COVANTA - Welcome to Dublin City Council | Dublin … · • Emissions to air will be monitored ... details see Covanta and Contractor organisational diagram included ... environmental

Dublin -, Waste to Energy - � lfl1den1 lndnl!ralixl & la:MfY

FAO: Simon Buckley Office of Environmental Enforcement, Environment Protection Agency, Richview, McCumisky House, Clonskeagh Dublln14

Ref: W0232-01: Commissioning Plan

Dear Mr. Buckley

COVANTA

September 07, 2016

In accordance with Condition 3.17 of the Waste Licence W0232-01 ("The lfcensee shall at least three months prior to the date of plant commission, submit to the Agency for Its agreement a Test Programme/ Commissioning Plan), please find enclosed a copy for the Agency's review

I trust this is satisfactory. Should you have any queries please do not hesitate to contact me.

Dublin Waste to Energy Ltd., Pigeon House Road, Poolbeg, Dublin 4. Tel: +353 (0)1690 9731 Registered Office: Arthur Cox Ltd., Earlsfort Centre, Earlsfort Terrace, Dublin 2.

Dublin Waste to Energy Facility

Employer: COVANTA Europe Engineering Ltd. Site Address

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Arthur Cox Building 29 Earlsfort Terrace Dublin 2 Ireland

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I Dublin WTE Facility I Pigeon House Road

Poolbeg Peninsula, Dublin 4 Ireland ---J

Clemens Fuchs Thomas Zacharias Rafael Masey Changes after Review Covanta 22.07.2016 22.07.2016 22.07.2016

Clemens Fuchs Thomas Zacharias Rafael Masey Comments and Appendix 2 Implemented 21.07.2016 21.07.2016 21.07.2016

Clemens Fuchs Thomas Zacharias Rafael Messy Comments Covanta implemented 06.07.2016 06.07.2016 08.07.2016

Clemens Fuchs Thomas Zacharias Rafael Masey Rrst Issue 31.05.2016 31.05.2016 31.05.2016 Author Reviewer Approver Short description of change llnltlals Data, Slgnalul'II) (Initials 08111. Signature) (lnltlalo 08111, SJvnatu,.)

Commissioning Plan

I Project N- r -

jP-3270 Project Name - -- ,

Dublin WTE Facility AIC

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50052719 -2.1

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Issued by

Hitachi Zosen ln1111a AG Hardtunnstrasse 127

P.O. Box 680 8037 Zurich, Switzariand

www hz-mova com Tai. +41(0)442n 1111 Fax +41(0)442n 1313

All rights 11!SIIVed ICC1ll'ding ID 150 1111l16

I Hitachi Zosen INOVA

Hitachi Zosen lnova AG 1 50052719 - 2.1 Document Nr-Rev:

- Project Name: Dublin WTE Faclllty

Title: Commissioning Plan

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Table of contents

1 Introduction 3

2 Commissioning Programme 4 2.1 Cold Commissioning 4 2.2 Phase 1: Refractory Lining Dry Out & Boil Out.. 4 2.3 Phase 2: First Firing with Start-up and Auxilliary Burners 4 2.4 Phase 3: First Firing with Waste and Steam circuit testing 4 2.5 Phase 4: Optimization 5 2.6 Phase 5: Performance Warranty Test 5 2.7 Phase 6: Commercial Operation 5

3 Personnel and Organisational Structure 6 3.1 Personnel 6 3.1.1 Contractor (HZI) 6 3.1.2 Independent Agency (TUV) Error! Bookmark not defined. 3.1.3 Covanta Personnel 6 3.1.4 Control of Personnel 6

4 Regulatory Requirements 7 4.1 EPA Permit Limits and Requirements 7 4.1.1 The emissions llmlts to air 7 4.1.2 Emissions Limits to Water 8 4.1.3 Waste Water Disposal. 8 4.1.4 Notlficatlons 8 4.2 Verification of Compliance with Regulatory Requirements 9 4.2.1 Post Combustion Chamber Temperature eso•c / 2s 9 4.2.2 CEMS 9 4.3 Noise during Commissioning 9

5 Waste Profile 10

6 Reagent Delivery Profile & Storage 11

7 Residue Disposal 12 7 .1 Boiler/Bottom Ash 12

7.2 Flue Gas Treament (FGT) Residues 12

Appendix 1 - Commissioning Organisation Diagram 13 Appendix 2 - Dublin Commissioning Programme 14 Appendix 3 - Validation of Combustion Conditions ••••..••••.••••••..•••..•..•••••............... 16

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Project Name: Dublin WTE Facility


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50052719 • 2.1 J Hitachi Zosen l�va AG Poworlng Today Protec.ting Tomorraw CO VANTA

1 Introduction The Dublin WTE Facility Project is currently under construction by the Contractor Hitachi Zosen lnova AG (HZI) on behalf of Covanta.

This document outlines the organisational structure and procedures Implemented for the safe and effective commissioning of the Dublin WTE Facility. The intention of this document is to illustrate the high level procedures to be employed rather than the detailed procedures which are a suite of specific system procedures.

The timing of the commissioning period is based on experience with comparable facilities. Commissioning starts after the Mechanical Completion system wise. The Commercial Operation Date signals the end of commissioning. A summary of the commissioning timeline is illustrated by Figure 1.

Figure 1: Commissioning Time/ine. P1 - P6 correspond to phases 1 to 6 described below.

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'INTI l Project Name: Dublin WTE Faclllty I Hitachi Zose n I

I j Title: Commissioning Plan I NO VA od�y Protocttng Tomorrow

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2 Commissioning Programme Commissioning of the plant is a dynamic process. It begins with pre commissioning, signal tesling, followed by function testing of the systems based upon the design function-logic descriptions and logic-diagrams. These include all safety-interlocks and protection systems as well as preparation and filling with fluids as appropriate to bring the plant to Its readiness state for hot-commissioning. The Contractor uses a detailed commissioning program to schedule activities. This program is then reviewed on a weekly and daily basis to ensure the best use of the time available.

In order to maintain flexibility but clearly define what has been completed, the hot commissioning process is broken Into six distinct phases with each phase being completed in series with the contractor providing notification before moving on to the next phase.

Appendix 2 provides an overview of the commissioning programme, the six phases and status of major parameters during each phase

A new phase will only begin once it can be clearly shown that the current phase Is complete and the plant is operating as expected.

2.1 Cold Commissioning Cold commissioning occurs before any heat source is applied so there will be no Flue Gases exhausted thru the stack. During cold commissioning systems will be verified for completeness according to their piping and Instrumentation diagrams. Basic functionality will be verified e.g. manual actuation of dampers and flaps, alignment and rotation checks of motors and pumps etc. Electrical installations, instruments and measuring equipment will be checked and recalibrated if necessary. Mainly these are:

• Burner logic will be tested • interlocking with waste feed and emission limit values will also be tested • the CEMS will be calibrated • the main Interlocking will be tested

2.2 Phase 1: Refractory Lining Dry Out & Boil Out • No waste incinerated. • Temporary oil burner will be used • Emissions during this period will be due to the tuning of the temporary oil burners. • The emissions will be monitored by CEMS.

2.3 Phase 2: First Firing with Start-up and Auxiliary Burners • Steam blowing • No waste Incinerated. • Emissions to air will be monitored by CEMS and reported to the EPA. • The 1•1 stage of the 2-stage wet scrubber will be operational including atomization

of water.

2.4 Phase 3: First Firing with Waste and Steam circuit testing • Shutdown and start-up using oil burners, • Progressive increase in quantity of waste on the grate for basic adjustment of the

combustion. • All components of the flue gas treatment system will be operating.


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• Commissioning Turbine, Adjustments by open-circuit operation, switch-over from turbine-bypass to turbine and return, Turbine trip. Possibility of shutdown of the boiler,

• Adjustments at low load and nominal load, combustion and flue-gas cleaning • Synchronisation and Tests Turbine • Emissions to air will be monitored by GEMS and reported to the EPA

2.5 Phase 4: Optimization • Plant optimization, combustion control system, flue gas treatment, water steam

cycle and consumables • Test to achieve the Performance Demonstration Certificate (Phase 5). • The waste throughput capacity will be adjusted for turbine-generator testing and

control loop testing. This will include the testing of the emission control and monitoring system control loops.

• The 850C0 will be confirmed as per 4.2.1 of this document • Emissions to air will be monitored by CEMS and reported to the EPA in accordance

with license requirements

2.6 Phase 5: Performance Warranty Test • Demonstration of compliance with the contract conditions • Demonstration of compliance with the Performance Warranties and Performance

Guarantees. • Emissions to air will be monitored by GEMS and reported to the EPA.

2. 7 Phase 6: Commercial Operation • Continues Commercial Operation • Emissions to air will be monitored by GEMS and reported to the EPA

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3 Personnel and Organisational Structure During the commissioning period Contractor personnel will commission and run the plant with the aid of the subcontractors contracted to install the various subsystems. Covanta's Project Manager or his representative will liaise directly with the Contractor's commissioning staff on day to day issues and through the weekly commissioning meetings. Covanta will provide operations and maintenance staff in sufficient numbers during the commissioning phase. During this time the Covanta's staff will receive training on the equipment and assist with the commissioning.

3.1 Personnel

3.1.1 Contractor (HZI) The Contractor appointed commissioning manager shall take overall responsibility for the commissioning phase. He will also be responsible for the permit to work system, commissioning engineers and operation engineers.

The Contractor's commissioning staff are experienced with most having carried out several commissioning projects for the contractor. The staff selection for the job ensures that they have the necessary experience. In addition they undertake the Contractor's internal training including necessary practical and theoretical training for operating the systems/plant.

3.1.2 Covanta Personnel Operating personnel for the facility have been appointed and will be based on site. For details see Covanta and Contractor organisational diagram included in Appendix 1.

3.1.3 Control of Personnel A Contractor "Permit-to-Work" System will be in place to prevent accidental injury to personnel, damage to property, plant, environment, premises and product.


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Document Nr-Rev: 50052719 • 2.1 Hitachi Zosen lnova AG

4 Regulatory Requirements

4.1 EPA Permit Limits and Requirements The emissions limits and requirements for the Dublin WTE Facility are defined in the environmental pennit "EPA/Licence Register No W0232-01, Schedule B"

4.1.1 The emissions limits to air The emissions limits to air for each process line are provided in table 1. Note that this table and all associated conditions in the license must be considered together for a complete evaluation of unit performance.

