Development of a monitoring concept for continuous BAT .... 2007-2011 Update of the... · for its Waste incineration installation and regularly prove the BAT ... eventhough ISVAG

Fachgebiet

Development of a monitoring conceptfor continuous BAT assessment for theISVAG MWI, Antwerp and a 2007-2011update of the technical performancestudyFebruary 2012

Dipl.-Ing. Carsten Böhm

Prof. Dr. Ing. Vera Susanne Rotter

Technische Universität Berlin, Dep. Solid Waste Management

Contact: Institute of Environmental Technology, Chair of Solid Waste Management, Secretariat Z2,Strasse des 17. Juni 135, D-10623 Berlin, Germany Tel: +49 30 314-28512, [email protected]

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Contents

1 Terms of Reference.........................................................................................................1

1.1 Background ......................................................................................................................... 1

1.2 Scope of the Study .............................................................................................................. 1

2 Initial Situation ...............................................................................................................3

2.1 NOx-Emissions ..................................................................................................................... 3

2.1.1 Emission Trend of the ISVAG Municipal Waste Incinerator ........................................ 3

2.1.2 Current European and Best Available Technique Emission Standards ....................... 4

2.1.3 Practice of Emission Monitoring across European Countries ..................................... 5

2.2 Energy Recovery from Waste.............................................................................................. 9

3 Materials and Methods................................................................................................. 11

3.1 NOx-Emissions and Emission Standards ............................................................................ 11

3.2 Survey on NOX emission of Germany WIP........................................................................ 12

3.3 Energy Flows and Recovery Efficiency .............................................................................. 12

4 Results ......................................................................................................................... 14

4.1 Assessment of NOx-Emissions ........................................................................................... 14

4.1.1 Indications for the Future Development of Emission Standards .............................. 14

4.1.2 Evaluation of the NOx-Emissions from ISVAG in the Context of BAT and StricterNOx-Emission Standards ............................................................................................ 16

4.1.3 Confidence of the emission measurements.............................................................. 20

4.1.4 Transparency in Communication of Emissions.......................................................... 23

4.1.5 Comparison with other plants................................................................................... 24

4.2 Assessment of Consumption and Production Data .......................................................... 25

4.2.1 System Boundary and Energy Flows.......................................................................... 25

4.2.2 Energy Recovery Efficiency R 1.................................................................................. 28

4.2.3 Production and Consumption of Energy ................................................................... 29

5 Conclusions and Recommendations .............................................................................. 33

5.1 NOx-Emissions ................................................................................................................... 33

5.1.1 NOX reduction potential ............................................................................................ 33

5.1.2 Emission measurement techniques .......................................................................... 33

5.1.3 Data reporting and communication .......................................................................... 34

5.2 Energy Flows ..................................................................................................................... 34

5.2.1 Status Energy Efficiency performance....................................................................... 34

5.2.2 Improving the Energy Efficiency performance.......................................................... 35

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5.2.3 Recommended next steps ................................... Fout! Bladwijzer niet gedefinieerd.

References........................................................................................................................... 36

Annex.................................................................................................................................. 38

Technische Universität Berlin – ISVAG

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1 Terms of Reference

1.1 Background

As a voluntary commitment, “Intercommunale voor Slib- en Vuilverwijdering vanAntwerpse Gemeenten” (ISVAG) committed to apply a Best Available Techniques (BAT)for its Waste incineration installation and regularly prove the BAT compliance. In thiscontext, monitoring system the Municipal Waste Incinerator (MWI) in Wilrijk, Belgiumenabling the continuous control of the company’s environmental performance andindicating the degree of compliance with BAT relative to other waste incineration plants.

In the project phase 2009-2010 a first BAT assessment was conducted by the TU Berlin,chair of solid waste management, which used standard data as recorded from ISVAGaccording to the permit (Rotter et al. 2010). The used data were measured in 2001-2007.Nevertheless, the actual set-up of the “Best Available Techniques Reference Document(BREF) for Waste Incineration (WI-BREF)” is not suitable to assure the bestenvironmental performance because published emission data are up to 12 years old anddo not reflect new technical development.

Additionally, it became obvious that one of the limitations of any “BAT comparison” areEurope-wide not standardized monitoring and measurements requirements. In addition,there are no uniform measuring, calibration and reporting rules for emission andconsumptions data on a European level. Waste incineration plants need in the futureBAT-conform monitoring. This might include adapting measurements techniques foremission, adjusting calculation algorithms, measuring additional parameters inside theplant or the monitoring of downstream processes like treatment and disposal of solidresidues.

