or LOI of slag and bottom ashes through data, tests results and reference facility or facilities

The facility includes waste feed interlocks as 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.

• Provide technical details and diagrams of the proposed waste interlock for the facility • Provide procedures, documents or plans for management of interlock

Air Quality Impact Assessment in accordance with the Approved Methods for the Modelling and Assessment of Air Pollutants in NSW

Demonstrate approved methods applied to AQIS and completed by suitable qualified

professional

Th

erm

al

eff

icie

nc

y

The net energy produced must be positive

• Demonstrate net energy is positive

The facility demonstrates that at least 25 per cent of the energy generated will be captured as electricity (or an equivalent level of recovery for facilities generating heat alone)?

• Demonstrate at least 25% will be captured as electricity or heat

The facility demonstrates that any heat generated by the thermal processing of waste is recovered as far as practicable. Including use of waste heat for steam or electricity generation or for process heating of combined heat and power schemes.

• Details of heat use on site, equipment and specifications

Re

so

urc

e

Re

co

very

Cri

teri

a The facility may only receive feedstock from waste processing facilities

or collection systems that meet the criteria outlined in Table 1 of the Waste to Energy Statement . Note; Proponents wishing to use waste or waste-derived materials for energy recovery that are not defined in Table 1 must contact the EPA to discuss their proposal. The EPA will consider any such proposals on a case-by-case basis in accordance with the energy from waste considerations outlined in this policy statement and the principles set out in the POEO Act and WaRR Act

• Provide contract or supply agreements, draft agreements • Information of the specific sources of wastes, processes waste has been subject too, and bin system/s details if MSW • If propose to use C&I no limit, prior approval from the EPA is required • Demonstrate with descriptions, diagrams, waste classification, descriptions photos, tests results etc.

The EPA may give consideration to increases to the maximum allowable percentage of residuals from facilities receiving mixed municipal and commercial and industrial waste where a facility intends

• Contact EPA is considering increasing maximum allowable percentage




to use the biomass component from that process for energy recovery, rather than land application and the facility can 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

• Develop management plan or procedure plan for the receipt and processing of waste that includes standard operating procedures that ensure hazardous materials do not enter waste stream for energy recovery e.g. batteries, asbestos.

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 centers).

• If using the C&I no limit category it needs to be demonstrated 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

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

• Resource Recovery Order and Exemption Application

Source: Adapted from https://www.environment.nsw.gov.au/-/media/OEH/Corporate-Site/Documents/Funding-and-support/Environmental-Trust/Recycling-

innovation/recycling-innovation-energy-from-waste-compliance-160208.pdf

https://www.environment.nsw.gov.au/-/media/OEH/Corporate-Site/Documents/Funding-and-support/Environmental-Trust/Recycling-innovation/recycling-innovation-energy-from-waste-compliance-160208.pdf

https://www.environment.nsw.gov.au/-/media/OEH/Corporate-Site/Documents/Funding-and-support/Environmental-Trust/Recycling-innovation/recycling-innovation-energy-from-waste-compliance-160208.pdf