Table 1: EPA/Licence Register No W0232-01 Schedule B. 1 emission limits

Flue Gas Species Units M Hourly Average Dally Average Periodic Note4

A B

Particulate Matter mg/Nm3 3(1'ote 1 1(1101• 1 10 -

TOC mg/Nm3 2(1'ote 1 leJNolt l 10 -

HCI mg/Nm3 60Nota I 1(1101• 1 10 -

HF mg/Nm3 4Noto 1 2 Noto 1 - 2

co mg/Nm3 100Noto2 - sa-•6 150Note3

SOxasS02 mg/Nm3 200Noto 1 50Nott 1 so - NO+ N02 (as N02) mg/Nm3 400-1 2wa1o1 200 -

NH3 mg/Nm3 - - -

N20 mg/Nm3 - - -

Cd and TI and their compounds mg/Nm3 - - 0.05 (total)

Hg and its compounds mg/Nm3 . - 0.05

Sb, As, Pb, Cr, Co, Cu, Mn, Ni and mg/Nm3 - - 0.5 V and their compounds

Dioxins and furans (as 1-TEQ) ng/Nm3 - - 0.1

Nata 1: None of the half·hour1y average valuH shall exceed any of the emission llmtt values set out In column A, or, 97% of the hall hourly average values over the year shall nol exceed any of the emission limit values set out In column B.

Note 2: 97% of the dally average value over the year does nol exceed the emission limit value.

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50052719 • 2.1 Hitachi Zosen lnova AG Powarin9 Tod:iy Protocttng Tamo,row ..___��

,COVANTA

Note 3. 95% of all measurements determined as 1 O·mmute average values shall not exceed the emission linlt value

Note 4: All concentrations referenced to 11 % 02, dry gas basis at O C, 1 atmosphere.

4.1.2 Emissions Limits to Water No emission from the installation shall be made to water (other than to sewer).

The emissions limits to water for the cooling water to the cooling water outfall is shown in table 2:

Table 2: EPA/Licence Register No W0232·01 Schedule 8.2 emission lututs to water

Parameter Emission limit Value

Volume to be emitted Max. In any one day 570'000m3

Max. rate per hour 14'040m3

Temperature rise A. T relative to intake 9.0°C

Total residual chlorine (as HOCL)) 0.5 mg/I and 0.2 mg/I (as 24 hour average)

4.1.3 Waste Water Disposal As per agreement with Irish Water, Waste water generated following rinsing and cleaning of boilers and pipes will be sampled, analyzed and disposed of at the Waste Water Treatment Plant (WWTP).

4.1.4 Notifications • During phases 1 and 2, the CEMS will be calibrated and monitored. • During phases 3 to 6, the CEMS will be continually monitored and recorded. • During phases 3 and 4 the EPA will be notified if maximums are exceeded. • During phases 5 and 6 normal permit reporting will be undertaken.

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4.2 Verification of Compliance with Regulatory Requirements The regulatory requirements will be tested during Phase 5. These tests will be carried out by an independent third party, who will be appointed later.

4.2.1 Post Combustion Chamber Temperature 8S0°C / 2s During Phase 4, the flue gas residence time and temperature requirement will be demonstrated in compliance with procedure attached to this document (appendix 3).

4.2.2 CEMS The CEMS has been purchased based on a design consistent with BAT and requirements of the Waste Licence (W0232-01 ). This will be verified once all equipment is installed. The homogenous flow for sampling in ducts will be tested during phase 3 and 4. The CEMS will be first qualified during workshop tests.

Functional verification of the software was completed during factory acceptance testing. The software will be verified again during the cold commissioning phase and the CEMS unit will also be calibrated with standard gasses.

Calculation and standardisation of the monitoring results is undertaken with the manufacturer's accredited software.

The CEMS supplier will provide warm and hot commissioning support and QAL2 testing is planned to be undertaken during the period of stable operation during phase 4 or 5.

4.3 Noise during Commissioning Noise monitoring will take place 3 month after commencement of the licence activity {coordinated by Covanta).


Project Name: Dublin WTE Facility -

1COVANTA I Hitachi Zosen, Title: Commissioning Plan I N Q VA '

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5 Waste Profile The quantity of waste delivered on site will vary during commissioning as the following activities are carried out:

• Steam blowing • Turbo-generator tests and combustion tuning • Load testing

Prior to the waste being delivered to plant, the fire fighting systems in the tipping hall and bunker will be fully operational:

• Sprinkler and water cannons in the bunker (incl. feed hopper protection and crane control window protection)

• Sprinklers in the tipping hall

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6 Reagent Delivery Profile & Storage

T bl 3 R t d r a e eagen e tvenes System Descriptions Description Storage

Quantity

Activated Carbon (PAC) One silo 1 x 200m3

Puffer Silo CA(OH)2 One silo 2 x 200m3

Quik Lime Cao One silo 1 x 200m3

Caustic Soda (50%) NaOH One tank 1 x 50m3

Fuel oil (Gasoil) One tank 1 x 100m3 I

Sodium Hypochloride One tank 1 x 50m3 I I

Hydrochloric HCI One tank 1 x 1m3

Ferric Chloride FeCl3 One tank 1 x 1m3

Sodium Meta One tank 1 x 1m3

Ammonia solution NH40H; 24.5% One tank 1 x 60m3 I

Trisodium Phosphate One tank 1 x 0.25m3 N83P04


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7 Residue Disposal From the first firing with waste all the necessary licenses and discharge consents for the facility will be in place. The disposal of residues will be as follows:

7.1 Boiler/Bottom Ash Bottom ash will be tested to determine its characterization, including TOG, and a separate protocol will be established and submitted to the EPA for agreement prior to removal off-site for recovery/ disposal.

7.2 Flue Gas Treatment (FGT) Residues Flue Gas treatment residues and boiler Ash will be conveyed from the process and stored in an on-site silo pending removal from the site subject to approval from the EPA. A protocol will be submitted under separate cover.

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Appendix 1 - Commissioning Organisation Diagram

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Appendix 3-Validation of Combustion Conditions

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Validation of Combustion Conditions

Method statement

Useful practically orientated method for monitoring and validating incinerator furnace operating conditions, with respect to minimum gas temperature and gas residence time

Compiled by:

TOV SOD lndustrie Service GmbH Business Area Environmental Engineering Westendstrasse 199 80686 Munich Germany

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Bernhard Thull

++49 89 / 5791 1480 [email protected]

REVISION COMMENTS DATE CHECKED BY 00 first edition 05 P.A,av2015 Th

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Contents Page

EC DIRECTIVE REQUIREMENTS (SOURCE: BAT, TECHNICAL REPORT P4-100fTR) 5

2 TEMPERATURE ISSUES (SOURCE: BAT, TECHNICAL REPORT P4-100!TR) 6 2.1 Rl!QUlREMENrS BAT GUIDELINE 6 2.2 USEFtn. PRACTICAll.Y ORIENTATED DECISION "WHERE, WHEN AND HOW" 6

2, 2. I Continuous furnace tempff'ature monitoring 6 2.2,2 Verification of minimum temperature 6

3 RESIDENCE TIME 7 3.1 REsIDl!NCEllME ISSUES (SOURCE: BAT, TECl!NICALREPOR.TP4-100ffR)

J.J.I Plugjlow J.J.2 Stirred reactor flow J.J.3 Realjlowsilllation

4 INTRODUCTION OF A PRACTICALLY ORIENTATED METHOD

7 7 7 7

8 4.1 EVALUATION 10 4.2 USUAL USED MEASUltlNG EQUIPMENT 10

4.2.I Suctionpyrometer IO 4.2.2 Thermo couples J J 4.2.3 IR camerm I J 4.2.4 Dxygt!tl measurement J J

4.3 DETERMINATION OF 1llE TEMPliRATUllE GRADIENT 11 4.4 CHECKING OF ras RETENTION TIME OF 1HE EXHAUST GASES 13

4.4. I Measuring Planu 13 4.4.2 Determination of the Retention Time 13

4.S CHECKING OF 1HE HOMOGENEOUS FASHION OF 1HE GASES PRODUCED AND TIIE AIR SUPPLIED 14 4.6 CHECXINOOFllll!OXYOENCONTENT 14

5 MEASUREMENT UNCERTAINTIES 15 S. l MEASuiuNO UNCERTAINTIES OF TitE MEAsUREMENT OF MINIMUM TEMPERATURE 16 S.2 CALCULATION OF 1HE MEASUlllNG UNCERTAINTY OF 1llE RETENTION TIMI! 17 S.3 CALCULATION OF MEAsURJNo UNCERTAINTY OF nm MEAsURJNO SYSTEM FOR 1llE MlNJMuM OXYGEN CoNTI!NT 20

6 SUMMERY 6.1 GUIDANCE 6.2 Rl!sIDENCE TIME 6.3 HOMOGENEOUS FASlllON 6.4 MINIMUM TEMPERAlUltE

APPENDIX 1: BRITISH GUIDELINE

APPENDIX 2: GERMAN GUIDELINE

Combustion conditions

22 22 22 23 23

25

26

Plgo3/31 �:IS-I/T-&IIJCIVl/21)15-05-05 RapanNo.OGZ3711,

Vienna Energy fll>m Waste Faclnty designed by Frtedensrelch Hundertwasser

Combustion Conditions

Compiled by: Bernhard Thull

Statement on Independence of TUV SOD lndustrie Service GmbH

TUV SOD lndustrle Service GmbH Is an Independent, Internationally recognised, engineering technology centre, which provides a range of skills and expertise to both Industry and govern

ment organisations. TUV SOD lndustrfe Service GmbH Is a member of the TOV SOD Group who are based In Munich with over 20,200 employees and a turnover of £1.6bn.

TUV SOD lndustrie Service GmbH is independent of manufacturers, service companies and end users. We offer complete impartiality in all our business deallngs. We are frequently called upon to by our clients to provide independent technical review, expert witness and due diligence ser

vices where complete confidentiality is respected and Integrity is of utmost importance.


TOV SOD lndustrie Service GmbH, Environmental Service

All rights reserved. No part of this publication may be reproduced, stored in retrieval system, or transmitted In any form by any means, electronic, mechanical, photocopying,

recording, or otherwise, without the prior written permission of TOV SOD lndustrfe Service GmbH (Germany)

Indemnity

TOV SOD lndustrie Service GmbH warrant that lnfonnaUon given In this report shall perform to the specification as detalled In the appropriate documentation but T\)V SOD lndusbie Service

GmbH shall not be liable for any claims, actions, demand or proceeding for any loss, damage, costs, charges or expenses whatsoever arising under any statute or at

common law, in connection with, or In consequence of, the use of the Information herein or any part thereof except that which cannot be lawfully excluded.