1.2 Scope of the Study

The Chair of Solid Waste Management of TU Berlin under the lead of Prof. Rotter willcarry out a study with the goal to recommend future measures for the introduction of aBAT-conform monitoring system. This study focuses on NOx-emissions and energy flows,mainly because these two aspects, eventhough ISVAG was complying with the BREFdocument from 2006 in the first BAT study (Rotter et al. 2010)., showed the highesttechnical innovation potential over the last five yearsand may come to new conclusionsregarding BAT

In detail, the scope of this study includes an assessment of the application of BAT atISVAG by examining the following aspects:

Update of the NOx-emission trend from ISVAG

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Search for concrete indications for a future enforcement of European NOx-emission standards for waste incinerators

Evaluation of ISVAG’s NOx-emission trend in the context of BAT-associated andexpected emission standards

Comparison of ISVAG’s relative to European waste incinerators and identificationof requirements for comparison

Determination of the waste energy recovery efficiency in compliance withinterpretation of relevant guidelines

Evaluate energy production and consumption figures Provide general recommendations for achieving BAT compliance and for the

implementation of a continuous monitoring instrument to evaluate the currentBAT status


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2 Initial Situation

2.1 NOx-Emissions

2.1.1 Emission Trend of the ISVAG Municipal Waste Incinerator

In order to evaluate the general development of the NOx-emissions from the ISVAGMWI, the yearly averages of the NOx-emission concentrations have been plotted in theFigure 2-1 for the period from 2001 until 2011. In general, the respective NOx-emissionsclearly show a falling tendency throughout the last years, starting from about180 mg/Nm³ in 2001 and reaching slightly higher than 100 mg/Nm³ in 2011. Thepresented emission values are averages of emission data of both existing process lines 1and 2 of the ISVAG plant. The respective data is taken from the mass and energy flowsheet attached in the Annex B. On the basis of the described trend, it can be concludedthat measures realized in order to decrease the NOx-emissions have shown effective. AtISVAG, a selective non-catalytic reduction (SNCR) process is installed for the removal ofNOx from the flue gas.

Figure 2-1 Trend of NOx-Emissions from 2001 until 2011 of the ISVAG MWI (emission levelreferred to 11% O2, 271,15K, 1013,25hPa, non-validated data)

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The Figure 2-1 also shows the voluntary NOx-emission limit level (ELV) which ISVAG MWIcommitted to. It is 120 mg/Nm³ for the yearly average and it can be concluded that,since 2010, the plant’s emissions are well below this limit.

2.1.2 Current European and Best Available Technique Emission Standards

European member states have introduced their specific national legislation concerningemissions from waste incineration as an adoption of the relevant European directives(i.e. Directive on Industrial Emissions 2010/75/EU (IED), Directive on the Incineration ofWaste 2000/76/EC (WID)). The Table 2-1 gives an overview of the most importantfigures of the NOx-emission standards that are currently valid in Belgium, TheNetherlands, Germany and ISVAG, as examples.

Table 2-1 Current European Emission Standards for NOx

Timeinterval

2010/75/EU (IED)2000/76/EC (WID)

VLAREM(B)

ISVAG(B)

BVA1)

(NL)17. BImSchV(D)

Half hourlyaverage

A (100%): 400B (97%): 200

A (100%): 400B (97%): 200

400 400 400

Dailyaverage

200 200 200 200 200

Monthlyaverage

- - - 70 -

Yearlyaverage

- - 120 - 100 2)

11% O2 11% O2 11% O2 onleif measuredO2 content >11%, nonormalizationfor O2 < 11%

all values in mg/Nm³1) valid until 1 January 20132) only for firing capacity >50 MW, already in force

In addition to the requirement defined in the European directives of monitoring halfhourly and daily averages of the NOx-emission concentrations, emission limits can also


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be defined with respect to a period of a month or a year. For example, this is the casefor The Netherlands where a monthly limit has been introduced. Yearly emission limitscan be found in Germany and in Belgium..

In addition to the frame of the Waste Incineration Directive (WID) two trands can beseen. 1) Member states setting strickter ELV on a national level and 2) permits requiringstricter ELV than the national legislation.