TOV SOD lndustrle Service GmbH WestendstraBe 199

80686 Miinchen Germany

Tel: +49 (0) 89 57911480

All Rights Reserved

Combustion canditlona

PogoS/lt �IS-I/T-MUC,,/2at� RlpOII No. 002l7I,

1 EC Directive Requirements (source: BAT, technical report P4-100/TR)

The 1989 EC Directive on New Municipal Waste Incinerators (EC 1989 a) contained mini mum requirements regarding furnace gas conditions. New plant were required to sustain a furnace temperature of at least 850"C for at least two seconds. Existing plant were covered at the same time by a separate Directive (EC 1989 b) and those that had major technical dif ficulties in meeting the new requirements were required to satisfy them when the furnaces were replaced.

An EC Directive on the incineration of hazardous waste (EC 1994) was transposed into UK law in 1997 and also contains minimum furnace conditions. However, a new Directive on the incineration of waste (EC 2000) is replacing the earlier Directives and will apply to both the incineration of hazardous and non-hazardous waste, (with exemptions for vegetable waste, radioactive waste and animal carcasses). The new Directive contains minimum furnace con dition requirements similar to those given In the earlier Directives, although a range of tem perature criteria is specified that depend on the nature of the waste stream.

Unfortunately, the wording of the various directives in respect of the furnace gas condition criteria (see Boxes A and B) Is ambiguous and this has led to problems when trying to demonstrate compliance.

BOX A: Article 4 of both 1989 Directives specifies that "the gases resulting from the combustion of waste must be raised, after the last injection of combustion air, in a con trolled and homogenous fashion and even under the most unfavourable conditions, to a temperature of at least 850"C, for at least two seconds, In the presence of at least 6% oxygen".

BOX B: Article 6 of the Directive on Incineration of hazardous waste reads, "incin eration plant shall be designed, equipped and operated in such a way that the gas result· Ing from the incineration of hazardous waste is raised, after the last Injection of comoue tlon air, In a controlled and homogenous fashion and even under the most unfavourable conditions anticipated, to a temperature of at least 850"C, as achieved at or near the Inner wall of the combustion chamber, for at least 2 seconds in the presence of at least 6% oxygen; if hazardous wastes with a content of more than 1 % of halogenated organic substances, expressed as chlorine, are incinerated, the temperature has to be raised to at least 11 oo·c·.

Article 6 of the new Directive on the incineration of waste has similar wording to the Directive on the incineration of hazardous waste In respect of furnace conditions, but It allows the competent authority to authorise the use of an alternative "representative" measurement point for the monitoring of the minimum temperature.


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2 Temperature issues (source: BAT. technical report P4·100ffR)

2.1 Requirements BATauldellne

The 1989 Directives are not specific as to where furnace temperature Is to be verified. How ever, the other two Directives at least give some indication on where verification should be carried out; for example, they mention the temperature minimum "as achieved at or near the Inner wall of the combustion chamber". The 2000 Directive also gives Regulators some latitude and allows the competent authority to authorise the use of an alternative "rep resentative" measurement point for the monitoring of minimum the temperature.

The Environment Agency has tried to give clearer guidance in guidance note S2 5.01, both on the temperature minima to be achieved by certain Incineration processes and on the loca tion of the measurement point. For example, it says that gas temperature at the point of exit from the secondary combustion chamber should be continuously measured and recorded. The Directives (and guidance note S2 5.01) are quite clear that furnace exit temperatures are to be measured, but the issues to be resolved are "where, when and how" these measure ments.

2.2 Useful practically ortentated decision "where, when and how"

2.2.1 Continuous furnace temperature monitoring

Where: The best place based on practical experience Is the roof of the first pass (after bu ming chamber) in the middle of the gas stream to the second pass.

When: Continues by using a suitable measuring equipment.

How: With thermocouples, at minimum two, better three distributed over the width of the first pass.

2.2.2 Verification of minimum temperature

Where: Ideal in the 2 second residence time level.

When: Under the most unfavorable conditions.

How: With water cooled suction pyrometer.

Combua11on conditions

lrdl.l!lde Sa rt Cl

3 Residence Time

3.1 Residence time Issues (source: BAT. technical report P4-100ITR)

For demonstrating compliance with the residence time criteria, the word "verification" is used In the Directives. However, It Is unclear whether verification can be based on design calcula tions and estimates, or whether only calculations based on actual measured data are air ceptable. It Is also unclear whether a minimum or an average residence time is being re ferred to. Consequently, a major obstacle for detennining the residence time of an incinerator is the lack of a comprehensive definition of this parameter. Clarification of the definition to be employed Is therefore essential to allow any verification procedures to proceed. If an inciner ator furnace combustion chamber Is considered as a reaction system (or vessel), then at least three situations can apply concerning residence time:

3.1.1 Plug flow

This is a simple hypothetical case in which there is no mixing and the gas velocity is uniform throughout the reactor vessel (see Figure 1a}. If a short discrete pulse of tracer gas were in jected Into the reactor, It would emerge from the high temperature zone still as a discrete pulse but after a short delay. The duration of the delay Is the minimum gas residence time (also called the plug flow time}. Under this model, the minimum gas residence time and the average residence time are the same. Verification by this method is relatively straightforward. The single gas residence time (RT) can be found by dividing the qualifying volume of the high temperature secondary combustion zone CVoscz) by the average gas volume flow-rate (Cle) through the secondary combustion chamber. Therefore, RT (In seconds)= Vascz* 3600/Cc Where Vascz is In m3 and Cle is In m3h"1)

3.1.2 Stirred reactor flow

The other extreme is also possible, i.e. a stirred reactor in which theoretical and instantane ous perfect gas mixing occurs. In this case, If a short pulse of tracer gas were Injected into entered the reactor then some would immediately emerge from the high temperature zone. The remaining tracer would only emerge slowly and would exhibit an exponential concentra tion decay I time characteristic. This Is because a small and ever decreasing concentration of tracer remains In the combustion chamber but this Is being progressively diluted by Incoming clean gas which contains no tracer. In this case, the minimum gas residence time would ap pear to be zero and verification would be Irrelevant.

3.1.3 Real flow situation

In the real situation there is partial mixing, and both plug and stirred reactor flow characteris tics will be present (see Figure 1 c). If a short pulse of tracer gas were Injected Into the vessel, the resulting concentration curve would be somewhere between the above two extremes. Af. ter a short delay a small amount of tracer would emerge from the high temperature zone. A short time thereafter, the concentration would rise to a maximum (this approximates to the average residence time) before the concentration slowly decays away.

Combustlan conditions

l'lgol/31 �IS-IIT-11UCo'41/20t� Ropcrt NG. OCl237lh

ConsequenUy, a distribution of residence times is now present which contain the characteris tic components of both plug and stirred flow. More correctly the system has a plug flow time and a stirred reactor time constant The distribution may be bell shaped or, more likely, it will be skewed. The shape of the distri bution will be Influenced by several factors, including the existence of dead spaces, recircula tion zones and high velocity channels. As a consequence, the interpretation of such a con centration I time response curve is dlfflcult. Different approaches are possible.

4 introduction of a practically orientated method

This protocol describes the procedure for demonstrate that the combustion chamber mini mum gas residence time (after the last injection of combustion air) and temperature in the combustion chamber are satisfied.

The residence time calculation protocol is based on the requirements from the sector guid ance note IPPC SS.01 combined with the requirements stated in German Federal Ministry of the Environment, Nature Conservation and Nuclear Safety Research Report 360 16 004 UBA-FB 001090 (the only available guideline regarding the verification of minimum combus tion conditions in the EC).

To demonstrate compllance, the temperature and oxygen concentration will be measured at the begin (after the last combustion air) and the top of the first pass vertical radiant heating section. Simultaneously, flue gas flow, temperature, humidity and oxygen concentration measurements will be carried out in the stack. The flow as measured in the stack will be cor rected to the temperature, oxygen concentration, humidity and density conditions pertaining to the first pass vertical radiant healing section and show the flow through the boiler for the residence time determination as a plug flow.

The guidance for the incineration of waste and fuel manufactured from or including waste sector guidance note IPPC SS.01 combined with the German method will be used for deter mining the residence time and temperature; the guideline can be found in Appendix 2. The methods will be based on the Review of BAT for New Waste Incinerator Issues and the German Federal Ministry of the Environment. Nature Conservation and Nuclear Safety Re search Report 360 16 004 UBA-FB 001090.

The furnace temperature will be measured at 2 cross section positions using water cooled suction pyrometer. The cross sections will be as near as possible to the beginning of after burning zone (BABZ) and the end of the after burning zone (EABZ).

Fixing of measuring planes

A measuring plane (1st measuring plane) shall be fixed at the end of the afterbumlng zone (above the supporting burners) for the respective approved operating states. The design data of the manufacturer or supplier are the basis for that A further measuring plane (2nd meas uring plane) shall be fD<ed where the beginning of the afterbumlng zone was defined. This measuring plane shall be fixed after the last supply of Incineration air on the basis of the de-


Pogt9/lt _...., ls-UT-MUClll /2!1ts.OS45 R,pcrl Na. D0237II

sign data of the manufacturer or supplier. The plane, where, first of all, we may proceed from a uniform mixing of the incineration gases with Incineration air is defined as the beginning of the afterbumlng zone. Owing to the existing local conditions Insignificant deviations of the position of the 2nd measuring plane from the actual beginning of the afterbuming zone are possible. This will be compensated by respective conversions.

Measuring equipment

According to the present state of the art, exclusively water-cooled suction pyrometers with a ceramic screen shall be used for checking the minimum temperature. A sufficiently high suc tion speed shall be set. At least one measuring instrument shall be used at the same time for each measuring axis fDCed. The thermocouples used in the suction pyrometers shall corre spond to the PTB requirements 14.2 of December 2003.

Fixing of the measuring points for grid measurement

Temperature measurement is carried out as grid measurement at least on two measuring axes in the Incineration chamber. The measurement section shall be subdivided into two equal areas with the measuring points being in their centres of gravity. The number of meas· urlng points Is 1 per approx. 2 m2• A uniform distribution of the points over the measurement section is to be ensured.

Schema of the measuring levels and Reference points

beginning of after burning zone BABZ ... end of after burning zone EABZ

J - plane of auxUlary burner ABRP s .. measuring plane 2 MP2 MPl • measuring plane 1 MP1 operating measuring plane OMP (MP2·BABZ) �BABZ {MP1 • MP2) AH1,2 (MP1 • BABZ) AH BABZ-EABZ H width depth cross sectional area A

4.1 Evaluation

For each fixed measured point a conversion of the single 10-minutes average values will be made over a temperature gradient on a fictitious measuring plane, which corresponds to the plane in which the retention time of 2 seconds is kepl Use multiple traverse measurements of gas temperature to identify (or confirm) the lowest gas temperature location at, or shortly after, the qualifying secondary combustion zone. Confirm that 95% of the one-minute mean temperatures (continuously monitored at the iden tified lowest temperature location over a period of at least one hour) exceed the stated mini mum temperature requiremenl

4.2 Usual used measuring equipment

4.2.1 Suction pyrometer

measuring method guideline probe suction speed of suction manufacturer sensor type: measuring Instrument manufacturer type measuring range measuring uncertainty

thermoelectric VOi 3511 part 5 suction pyrometer with a bipte ceramic shield water-cooled compressed air ejector ca. 80 mis TOV lndusbie Service GmbH NICr-NI-Thermocouples K, class A (calibration by manufactory) data acquisition and control system .Trendows XP" E Kirsten Trendows XP, Version 3.8.41.2 - 210 to 1360 ·c ±5"C

For the elements put in the suction pyrometer the same requirements are valid as for the in stalled instruments.

� Suction Pyrometer

CombusUon c:ondtians

1'1\1111131 -IS-l/1'-MUCM>llllt Rapalt Na. 002371h

4.2.2 Thermo couples

measuring method guideline probe

manufacturer sensor type: measuring Instrument manufacturer type measuring range measuring uncertainty

4.2.3 IR cameras

measuring method guideline probe manufacturer sensor measuring Instrument manufacturer type measuring range measuring uncertainty

thermoelectric VDINDE 3511 part 1 thermo couple calibrated against suction pyrometer with a triple ce ramic shield water-cooled BauerGmbH Nier-NI-Thermocouples K, class A (calibration by manufactory) data acquisition and control system .Trendows XP" E Kirsten Trendows XP, Version 3.8.41.2 - 210 to 1360 ·c ±5 ·c

infrared VDINDE 3511 part 4 camera Heitronlcs GmbH IR sensor 4, 7 urn data acquisition and control system .Trendows XP" E Kirsten Trendows XP, Version 3.8.41.2 - 210 to 1360 •c ±S"C

4.2.4 Oxygen measurement

test object measuring method measuring Instrument manufacturer measuring range measuring uncertainty

oxygen electrochemical analysis of gas 02- measuring equipment type KE-25F-3 TOV SOD lndustrie Service GmbH I FIGARO 0-25,0Vol. % ±0,2Vol.-%

4.3 Determination of the Temperature Gradient

Grid measurements for the licensed operating states will be carried out on the same operat ing state of the plant on the measuring planes 1 and 2 at the same time. The conditlons of the measurements are described before. The average temperature differ ence �T 1,2 between plane 1 and 2 for the respective operating state ls formed out of the measured values.

1 • AT..2 =- L(Tu-T.,) n ,..


l'lgo1ZU1 lllrfll....na: IS-IJT-MI.IC"Al/2111- Ripllll Na. OG2311h

T 1 i -average value of the temperature grid measurement on plane 1 T 21 - average value of the temperature grid measurement on plane 2 n - number of the temperature grid measurements on plane 1 or. 2 (n = 6)

The temperature gradient To can be determined out of the temperature difference fl T 1,2 and the difference in altitude fl H1,2,

d7;,2 TG=--

Mli,2

- average temperature difference between plane 1 and 2. - distance between plane 1 and 2. - average temperature gradient.

On supposition of a linear course of temperature between plane 1 and 2, or beyond it, the average temperature for each plane In the combustion chamber is determined by that. In verse the plane in the combustion chamber, in which the minimum temperature of the ex haust gases is barely kept, can be determined arithmetically.

1 • 7;=-�);,

n /:I

AH =(T. - T. /,Hu T I M dT. 1,2

• Average value of the temperature grid measurements measuring plane 1 - Minimum temperature of the exhaust gases (850 •c) - Distance between measuring plane 1 and 2 - Distance between the plane in the combustion chamber, on which the

exhaust gases still keep the minimum temperature on an average, and measuring plane 1.

CombusUon condillons

P1g113/31 -IS-IJT-MUC/lll/2!)1S,05,!JS Rapa,tNo. 00237111

4.4 Checking of the Retention Time of the Exhaust Guea

According to DIRECTIVE 2000/76/EC a retention time of the exhaust gases of 2 s shall be checked by measurements. For the detennination. the plug flow method Is the practically ori entated decision.

4.4.1 Measuring Planes

Volume flow and boundary parameters belonging to It measured on a suitable measuring plane In clean gas. Best place, the exhaust gas flow shall be measured in the stack and then, recalculated to the first pass conditions. The average temperature, oxygen content, humidity and the pressure for the conversion measured on the planes 1 and 2 In the after burning zone.

4.4.2 Determination of the Retention Time

To detennlne the retention time of the exhaust gases in the range above the minimum tem perature, the exhaust gas volume flow will be measured and shall be converted to the ex haust gas conditions In the after burning zone. The measurement of the volume flow shall be taken under consideration of the EN ISO 16911-1 lsochronic to the grid measurements to prove the minimum temperature. When cal culating the retention time the flow conditions in the after burning zone are taken as Ideal plug flow. According to the proof of the assumption of an Ideal plug flow for the calculation of the reten tion time the RW TOV has drafted a unpublished report. so far by order of the president of German Regional Council In Monster from the 14.07.1987. To determine the retention time of the stack gas experimentally in the after burning chamber a noble gas tracer had been injected In 2 control planes at the gravity centre of the planes, which run through the after burning zone together with the exhaust gases. At the leaving of the last control plane the exhaust gas flow had been led to a transportable mass spectrome ter by a partial sampling In the measuring grid. The retention time of the tracer had been de termined out of the time difference between Injection and the time of the signal rise at the mass spectrometer (corrected on the response time). The calculation, as It is described in this case, had also been carried out and compared with the tracer gas test. The calculation of the retention time on the assumption of an Ideal plug flow can be advo cated because of the results. The parameters like 02, pressure and humidity In the after burning zone, which are neces sary for the conversion, have to be recorded by measurements. The temperature taken as a basis for the conversion is the average value from the tempera ture at beginning of the after burning zone T BABZ and the minimum temperature.

Under consideration of the geometric conditions and the converted volume flow, It Is possible to calculate the retention time In the after burning zone using the following formula.

Combustion condlUcns

Plgo 14/31 -IS-UT-Muc.1hl2015*f5 Report No. 1111231111

with: . VF11 -average value of volume flow of the exhaust gases In the combustion

chamber (at operating state, humid) at TllNIIZ + TM 2

- distance between beginning of after burning zone and plane 1 - cross section area combustion chamber (for A= const.) - retention time of exhaust gases above minimum temperature - distance between the plane In the combustion chamber at which the

exhaust gases still keep the minimum temperature on average and plane 1

Criterion of quality Is a retention time of 2 seconds.

4.5 Checking of the Homogeneous Fashion of the Gases Produced and the Air suppHed

AB H Is not possible to determine a homogeneous fashion wtth standardised methods, as such exists for the minimum temperature and the oxygen content. a pragmatically way to de termine the conditions shall be taken. We may proceed from a uniform mixing of the Incineration gases with Incineration air If the temperature In each measuring point in the two measuring planes and thus over the whole afterbumlng zone Is maintained and the lndMdual values for the volumetric oxygen content do not deviate more than 50 of hundred from the volumetric oxygen content for the respec tive network.

4.6 Checking of the Oxygen Content

Usually the oxygen measurement is carried out simultaneously with the temperature meas urement via suction pyrometers so that measuring plane and measuring points will be Identi cal. Measuring plane, measured points, calculation of the measured values and essentially also the measuring range are identical to those of the measurement of temperature.

Requirements: In many situations, the BAT oxygen concentration is likely to be about 6%.

Combustion comfillons

Pogo 15131 �15-UT-MUC/11/201- Rtpart Nu. 00237111

5 Measurement uncertainties

The following example shows the theoretical maximum of uncertainties for measurements In the after burning chamber. The real uncertainties will be calculated after the measurements under care and attention of the local conditions at site.

When measuring the temperature the measuring uncertainty is determined and calculated as follows shown es an example.

Accidental component of the measuring uncertainty

The more measurements are carried out the smaller becomes the accidental component of the measuring uncertainty of the average value of repeated measurements. The number of tests is determined by convention. In the present case the accidental component can be re garded as very small and therefore be Ignored.

Well-known systematic component of the measuring uncertainty

Exactly well-known systematic measuring uncertainties are not known

Unknown systematic component of the measuring uncertainty

The measuring uncertainties have to be assigned to this group but It Is necessary to distin guish the two:

a, Measuring uncertainties caused by unknown systematic deviations, which can be treated arithmetically like accidental deviations.

b, Measuring uncertainties caused by unknown systematic deviations, which have to be treated by all means like systematic deviations.

Addition of measuring uncertainties

For a temperature measuring system, the respective uncertainties are squarely added if they can be treated like accidental ones.

Deviations as specified to a, as well as to b, are known In the present case. The deviations as specified to b, have the same direction of action and are first of all added linearly. The result Is treated like an accidental deviation and added squarely.

Combullion conditions

5.1 Measuring Uncertainties of the Measurement of Minimum Temperature

Uncertainties specified to a,: Precision of measuring of the thermocouples type K (Weights and measures regulations 14.2 PTB)

Uncertainty by non-homogeneity of material (VD13511 part 1)

Uncertainty by the reference junction correction (VDI 3511 part 2)

±6°C

±5"C

±3"C

Uncertainty by analogue/digital conversion (data acquisition and control system (Estimated, ± 0,5 % of the final value of the measuring range) BAD ± 4 •c Uncertainty by temporary variable measuring values (systemic Inertia) (VOi 3511 part 2) es

Uncertainty by the spatial situation of the measuring points

Uncertainties specified to b,: Drift dependence of the element of the temperature (Weights and measures regulation 14.2 PTB)

±5"C

±5"C

+ 3 "C/a

Radiation error by ceramics in dependence on the diameter of the element (VDI 3511 part 5, dependent on the temperature) es, + 5 •c

Increase of temperature In the air during the suction (VDI 3511 part 5, dependent on the speed)

Calculation of the measuring uncertainty

e=�62 +52 +32 +42 +52 +52 +(3+5+2,5)2

The measuring uncertainty of the definition of the minimum temperature amounts to ± 12,5 ·c.


eA + 2,s ·c

Plgot1131 -:IS-llT-MUC111/201� Rlport No. OG2J71h

s.2 Calculation of the Mt1suring Uncertainty of the Retention time The uncertainty, relative to the retention time, is based on the measuring uncertainties of the single measured values which enter into the calculation .To each of these values a range of uncertainty has to be assigned. For those values which are measured In the clean gas the confidence range statistically found out by calibration was used. For those values measured In the after burning zone: the minimum temperature and the minimum content of oxygen, there are enclosed separate uncertainty calculations whose result Is taken Into consideration In the present case. The uncertainties for all further values are known (for example literature etc.) or have to be estimated. The evaluation was, among other things, carried out according to the following guidelines: General technical measuring terms DIN 1319 part 3 08/83 General technical measuring terms DIN 1319 part4 12/85 Progression of error limits VDENDI 2620 part 1 01/73 Progression of error limits VDENDI 2620 part 2 01/73 The single measuring values which enter into the calculation are listed in the following.