Ad 1) In Germany from of 2013 emission limit of 150 mg/Nm³ (daily average average)will be valid for new large incineration plants >50MW in operation, from 2019 this willalso be valid for old installation >50MW. This is regulated in an amendment of theSeventeenth Ordinance on the Implementation of the Federal Immission Control Act(17. BImSchV) that is relevant for waste incinerators. This amendment implements theEuropean IED. This situation is explained and evaluated in detail in part 4.1.1 of thisreport.

Ad 2) Already now, it is not unusual that (German) authorities require plant operators tocomply with only 50% of the NOx-emission limits given in the currently relevantlegislation document 17th BImSchV. As an example, for the existing waste incinerator inBonn, Germany, only 200 mg/Nm³ as allowed half hourly average and only 100mg/Nm³as allowed daily average have been set by authority decision. This plant is in operationsince 1991. It has an electrical power output of about 15 MW and has installed an SNCRprocess for NOx-removal (Berg/Heidrich 2006). For the waste incinerator of Berlin,MHKW Ruhleben, the yearly average 100 mg/Nm³ has been set as limit (Amtsblatt2011). The waste incinerator MVR Müllverwertung Rugenberger Damm in Hamburg isoperated at a daily NOx-emission limit of 120 mg/Nm³ and a yearly limit of 100 mg/Nm³(MVR 2011).

A further important reference for emission standards associated with best availabletechnique (BAT) is given with the Best Available Techniques Reference Document forWaste Incineration (WI-BREF). According to the WI-BREF, BAT-conform NOx-emissionsfrom installations not using SCR should be in the range from 120 to 180 mg/Nm³ (dailyaverage).It is mentioned that under certain conditions (low raw NOx and/or high reagentdose rates) levels below 70 mg/Nm³ have been reached. With respect to the half hourlyemission limit, the corresponding BAT-range is between 30 to 350 mg/Nm³ (WI-BREF2006, p. 440 f.).

2.1.3 Practice of Emission Monitoring across European Countries

Although national emission monitoring regulations of European countries are partingfrom the same European directive, country specific differences in the monitoring

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practice can be observed. Concerning emission limit surveillance, the IED allows forcrediting waste incineration plants for the uncertainty of their emission measurementsby validation of the measurement values.

2.1.3.1 Data validationThe general and simplified algorithm for the validation of the measured emissionconcentration values is given in the Figure 2-2. The main step of this validation algorithmis the reduction of the standardized emission concentration (K) by subtraction of acertain correction term (VB), resulting in the validated standardized emissionconcentration (Kval). This algorithm is applied to the measured half hourly emissionconcentration averages given in standard conditions (dry flue gas, with 11 vol.-% oxygen,at 273.15 K and 1013.25 hPa). Daily averages of the NOx-concentration is determined onthe basis of Kval of one day .

Figure 2-2 Simplified Algorithm for the Validation of Measurement Values

EU member states apply different methods for measurement validation. Especially, thedetermination of the correction term (VB) is subject to country specific interpretation ofthe according regulation given in the WID1. For NOx-emissions, it is specified that the95%-confidence interval shall not exceed 20% of the daily emission limit value (200mg/Nm³). This corresponds to a correction term (VB) of 40 mg/Nm³ for NOx-emissions(WID 2000, Annex III). As VB may be subtracted from the original measured value (K),emission validation is a procedure in favor of any emitting plant, because it provides acertain tolerance towards the existing emission limit.

There are countries (e.g. France, Germany, England) in which VB is obtained from thecalibration procedure of the emission measurement equipment according to thestandard reference method QAL2 described in DIN EN 14181 (Bianchin 2011). In these

1 “11. The half-hourly average values and the 10-minute averages shall be determined within theeffective operating time (excluding the start-up and shut-off periods if no waste is being incinerated)from the measured values after having subtracted the value of the confidence interval specified inpoint 3 of Annex III. The daily average values shall be determined from those validated averagevalues.“ (WID 2000, Article 11, Measurement requirements)


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cases, the parameter VB represents the 95%-confidence interval obtained from thecalibration of the measurement equipment, and it is considered as a measure for theuncertainty of the emission measurement system. In other countries (e.g. Belgium,especially ISVAG, The Netherlands), VB is not derived from equipment calibration butequal to the legally allowed maximum of 40 mg/Nm³.

In practice, country specific validation methods do not only result from different ways ofquantifying VB but also from its application to the measured emission concentration K.For the three examples France, Great Britain and Germany, the Figure 2-3 presentsqualitative diagrams with validation methods for the same value for VB and the sameemission limit value (ELV). Starting from a couple of measurement points, a calibrationcurve is defined together with the borders of the respective 95%-confidence interval.The correction term (VB) is given as the difference of two concentrations, of which oneis obtained from the intersection of the lower 95%-confidence interval border with ELV.Then, VB can be determined with the concentration resulting from the calibration curveat the same signal size. Finally, VB can be expressed as percentage of ELV.

Country Specific Validation Methods

France Great Britain, Germany

France: Subtraction of VB as percentage up to ELV, above ELV substraction of VB as fixed value

Great Britain: Subtraction of VB from the calibration curve as percentage over the whole range

Germany: Subtraction of VB from the calibration curve as fixed value over the whole range

source: DURAG AG (modified)

Figure 2-3 Country Specific Validation Methods for Emission Measurements

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Regarding the validation methods, the Figure 2-3 shows that, in the case of Germany,the validation results in a parallel line to the original calibration curve. A constantcorrection value (VB) is subtracted from the measured concentration over the wholemeasurement range, i.e. VB expressed as a percentage refers to the constant ELV so thatthe correction term is a constant, too. The German Bundeseinheitliche Praxis bei derÜberwachung der Emissionen (BMU 2010) and 17. BImSchV (Annex III2) define that thevalidation value should be derived from calibration and that it can be subtracted. In theexample of Great Britain, VB refers to the measured concentration so that there is arelative correction, i.e. a relatively small correction for lower measured concentrations,and a greater correction at higher concentrations. The case of France can be regarded ascombination of the two latter methods. It can be seen that the validation is split into tworegions. Measured concentrations below the ELV are validated by subtracting VB as apercentage of the measured concentration. Above the ELV, a constant value issubtracted as VB refers to the constant ELV.

In summary, it has to be pointed out the that those three countries (GB, Fr, Ger) applyfor data valifdation only the real VB from the calibration measurement and not themaximum allowed percentage according to ANNEX III of the WID. In practice, in Flandersa validation correction is not considered in the reporting of emission data to VLAREM,while in the Netherlands only “validated data” are reported. E.g. for NOx emissions thisvalidation leads to a “reduction of reported emission 20 % of the valid ELV. This practicein the Netherlands corresponds with the nominal reduction of measured emissions ofminus 80 mg/Nm³ for the half hourly average, minus 40 mg/Nm³, minus 14 mg/Nm³ forthe daily average. It also should be noted that the validation of emission measurementsis relevant for the decision whether an installation complies with its own ELV but is notappropriate for the comparison between installations.

2.1.3.2 NormalizationAnother factor hindering an easy comparison of emission performance indicators acrossEurope are differences in the practice of “normalization” of emission concentrations tostandard conditions. According to ANNEX III of the WID emissions concentration are tobe reported in standard conditions (dry flue gas, with 11 vol.-% oxygen, at 273.15 K and1013.25 hPa).

BN

NBBN pT

pTcc

cN, TN, PN: concentration, temperature, pressure under normal condition

2 “The validated half‐hourly mean values and daily mean values shall be determined from the measuredhalf‐hourly mean values after having subtracted the measurement uncertainty (confidence interval)determined during calibration.” (17. BImSchV 2003, Annex III)


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cB, TB, PB: Konzentration, Temperatur, Druck im Betriebszustand

M2

2B E

O%21O%21

EM

B

O2B: reference oxygen content

EB: emission concentration referred to the reference oxygen content

O2M, EM : measured oxygen content and measured emission

In practice the normalization to a reference oxygen content leads to nominal loweremissions if the measured oxygen contentment is below the reference oxygen content(11%). In general this is the case for waste incineration plants which are operated at 8-9% O2.

For that reason, Germany only allows the normalization to 11% reference oxygencontent for continuous measurements if the measured oxygen concentration is above11% which is normally not the case. That leads to the fact that in most cases reportedvalues in Germany are nominally higher relative to countries where the normalization to11% is generally allowed.