-Clean Gas volume flow after boiler temperature after boller pressure at the measuring point content of moisture after holler oxygen content after boiler

·After Burning Zone volume flow of stack gas mean temperature NBZ mean oxygen content NBZ pressure at the measuring point content of moisture

-Geometry area A height Mi height �HT

-Symbols G: limits of error X1, x2: measured values A: area H: height Ht difference In altitude VFR.: volume flow In m•Jh t: temperature of stack gas In •c p: ambient air pressure In hPa f: moisture of exhaust gas in Vol. % 02: mean oxygen content of the exhaust gases in Vol. %

Combuation conditions

!'Igo 11131 -..,,.,, ISUT-MUCIIIII !fJ15.e45 Rlpar1 No. OOZl71h

ltdU!llla Setvce

Measuring Uncertainty of the Retention Time

Statistic Result of the Error Limit G when Connecting by means of Addition:

Relative Statistic Result of Error Limit G when Connecting by means of Multiplication:

Relative Statistic Result of Error Limit G when Connecting by means of Division:

Conversion Formula of Volume Flow;

Standardization:

. . v .... V Non110, = 273, 15 + t.1013• 100 • 21 ---- -- --- ---

273,15 p 100-/ 21-0z,

Destandardization:

;, • .,,. =V .213,lS+t .10n.�._2_1_ Nomi,,, 273,15 p 100- f 21-01

Formula of Calculation of the Re�ntion time tVz

t"' = A•(lf_ + H,) VFII

Error limit of the Volume Flow Measuring:

Combustion condllionl

P1g1t9/3t Rlrfnna'Dllll:l$,llf-MIJCIVll20t Rlport Na.OOZ37tll

frdimle S.NCI

Calculation of Measuring Uncertainty of the Retention Time

Error Limit of the Measurement of Temperature:

IG I= 273, 15 +(t + Ill) _ 273, 15 + 'I ' 273, 15 273, 15

Error Limit of the Measurement of Pressure

IG 1=1�-10131 p p+l!,.p p

Error Limit of the Measurement of Moisture:

IG 1-1____!.QQ_ 100 I I - 100 - f 100 -{f + 4/)

Error Limit of the 02 Measurement:

IG I I 21 21 I o, = 21-02 - 21-{02 +A02)

Error Limit of Planimetry

Error Limit of Altitude Measuring

Relative Statistic Result of the Error Limit of the Retention Time Gvz

The measuring uncertainty for the determination of the retention time Is essentially depend· ent on the range of tolerance of the measurement of the volume flow. The mean error of the retention time amounts to less than 10 % (less than 0,2 sec.) of the measured value.


P,,go211131 -ISUT�l2111HS45 Rlpmt Na. 00237111

lrdlllllle &ervc:e

5.3 Calculation of Measuring Uncertainty of the Measuring System for the Minimum Oxy gen Content

The measuring uncertainty In measuring systems for the minimum oxygen content is deter mined and calculated as follows.

Accidental component of the measuring uncertainty

The more measurements are taken the smaller the accidental component of the measuring uncertainty of the average value of repeated measurements gets. The number of tests is de termined by convention. In the present case the accidental component can be regarded as very small and therefore be Ignored.

We/I-known systematic component of the measuring uncertainty

Exact well-known systematic measuring uncertainties are not known.

Unknown systematic component of the measuring uncertainty

The measuring uncertainties have to be assigned to this group but It is necessary to distin guish:

a, Uncertainties caused by unknown systematic deviations which can be treated arithmeti cally like the two:

b, Uncertainties caused by unknown systematic deviations which have to be treated like sys tematic deviations by all means.

Addition of measuring uncertainties

For a measuring system for the minimum oxygen content the respective uncertainties are added squarely If they can be treated as accidental ones. Deviations as specified to a, as well as to b, are known in the present case. The deviations as specified to b, have the same direction of action and are first of all added linearly. The result Is treated like an accidental deviation and added squarely.


PogtZl/31 lllrffflnc:en)a: IS-l1T ./ollJCIOI I 2015-05-05 Rlporl No. OOZ371h

lrdll!lde Sert Cl

Measuring Uncertainties of the Definition of the Minimum Oxygen Content

Measuring uncertainties specified to a,:

Precision of measuring of the analyzer (Probation guideline)

Uncertainty by calibration gas mixture (Certification)

:t0,20Vol. %

:t0,06 Vol.%

Uncertainty by analogue/digital conversion (data acquisition and control system) (statement of the constructor, :t 1% of the final value of the e"° :t 0,25 Vol.% measuring range)

Uncertainty by temporary variable measuring values (systematic Inertia) (Dead-time and 90%-time) es :t 0, 10 Vol. %

Uncertainty by local situation of the measuring points (Deviation of the measuring grid x) :t 0,60Vol. %

Drift dependence of the analyzer from the temperature (type approval guideline)

Uncertainties specified to b,:

After burning effect In the non-cooled part of the probe (Catalytic after burning of CO (tube furnace effect))

Calculation of the measuring uncertainty

�2 2 2 2 2 2 2 e=e, +eu +em +es +eL +e0 +ew

e= �0,22 + 0,062 +0,252 +0,12 +0,62 +0,12 +0,052

:t 0, 10 Vol.%

� - 0,05 Vol. o/o

The measuring uncertainty of the definition of the minimum oxygen content amounts to :t 0, 7 Vol. %


lr�Sertce

6 Summery

&.1 Guidance

This practically orientated method Is based on the requirements given In the guidance for the Incineration of waste and fuel manufactured from or Including waste, sector guidance note IPPC SS.01 combined with the requirements from the guideline "German Federal Ministry of the Environment, Nature Conservation and Nuclear Safety Research Report 360 16 004 UBA-FB 001090"

e.2 Residence time > Measure worst case gas residence time using a time of ffight method.

Two residence time measurement approaches are recommended. The first Is based on an assumption of "plug flow" and measures the residence time by moni toring the mean gas flow rate leaving the system. As plug flow is assumed then the mean and minimum gas residence times are considered to be Identical. A suggested procedure Is described which measures the mean gas flows In the stack or boiler ouUet, and through sub sidiary measurements this can be related to the mean furnace residence time at mean fur nace gas conditions. The second approach assumes that some stirring occurs within the furnace chamber and us es a time of flight determination. Two measurement methods are recommended and de scribed. The first uses an Inert gas pulse Injection, with mass spectrometer detection of the response signal, which Is compared to a reference pulse. The second uses a pseudo random binary pulse perturbation, in which propane Is injected and the response signal detected by a fast carbon dioxide cross duct detector. Cross correlation techniques are used to compare the Input and response slgnals. Such methods can measure residence time distribution, In cluding minimum mean and peak values.

Method: time of flight determination

Requirements: Time of flight methods could be used at some existing plant but its use could become more difficult. This arises because of the need to provide additional access points In fumace chambers and could prove difficult and cosUy for existing Installations.

Benefits: Determination of retention time under assumes that some stirring occurs within the furnace chamber.

Disadvantage: Determination is time Independent from the temperature measurements. There is no way to make calculations on the same time base. For a proper calculation of temperature In the 2 second level a time synchrony determi nation of temperature and retention time is necessary but not possible by using the flight of time method.


l'lgt 23/ ll -..nlm: 18-UT-MUClll/201- Raport No. llOZ!7UI

lrdLIIIJlaS.ttce

Method: plug flow

Requirements: The plug flow method Is usable for all plants with a continuous or discon tinuous measurement of exhaust gas flow and a set of openings In the first pass.

Benefits: Determination of retention time synchronously to the temperature and oxy gen measurements. The temperature can be converting in the 2 second level using the same time base for all measurements.

Disadvantage: The method do not respect any stirring occurs within the furnace chamber. Nevertheless, this is the more conservative method.

Selected method as base of method: plug now

Execution:

Advantage:

Conformity:

The plug flow method Is the recommended method for all plant with suit able measurement levels and openings. Determination of retention time synchronously to the temperature and oxygen measurements Is possible. The temperature can be convert In the 2 second level using the require ments stated In German Federal Ministry of the Environment, Nature Conservation and Nuclear Safety Research Report 360 16 004 UBA-FB 001090.

The method is more conservative and also used as best practise In the most EU countries.

Complies not exactly with the guldellne IPPC 55.01. The selected method for determination off retention time must be confirmed by the environ mental agency. (This method are accepted by most of the new plants In UK)

8.3 Homogeneous fashion

There is not any difference between the German und the UK method In the judgement.

8.4 Minimum temperature )> Use multlple traverse measurements of gas temperature to Identify (or confirm) the

lowest gas temperature location at. or shortly after, the qualifying secondary combustion zone.

Selected method:


multiple traverse measurements of gas temperature and oxygen contend time synchronized with the retention time

P�2l!ll llm!l111aollll!I SJJT MUC'II l:lOIS-Or:l!> flnp::r1Mo CCl!l�

Execution.

Conformity

The furnace temperature will be measured al 2 cross section positions using suction pyrometers The temperature measurements at each location will be taken In a traverse for 10 minutes each measuring point in the centre of equal areas The temperature measurements will be carried out using one pyrometer for each opening at the same time.

Complies with the guidefine IPPC SS.01

, Conflnn that 95% of tire one-minute mNn temperatures (continuously monitored at the ldenfffled lowest temperature locatlon over a period of at least one hour) exceed the stated minimum temperature requirement.

Selected method

Execution:

Conformity:

multiple traverse measurements of gas temperature and oxygen contend time synchronized with the retention time

furnace temperature will be measured 3 Umes each point at 1 O minute Intervals. After the grid measurement the lowest point will be indicated and measured for one hour. That means three times the confirmation over the performance lest period from 8 hours

Complies with the guideline IPPC 85.01

, Use auction pyrometers to measure temperaturu (acoustic pyrometers or shielded thermocouples may only be used If calibrated against suction pyrometers.

Selected method

Conformity:

we uae water cooled suction pyrometer with a triple ceramic shield and compressed air for the operating of suction.

Complies with the guideline IPPC 55.01

l,. In many sltuatlon.s, the BAT oxygen concentration is likely to be about 6%.

Selected method:

Conforrmty

Suitability tested oxygen analyzer. Simultaneous measurement to the minimum temperature In the same measuring levels and on the same measuring point.