2.2 Energy Recovery from Waste

With the Directive 2008/98/EC on waste (Waste Framework Directive, WFD), recoveryoperations have been defined that describe the efficiency of the use of waste for acertain objective. Among the defined operations is the so called R 1 recovery operationthat can apply for plants that use waste “principally as a fuel or other means to generateenergy (*)” (WFD 2008, Annex II). The indicator R 1 has been introduced in order topromote the substitution of fossil energy use and to reduce greenhouse gas emissionsby the operation of high efficient waste incinerators.

In addition to the WFD, also the WI-BREF addresses that topic of energy recoveryefficiency, but it proposes a different formula for the calculation of the efficiency (WI-BREF 2006, p. 199). In this study, the R 1-formula of the WFD is considered as itrepresents content of a legally binding document.

In order to achieve the R 1-recovery status, waste incinerators in operation before 2009need to exceed the R 1-threshold of 0.6 defined by the WFD (WFD 2008, Annex II).TheGuidelines on the R1 Energy Efficiency Formula in Annex II of Directive 2008/98/ECrecommend the directive conform application of the R 1-formula in detail (EC 2011). Thisguideline focuses on the energy flows that should be considered, and on the definition

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of the system boundaries having an influence on the energy flows that should be takeninto account.

The influence of the system boundary has been demonstrated already in the previousISVAG assessment from 2010 (Rotter et al. 2010). In the scenario from 2007 “electricitysupplier” the indicator R 1 was 0.51 so that ISVAG did not fulfill the condition for energyrecovery. On the contrary, considering ISVAG as a “steam supplier” resulted in 0.89 for R1 (Rotter et al. 2010, p. 85 ff.). Thus, with the defined threshold value of 0.6 for R 1, theISVAG waste incinerator does or does not classify for energy recovery operations,depending on the inclusion or exclusion of the turbine and the generator from the R 1system boundary.

In this context, it is important to consider that the turbine and the generator on the siteare included into the definition of the technical unit of the operation permit of theISVAG plant. The owner of these aggregates is the company Electrabel which, bycontract with ISVAG, converts the steam delivered by ISVAG into electricity and returnsthe condensate to the ISVAG plant. Electrabel is responsible for maintenance,improvements of the turbine and its equipment. It is controlled from the control roomof ISVAG. ISVAG receives electricity from the grid, exclusively.

The mentioned R 1-guideline gives reasons for and against a consideration of the turbineplant inside the R 1-system boundary. At the moment and from a midterm perspectiveuntil 2023, ISVAG does not depend on a qualification for the R 1-status as it would workto more than full capacity due to the region’s high demand for waste treatment for thenext 10 years. Nevertheless, the efficiency of energy recovery is an aspect with BATrelevance, as the directive and the guideline refer to an application of the R 1-formulathat follows the WI-BREF. The continuous monitoring of the performance regardingenergy efficiency allows ISVAG to monitor the performance over the years and toanalyses reasons for variation. In addition, an assessment of the ISVAG plant on thebasis of R 1 as BAT-indicator is very useful as it implies also an assessment of energyflows, especially the consumed amounts of electricity, natural gas and the producedelectricity, that are relevant for the BAT-status.

Across Europe, the degree of achieving the R 1-status is not equally distributed. Whilenorthern countries do not seem to have problems in achieving this status, it can be moredifficult to reach for waste incinerators in southern countries. For Germany it isexpected that 70% of the waste incinerators would achieve the R 1-status (Jaron 2008,p. 16).


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3 Materials and Methods

3.1 NOx-Emissions and Emission Standards

In this study, NOx-emissions from ISVAG are compared to expected future emissionlimits and to BAT-associated standards. For that purpose, the NOx-emissions have beenprovided from ISVAG as time record tables containing the non-validated NOx-emissionconcentrations in the clean, dry flue gas at standard conditions and with 11 vol.-%oxygen, for each half hour of the period from 2007 until 2011, and for both combustionlines 1 and 2 (“Half hourly NOx Line 1 2007-2011”, Half hourly NOx Line 2 2007-2011”).

On the basis of these emission records, histograms for the NOx-emissions of each yearhave been produced. Statistical parameters (total number of measurements, minimum,maximum, arithmetic average) have been calculated in order to describe the distributionof the measurements, and to evaluate the NOx-emissions from ISVAG in the context ofcertain emission standards. In addition, for the years 2010 and 2011, histograms havebeen produced that show the frequency distribution of the daily average NOx-emissionsfrom ISVAG. Therefore, for each day the average emission has been calculated byaveraging all available half hourly average emissions of the respective day.