Complies with the guideline IPPC S5.o1

Business Area Environmental Engineering

.�L:---1 Combustion candrtlons

Plga25131 �:IS-l/T-MUC/1111201� Rlparl Na. 00237111

Appendix 1: British guideline

Indicative BAT requirements combustion validation

Sector Guidance Note IPPC SS.01

Measure worst case gas residence time using a time of flight method.

Use multiple traverse measurements of gas temperature to Identify (or confirm) the low est gas temperature location at, or shortly after, the qualifying secondary combustion zone.

Confirm that 95% of the one-minute mean temperatures (continuously monitored at the Identified lowest temperature location over a period of at least one hour) exceed the stat ed minimum temperature requirement.

Use suction pyrometers to measure temperatures (acoustic pyrometers or shielded ther mocouples may only be used if calibrated against suction pyrometers.

• The gases resulting from the combustion of non-hazardous wastes must be maintained at above 850 •c for at least 2 seconds (WID Article 6(1)). The gases resulting from the combustion of hazardous wastes with a halogen content greater than 1 % (as chlorine) must be maintained at above 1100 •c for at least 2 seconds (WID Article 6(1 )). WID Arti cle 6(4)

• There should be at least 6% oxygen In the combustion gases at existing Installations sub ject WID does not specify oxygen concentrations for the combustion gases. It should however be noted that BAT requires sufficiently oxidizing conditions at the final combus tion stage to provide for good combustion, and the Operator will be required to demon strate this in his application. In many situations, the BAT oxygen concentration is likely to be about6%.

Combultlon condlllans

Plgo21f31 Rlrlnncatl11t· 15-UT-MUCfdl I 2015-45-05 R,pr1 Ho. OCl2l7II

Appendix 2: Gennan guideline

Ra port: PJr Pollution Prevention Manual on Emission Monitoring ENVIRONMENTAL RESEARCH OF THE FEDERAL MINISTRY OF THE ENVIRONMENT NA TURE CONSERVATION AND NUCLEAR SAFETY; Research Report 360 16 004, UBA-FB 001090

Annex E, page 178 ff

E 4 Checking of Incineration conditions, according to § 13 subparagraph 1 In conjunction with § 4 subparagraph&. 2 and 3 or 6 and 7 of the 17th Federal lmmlsslon Control Ordi nance

E 4.1 Checking of the minimum temperature

E 4.1.1 Fixing of measuring planes

A measuring plane (1st measuring plane} shall be fixed at the end of the afterbuming zone (above the supporting burners) for the respective approved operating states. The design data of the manufacturer or supplier are the basis for that A further measuring plane (2nd measuring plane} shall be fixed where the beginning of the afterbumlng zone was defined. This measuring plane shall be fixed after the last supply of incineration air on the basis of the design data of the manufacturer or supplier. The plane, where, first of all, we may proceed from a uniform mixing of the incineration gases with incineration air is defined as the beginning of the afterbumlng zone. Owing to the existing local conditions Insignificant deviations of the position of the 2nd measuring plane from the actual beginning of the afterbumlng zone are possible. This will be compensated by respective conversions.

E 4.1.2 Measuring equipment

According to the present state of the art. exclusively water-cooled suction pyrometers with a ce ramic screen shall be used for checking the minimum temperature. A sufflclently high suction speed shall be set. At least one measuring Instrument shall be used at the same time for each measuring axis fixed. The thermocouples used In the suction pyrometers shall correspond to the PTB requirements 14.2 of December 2003.

E 4.1.3 Fixing of the measuring points for grid measurement

Temperature measurement is carried out as grid measurement at least on two measuring axes in the Incineration chamber. The measurement section shall be subdivided into two equal areas with the measuring points being in their centres of gravity. The number of measuring points Is 1 per approx. 2 m2• A uniform distribution of the points over the measurement section Is to be en sured.


E 4.1.4 Processing of measured values

Electronic recording of measured values shall be carried out with a sampling frequency of at least 0.1 Hz {corresponding maximally to 10 s between two subsequent measured values). The measured values shall be compressed to 10-minute means.

E 4.1.5 Acceptance measurement

To prove that the minimum temperature required {850 or 1100 "C) is kept the following number of network measurements according to E 4.1.3, is required in the case of a holler being dirty as a result of its operation: - undisturbed continuous operation {rated load): 3 grid measurements over a total period of at

least 3 hours - deviating operating states {e. g. partial load in the event of the operating state being approved):

3 grid measurements over a total period of at least 3 hours - starting without charging with starting materials {acc. to§ 4, subparagraph. 5, no. 1): 1 grid

measurement for the final state of the heating phase over a period of approx. 1 hour {with regard to E 5.3.1 ).

For each measuring point fixed according to E 4.1.3 the Individual 10-mlnute means are con verted to a fictitious measuring plane which corresponds to a retention time of 2 seconds {mini mum retention time) through the temperature gradients determined according lo E 4.2.2. The evaluation aiterion is the minimum temperature in each measuring point fixed according to E 4.1.3 as a 10-minute mean for each individual measurement.

E 4.2 Checking of the retention time of the flue gases

E 4.2.1 Measuring planes

To determine the retention time during which the minimum temperature has to be maintained two measuring planes (1st and 2nd measuring planes) are used {comp. E 5.1) E 4.2.2 Determination of the temperature gradient Network temperature measurements (always 3 network measure ments) shell be carried out et the same time In the 1st and 2nd measuring planes with the oper ating state of the Installation being the same. The basic conditions of the measuring equipment are given analogously to E 4.1. {The measur ing results obtained on the 1st measuring plane may be used for checking the minimum tem perature according to E 4.1 ). From the measured values the average temperature difference AT 1,2 between the 1st and the 2nd planes is calculated for the respective operating state {s. a. E 4.1.5).

T11 mean of network temperature measurement in the 1st measuring plane T 21 mean of network temperature measurement in the 2nd measuring plane n number of network temperature measurements in the 1st or 2nd planes.

Comblllllon condttlons

lrdU!llla Ser, Cl

Assuming a linear march of temperature between the 1st and 2nd temperature planes or beyond that the mean temperature In the Incineration chamber Is determined for each plane, on the other hand, the plane In the incineration chamber where the minimum temperature of the flue gases Is Just kept may be calculated.

(T. -T. )x Mu l JI. �Ti.2

1 ll

Tl= -LT1; ll ,,.I

The mean temperature gradient is calculated from AT1,2 / AH 1,2,

T1 mean of the network temperature measurements in the 1st plane TM minimum temperature of the flue gases t.11,2 distance between the 1st and the 2nd measuring planes Air distance between the plane in the incineration chamber where the flue gases Just keep

the minimum temperature on average and on the 1st measuring plane.

E 4.2.3 Determination of the retention time

To determine the retention time of the flue gases in the area above the minimum temperature the flue gas volume flow (e. g. at the boiler end) shall be measured and converted to the flue gas conditions In the afterbuming zone. The volume flow Is measured with regard to DIN EN ISO 10780 (issue of 1994) simultaneously with the network measurements being carried out to check the minimum temperature. When calculating the retention time the behaviour of an Ideal plug flow is assumed. The temperature on which the volume flow shall be based Is the mean from the temperature at the beginning of the afterbuming zone T BABZ and the minimum temperature. Tak ing the geometric conditions and the volume flow Into account the retention time in the after buming zone is calculated.

mean of the volume flow of the flue gases in the incineration chamber (In operation, moist)

at

TIWz+Tu 2

distance between the beginning of the afterbuming zone and the 1st measuring plane cross-sectional area of the incineration chamber (for A= const.) retention time of the flue gases above the minimum temperature.

The evaluation criterion is a minimum retention time of 2 seconds.


Plgo29/ 31 _, 1$1JT-MOOlh/2111iHJ5-05 Rlpr1 No. 002371h

E 4.3 Uniform mixing

E 4.3.1 Determination of a uniform mixing

We may proceed from a uniform mixing of the Incineration gases with incineration air If the temperature In each measuring point In the two measuring planes and thus over the whole afterbumlng zone Is maintained and the indMdual values for the volumetric oxygen content do not deviate more than 50 of hundred from the volumetric oxygen content for the respective net work.

E 4.3.2 Measurement of the oxygen content

Usually the oxygen measurement is carried out simultaneously with the temperature measure ment according to E 4.1 via suction pyrometers so that measuring plane and measuring points will be Identical.

E 5 Functional testing and callbratlon of measuring Instruments for the conUnuous monitoring of the minimum temperature according to § 10, subparagraph 3 In con junction with§ 11, subparagraph 1, no. 3 of the 17th Federal lmmlsslon Control Or dinance

E 5.1 Functlonal testing

Functional testing of instruments for measuring the minimum temperature shall be carried out every year as described hereinafter. • plausibility testing of the readout of measuring instruments according to the checkpoint

method (Ice point In ice-water mixture according to VDINDE 3511, sheet 2) or alternatively: checking by means of a comparison element either alternately in the places of Installation of the measuring Instruments or in other appropriate measurement apertures (basis: 1-hour mean)

- checking of the transmission of measured values with a constant supply point - checking to recognize an element faRure caused by the electronic evaluation system. For this

purpose each measuring instrument shall be disconnected. - checking of the measuring instruments as to their construction and fitting position as

compared with the time of the last calibration.

E 5.2 Calibration

The calibration shall be conducted at least every three years.

E 5.2.1 Determination of the end of the afterbuming zone

The incineration chamber temperatures are determined according to E 4.2.2 (averaging) always at full load and In further approved operating states. For the operating state "starting" attention Is

Combu.Uon conditions

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additionally drawn to 5.3.1. For this purpose, at least six network measurements (at full and par tial loads) shall be carried out simultaneously in the 1st and 2nd planes. For the periods of these network measurements the mean values measured by operational measuring Instruments shall be determined In a way that at least 6 data sets of network measurements - operational meas urements - will be available. Assuming a linear temperature march between the 1st and the 2nd planes or beyond them thus the end of the afterbumlng zone (defined as a plane In the Incinera tion chamber where the minimum retention time of 2 s is exactly maintained} may be determined (comp. Fig. E 2}.

A minimum retention time distance between the end of the afterbumlng zone plane and the 1st measuring plane mean temperature difference between the 1st and the 2nd measuring planes

1 6 AT1,2 = - L (Ti; - Ti,)

6 ,-1 T 21 mean of the network temperature measurement In the 2nd measuring plane T 11 mean of the network temperature measurement in the 1st measuring plane t,J.1,2 distance between the 1st and the 2nd measuring planes

The mean temperature gradient is calculated from /:J,.T1.it,J.1.2•

E 5.2.2 Calibration procedure

The mean temperature difference and Its lower confidence limit for the converted temperature values measured by network measurements in the 1st measuring plane is calculated with the aid of the measured operating temperature values: T ABZJ mean of the network temperature measurement I In the 1st measuring plane

converted to the plane at the end of the afterbuming zone (2 s retention time) T 81 mean of the operating temperature measurement i for the period of network

measurement AT1,2

T ABZl = Tit ---Ill ABZ Af.1,2

Determination of the confidence limit t,,_2 xs

VB= ..Jn The connection T ABZJ = f (T 81} shall be determined by linear regression. t.,.2 threshold value oft distribution (for N = n') S spread around the straight regression line


Pogo 31/31 �: 15-UT-M\JCIIII 2015,05,05 Rlj>Ol1No.D02371h

n = 6 (total number of measurements) - 1 • T ssz = - 2/ .A!Zt

n 1s1

- 1 n TB =-LTs,

n ,-1

Sr,r, = :t (TBI -Tar ,-1

For calibration of the measured operational values the following procedure shall be adopted:

- 1 6 st .JBZ = - L (T .46Zi - TB; ) 6 ,-1

AT,.sz

TCIIII Ts10

mean temperature difference between the end of the afterbuming zone and the measured operational values calibrated measured operational values (input to the emission value computer) 10-minute mean of the operating temperature measurement

The calibration shall be carried out completely for each approved operating state.

E 5.2.3 Parameterization of the electronic evaluation system

AT,.,.z* Is determined for each approved operating state and depending on the capacity (e.g. steam generating capacity PD) calculated flexibly by the evaluation computer; this refers also to the operating state "shutdown".

The function T ABZ* = f (PD) is parameterized. As regards the operating state "starting" compare E 5.3.1


-- Request for Information

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• R.I RI006669

Reference RI006669 ParentSu bject LR024675 Question

Dear Mr Mullins,

The Agency has reviewed your submission LR024675, in relation to the high level procedures proposed as

part of the test programme I commissioning plan. The Agency notes the content of this report.

In view of this submission the Agency requests that the licensee submit further information to demonstrate

how compliance with each specific requirement of condition 3.17.2 (a) to (f) of the IE licence register number

W0232-01 shall be achieved within each relevant phase.

The licensee shall also ensure the following is addressed as part of the submission:

1) Waste shall only be accepted at the facility from known customers or new customers subject to initial

waste profiling and waste characterisation off-site as required by condition 8.7 of the licence.

2) Submit the Quality Assurance Level (QAL) 1 report to the Agency, within two weeks of the date of

receipt of this request for information.

Dublin -, Waste to Energy - hlglif lfflda11 n:inn1fG'I g l!IXll'!l'i

FAO: Simon Buckley, Office of Environmental Enforcement, Environment Protection Agency, Richview, McCumisky House, Clonskeagh Dublln14

COVANTA

December 21st, 2016

Ref: W0232-01: RI006669: Further Information regarding Test Programme I Commissioning Plan.

Dear Mr. Buckley,

Dublin Waste to Energy Ltd. wish to respond to the Agency's request for further information regarding the Test Programme I Commissioning Plan as per condition 3.17.2 (a) to (f) of Industrial Emissions Licence number W0232-01. The response to each of the items is listed below:

3.17.2. (a) Verify residence time as well as the minimum temperature and the oxygen content of exhaust gas, which wifl be achieved during normal operation and under the mast un-fovouroble operating conditions anticipated.

This will be verified during phase 3 and 4 of the commissioning plan. Phase 3 is using both oil and waste which shall allow for the un-favourable operating conditions while phase 4 is the commencement of normal operations. This was highlighted previously in the commissioning plan Section 3 of Appendix 3 titled Residence Time.

3.17.2 (b) Demonstrate that each combustion chamber will be able ta achieve 850 °C for two seconds an a continuous basis.

It will be demonstrated that each combustion chamber will achieve the 850°C for two seconds on a continuous basis during phase 4 which is the commencement of the optimization phase. This shall be measured using thermocouples in compliance with schedule C.1.1. This was highlighted previously in the commissioning plan section 2.2.1 of Appendix 3 titled "Validation of Combustion Conditions"

Dublin Waste to Energy Ltd., Pigeon House Road, Poolbeg, Dublin 4. Tel: +353 (Oil 690 9731 Registered Office: Arthur Cox Ltd., Earlsfort Centre, EarlsfortTerrace, Dublin 2.

Dublin -, Waste to Energy - ligh!y fffidenl lraleratian & f!CIMIY

COVANTA 3.17.2. ( c) Establish all criteria for operation control and management of the abatement equipment to ensure compliance with emission limit values as specified in the licence.

This will take place during phase 3 when all components of the flue gas treatment system will be operating and the reagents are added to comply with emission limit values and dosage rates are optimized during Phase 4. The parameters listed in schedule C.1.1- Flue Gas Cleaning of Industrial Emissions Licence W0232-01 will be measured to establish all criteria for operation, control and management of abatement equipment. All parameters will be confirmed during the performance warranty test during phase 5 of the commissioning plan as highlighted prevlously in section 2 of the commissioning plan.

3.17.2 (d) Assess the performance of any monitors on the abatement system and establish a maintenance and calibration programme for each monitor.

The performance of the monitors on the abatement system will be assessed during phase 2 of the commissioning plan as requested by the Agency. Further assessment will be carried out as outlined previously in section 4.2.2 of the commissioning plan. Please find enclosed Emission Measurement QAL 2 document provided by Hitachi Zosen I nova (HZI).

3.17.2 (e) Confirm that all measurement equipment or devices (Including thermocouples) used for the purpose of establishing compliance with this licence has been subjected, in situ, to its normal operating temperature to prove it's operation under such conditions.

The validation of combustion conditions was previously submitted in appendix 3 of the commissioning Plan. Confirmation measurement will take place on all measurement equipment or devices during the performance warranty testing in phase 5.

3.17.2 (f)

Establish a list af the standby and back up equipment required to provide for contingency arrangements in the event of a breakdown of critical waste handling, treatment or abatement equipment.

The maintenance manager for the DWTE facility has compiled a list of standby and back up equipment that are essential for continued operation in the event of a breakdown. This list is retained on site for inspection by the Agency.


Dublin --, Waste to Energy ·- � llffidcnl n:nt8lilln & IICINIIY

COVANTA Outlined below are the additional responses requested by the Agency for correspondence reference RI 006669:

1. Waste shall only be accepted at the facility from customers or new customers subject to initial waste profiling and waste characterization off-site as required by condition 8. 7 of the licence.

All company's using the DWTEL facility will be subject to a pre-waste acceptance audit, which will be carried out by DWTEL staff (Business Manager and Environmental Manager). The completion of this form will be enforced by DWTEL management staff. Audits by DWTEL staff will commence early 2017 for all facilities sending waste to the facility. All facilities will sign a copy of the waste facility audit sheet as a record of acknowledgement for correct waste types allowable at the DWTE facility.

2. Submit the Quality Assurance Level (QAL) 1 report to the Agency, within two weeks of the date of receipt of this request for Information.

The QAL 1 reports were provided by the contractor Hitachi Zosen !nova (HZI) and were submitted to the Agency by DWTE on EDEN 25th November 2016.

3. Confirmatory monitoring for all continuously monitored parameters shall be completed during Phase 2 of the test programme I commissioning plan period.

As requested by the Agency, DWTE confirm that all confirmatory monitoring for all continuously monitored parameters shall be completed during phase 2. Further assessment will be carried out as outlined previously in section 4.2.2 of the commissioning plan.

4. All of the parameters listed in Schedule C.1.2. Monitoring of Emissions to Air shall be tested in Phase 4 of the test programme/commissioning plan period. In particular Metals (Cd, Tl, Hg, and Sb, As, Pb, Cr, Co, Cu, Mn, Ni and V) shall be sampled by way of 3 one hour samples per parameter. The monitoring shall be undertaken where possible at the maximum intended feed rates for waste.

The maximum intended feed rates will be reached during phase 4 of the commissioning plan. 3 one hour testing will take place for each of the parameters listed in licence schedule C.1.2. The regulatory requirements will be tested during phase S. These tests will be carried out by an independent third party, who will be appointed early in 2017.


Dublin -, Waste to Energy - lii,ltf lffidllllil:nnlllln & _,

COVANTA 5. Methods for the characterisation of the incinerator residue shall be submitted to the Agency for

the approval as required by condition 8.2.3 of the licence. The characterisation report on the incinerator residue shall be submitted to the Agency for the agreement in advance of the bottom ash being sent off site for disposal or recovery.

The bottom ash and Flue Gas Treatment Residue (FGTR) sampling plan was submitted to the Agency on Friday 161h December 2016 (uploaded to EDEN).

6. The licencee shall submit to the Agency an independent construction quality assurance validation report as specified by condition 3.23.2 of the licence within three months of commencement of waste acceptance.

The Construction Quality Assurance (CQA) validation report will be submitted within 3 months of commencement of waste acceptance as per condition 3.23.2. The independent validation report will be carried out by Fichtner Consulting Engineers and will comprise of the following: (a) A description of the works (b) As-Built Drawings (c) Records and Results of all integrity and validation tests carried out (including failures)

including a report on the details of the computational fluid dynamic modeling of the incineration plant

(d) Drawings and sections showing the location, capacity and discharge points of all pipes, drains, bunds, bunkers and waste storage areas

(e) Name(s) of contractor(s)/individual(s) responsible for undertaking the work; (f) Records of any problems and the remedial works carried out to resolve those problems ;and (g) Any other information requested in writing by the Agency.

The compilation of the CQA report is currently underway as Fichtner Consulting Engineers are on site periodically. The CQA report will be submitted on completion as per condition 3.23.2.

7. The Agency recommends that the /icencee conduct noise monitoring in advance of waste acceptance at the facility and three months after commencement of the licenced activity as specified in the commissioning plan.

An environmental monitoring programme has been implemented during the construction stage of the Dublin Waste to Energy (DWTE) Project. This included noise monitoring reports. These noise monitoring reports are available for viewing on site In the public file and on the DWTE website at www.dublinwastetoenergy.ie DWTEL will carry out further noise monitoring three months after commencement of the licenced activity and quarterly thereafter for a period of 3 years in compliance with conditions 4.3, 5.4 and Schedule C.6.2.

Dublin Waste to Energy Ltd., Pigeon House Road, Pool beg. Dublin 4. Tel: +353 (0)1 690 9731 Registered Office: Arthur Cox Ltd., Earlsfort Centre, Eartsfort Terrace, Dublin 2.

Dublin --, Wasfe to Energy �- hlglt, llffidel1I n:inlntian & 1'11:MfY

COVANTA If you require anything further please do not hesitate to contact the undersigned.

Yours Sincerely,

Mark H


r· Z C PZF). Z A Z « � ;.: L Z •B, aa $2J c""• ,_

Dublin Waste to Energy Facility

Employer: COVANTA Europe Engineering Ltd. Site Address

COVANTA Powering Today Prolecllng Tomorrow

COVANTA

Arthur Cox Building 29 Earfsfort Terrace Dublin 2 Ireland

Dublin WTE Facility Pigeon House Road Poolbeg Peninsula, Dublin 4 Ireland

5.0 --- 4.0 T�z.,t� - --- 3.0

2.0

� Danle!He add drawing numbers

25.08.20 25.08.201 25 08.2016

1.0 victors Daniel He Thomas Zacharias add more delalls 20.08.2016 20.08.2016 20 08.2016

0.0 vicior Sladler Daniel Hennessy Thoma• bcherla First Issue 07.06.2018 � 07.06.2016 07.06.2016 Rav Author I Ravi.war , ... ,!"J![:��J l Shor1 description of change (lrjlWo Dale, llignu,19) en••• Dale Sign.cure)

ODS Lot Emission Measurement QAL2

ProjectNr

P-3270 Prl>!ect Name

Dublin WTE Facility T AIC �cType

000000 J TSO Supplier

HZI HZl Documenl Nr- Rav

50052912 ·2.0

l Hitachi Zosen INOVA

T""'C>I* DocNo- Rav- 5003CIN2·5 Q

Issued by

Hitachi Zosen lnova AG Hardtunnslrasse 127

P.O. Box680 8037 Zurich, Swltze�and

www hz·lllova.com I Tel. +41 (0)44 2n 1111 Fax .. 41 (0)44 zrt 1313 I

CO VANTA Project Name: Dublin WTE Facility I Hitachi Zosen rtl . ODS Lot Emission Measurement INOVA ""-ring T- Prclactlng T_,,_. I e. QAL2

AIC: 000000 Document Nr-Rev: 50052912 - 2.0 Hitachi Zosen lnova AG

Table of contents

1 General lnforrnation 3

2 Speciflcatlons 3 2.1 Pre Calibration 3 2.3 QAL2 4 2.4 Homogeneity Test. 4 2.5 Comparison Test 5

3 Documentation 5

4 Attachments 5

5 Remarks 6

Print date 30 DB 18 10 38 Last salled 30 08 18 Page 2ore

r-COIINTI ProjedName· DubllnWTEFacility I j T'tl . ODS Lot Emission Measurement

I ,-r11,groday PmoctJnar .... ..- - I e. QAL2

I AIC: 000000 Document Nr-Rev 50052912 • 2.0

1 General Information

. Hitachi Zosenl INOVA I Hitachi Zosen lnova AG

Site Address: Dublin WTE Facility Pigeon House Road Poolbeg Peninsula, Dublin 4 Ireland

Table 1: Project Data

Supplier:

Description Value Description Value

Installation raw gas measurement Inside Temperature inside -10 ... +35"C

Installation emission measurement inside Temperature outside +10 ... +40"C

Number of lines 2 Number of redundant 1 emission measurement

The contractor has the overall lead of all tests and measurements which are described in Chapter 2 Specifications.

All activities must be coordinated with the Commissioning Lead Engineer (HZI) on site.

2 Specifications

2.1 Pre Calibration Table 2: Pre Calibration Emission Measurement

Description Method(s) Duration Date

Particulate matter EN 13284- 3x 60 Mins 111 waste fire + 2 weeks 1

Flow measurement 3x60 Mins

02 3x60 Mins

Water vapour 3x60 Mins

Print date 30 0816 1038 Last saved 30.08 16 Page 3 of6

COVANTA Projed Name: Dublin WTE Facility f Hitachi Zosen Ttl . ODS Lot Emission Measurement INOVA P-111 Tod>y Prot.,<1lng T--. I e. QAL2

AIC: 000000 Document Nr-Rev: 50052912 • 2.0 Hitachi Zosen lnova AG

2.3 QAL2 The functional test is also part of QAL2 and should be carried out in cooperation with the supplier of CEMS system in accordance with EN 14181.

Table 3: QAL2 acc. EN 14181 & EN 15259


HCI Hydrogen 111 waste fire + 8 weeks chloride

502 Sulphur dioxide

NO Nitrogen monoxid

N02 Nitrogen dioxid - c: Q) c:

NOx Nitrogen oxides 8. co Carbon monoxide �

0 .... C02 a

rn TotalVOC Total organic OJ c: (TOC) carbon '5 cu Particulate EN 13284-1 I!! - :2 matter 7ii > 02 Oxygen It) ....

1\1 H20 Water vapour

Flow - Temperature

Pressure

2.4 Homogeneity Test Table 4: Homogeneity Test acc. EN141181 & EN 15259


NOx Nitrogen oxides 111 waste fire + 8 weeks

502 Sulphur dioxide

02 Oxygen

co Carbon monoxide

Total voe Total organic (TOC) carbon

Flow/ . Velocity

Pr1nt date 30.08 16 10 38 Last saved 30 08.16 Page 4 of 6

COVINTI Project Name: Dublin WTE Facility I Hitachi Zosen Ttl . ODS Lot Emission Measurement INOVA "-.int Toay, "-loc:1lnv T-. I e. QAL2


2.5 Comparison Test Table 5: Comparison Test Raw Gas Measurement


HCI Hydrogen 1 x 60 Mins 111 waste fire + 8 weeks chloride

502 Sulphur dioxide 1 x 60 Mins

H20 Water vapour 1 x 60 Mins

02 Oxygen 1 x 60 Mins

C02 Carbon dioxide 1 x 60 Mins

3 Documentation

The QAL2 report shall to meet the requirements according EN14181 and the Environmental Permit. Language Number of copies Format

English 1 x Electronic pdf

4 Attachments

Table 6: Attachment 1 a List of General Attachments

No. Title DocNo Rev Issue Dat�

1 General Information 50031860 3.0

1 Site Conditions and Regulations 50035191 5.0

2 Delivery Information 50021924 7.0

Table 7: Attachment 1 b List of Specific Attachments to TSO

No. Title Doc No Rev luue Date

1 Nozzle Arrangement Clean Gas Duct A8051011 7.0 A8051012 5.0

2 30 Sketch Position Emission Measurement 50092512-1b 0.0

3 Nozzle Arrangement Raw gas Measurement A8051056 2.0

4 30 Sketch Position Raw Gas Measurement 50092512-1b 0.0

5 Environmental Protection Agency Permit 50031125 0.0

Print date 30 OB 16 10 38 Last saved 30 OB 1 B Page sore

COVANTA Project Name. Dublin WTE Facility f Hitachi Zosen Titl . ODS Lot Emission Measurement INOVA Powering Today p,...._., T_,_ e. QAL2


Table 8: Attachment 2, Technical Documents from Supplier

No. Title Delivery Date

1 Test report Pre Calibration 2 weeks after measurement on site

2 Test report QAL2 incl. functional and homogeneity tests 2 Weeks after end of QAL2on site

3 Test report comparison tests raw gas measurement 2 Weeks after last measurement on site

5 Remarks

• na

Print date 30.08 18 10 38 Last saved 30 oe 1 e Page 6 of5

Licence Return Approval Notice

Licence: W0232-01- DUBLIN WASTE TO ENERGY LIMITED

Submitted On: 20/01/2017

Licensee Submission LR024675 Title Commissioning Plan

Notification

Dear Mr Mullins,

The Agency has reviewed your submissions Ref. Nos. LR024675 and LR026409, in relation to the test programme/commissioning plan for the Dublin Waste to Energy Limited facility.

I am to advise you that on the basis of the information provided, the Agency approves the test programme/commissioning plan, subject to the licensee complying with the following conditions:

1) The calculations or model used to determine the residence time shall be provided to the Agency, prior to the incineration of waste (Phase 3), and not during the optimisation phase (Phase 4), as proposed. The residence time shall then be demonstrated to the Agency during the optimisation phase (Phase 4).

2) The calculations or model used to determine that each combustion chamber will achieve a minimum of 850 degrees centigrade for two seconds shall be provided to the Agency, prior to the first fire with waste (Phase 3), and not during the optimisation phase (Phase 4), as proposed. A minimum temperature of 850 degrees centigrade for two seconds in each combustion temperature shall then be demonstrated to the Agency during the optimisation phase (Phase 4).

3) The criteria for the operation, control, and management of the abatement equipment to ensure compliance with the emission limit values (El Vs) specified in Schedule B. 1 Emission Limits to Air shall be completed during the first fire with waste (phase 3), and not during the optimisation phase (Phase 4). A report on the successful operation of the abatement systems shall be submitted to the Agency as part of the independent construction quality assurance validation report.

4) The Quality Assurance Level (QAL) 2 report shall be submitted to the Agency, within three months of commencement of waste acceptance at the facility.

5) Submit to the Agency, on a monthly basis throughout the test programme/commissioning plan period, a report containing the raw and corrected data for the 24 hour average and 30 minute maximum values for 02, H20, temperature, S02, NOx, CO, HCI, HF, TOC, and total dust.

6) All monitoring for PM10, PM2.5, metals and dioxins conducted during the test programme/commissioning plan shall be sampled and analysed in triplicate.

7) Records of hourly and daily feed rates of waste to the incinerator shall be maintained on site, and be available for inspection by Agency personnel at all times.

8) The final test programme/commissioning plan report shall address all aspects of Condition 3.17 of the licence, and at a minimum include:

a) The record of hourly and daily feed rates of waste to the incinerator

b) The results of all monitoring undertaken during the test programme/commissioning plan, with comparative results between continuous emissions monitoring system (CEMS) data and contractor monitoring

c) All pertinent data required to demonstrate that the incineration of waste does not result in any adverse impact on the incinerator, abatement equipment or the CEMS, and that the conditions of the licence are being complied with

d) Verification of the installation and maintenance of negative pressure at the waste reception, waste bunker, and waste storage and incinerator residue storage/loading areas of the facility

e) The CEMS data software programming and description, an explanatory flow chart (from electrical signal to final results), and details of the programming used to assess compliance over a 12 month rolling period with Notes 1 to 7 of Schedule B.1 Emission Limits to Air

f) A detailed description of all relevant interlocks.

9) The licensee shall comply with all of the requirements of industrial emissions licence Reg. No. W0232-01 at all times.

This agreement may be modified or revoked at any time by the Agency following review of any data pertaining to the test programme/commissioning plan.

If you have any queries, please contact the undersigned at 01-2680100.

Yours sincerely,

Mr Simon Buckley

Inspector

Office of Environmental Enforcement

Dublin Region.