The chosen class width for grouping of emission data is 6 or 7 mg/Nm³, depending onthe analyzed data record. The number of cases is counted when a certain threshold oremission limit is exceeded regarding the ISVAG emissions, in order to quantify the risk ofexceeding a given emission limit.

A document with relevant data concerning the uncertainty of the NOx-measurements atISVAG, required for a comparison of ISVAG to other waste incinerators, has beenprovided by ISVAG with the calibration report containing information of the confidenceinterval of the NOx-measurement equipment (“95% betrouwbaarheidsinterval voor NO”,refer to Annex A and TÜV (1995)). In the context of measurement uncertainty,references have been searched that present a position towards BAT-associatedrequirements of emission reporting and uncertainties.

For the comparison with BAT-associated standards the WI-BREF was used as referencedocument. Nevertheless, following the start up of a revision of the BREF in 2014 trendsin emission reduction for NOX in other European countries could seen as indication for tobe expected stricter BAT associated emission values in the next BREF revision. InGermany were surveyed, both, reduction in reported emissions from operationalinstallations and reductions in upcoming new ELV (amendment of the 17. BImSchV, theGerman implementation of the WID).

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The majority of information that could not be submitted by ISVAG was requested by e-mail or by phone interviews with potential data suppliers, such as authorities, lobbyinstitutions and waste incinerator operators. Emission records and validation methodshave been requested with this strategy. Given answers were received digitally, orwritten down in the form of minutes. Requested reference data from other wasteincinerators that is not publically available has been unnamed for reasons ofconfidentiality. This refers especially to the presented measurement uncertainties andthe NOx-emission records from other plants. The information concerning countryspecific validation methods is taken from submitted information of DURAG AG, asupplier of measurement equipment.

3.2 Survey on NOX emission of Germany WIP

In order to update the outdated data of the WI-BREF a survey of all German Wasteincineration plants regarding their NOX emissions. For that purpose all installationsaccording to the waste management plans of the federal states were listed andpublically available data from the web pages evaluated. If information was not found itwas requested by email, mail and telephone. The following parameters were assessed.

Capacity [t/a] Type of DENOX system [SCR/SNCR] Emission limit according to permit Year of construction Annual average emission [t/a] Annual average emission [mg/Nm³] Ammonia slip[mg/Nm³]

None of the installations had information regarding the R1 calculations.

3.3 Energy Flows and Recovery Efficiency

R 1 is defined by the following R 1-formula on the basis of incoming and outgoing energyflows E of a defined system boundary of a waste incinerator (WFD 2008, Annex II; EC2011, p. 5):

R 1 = E − (E + E )0.97 x (E + E )R 1 efficiency parameter for the energy recovery from waste [-]Ep means annual energy produced as heat or electricity. It is calculated with energy in the

form of electricity being multiplied by 2.6 and heat produced for commercial usemultiplied by 1.1 [GJ/year]

Ef means annual energy input to the system from fuels contributing to the production ofsteam [GJ/year]


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Ew means annual energy contained in the treated waste calculated using the net calorificvalue of the waste [GJ/year]

Ei means annual energy imported excluding Ew and Ef [GJ/year]0.97 is a factor accounting for energy losses due to bottom ash and radiation [-]

The data for the particular required energy flows for this calculation have been deliveredby ISVAG for the period from 2001 to 2011 (“Overzicht Exploitatie ISVAG periode 2001 –2011”, refer to Annex B), and in detail for 2010 (“Overzicht 2010 verbruik en produktieenergie te ISVAG cv.”, refer to Annex C).

For the comparison with BAT-associated standards the WI-BREF was used as referencedocument.

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4 Results

4.1 Assessment of NOx-Emissions

4.1.1 Indications for the Future Development of Emission Standards

The strongest indication that has been found for the future development of NOx-emission standards is the proposed amendment of 17. BImSchV (Ordinance on theImplementation of the Federal Immission Control Act). This draft focuses especially onlower NOx-emission standards and is based on the fact that over the passed years inparticular SNCR installation could significantly reduce there NOX emission. These arecompared to the currently in force standards in the Table 4-1.

Table 4-1 Indications for Stricter NOx-Emission Standards

Time interval 17. BImSchV, in force (D) 17. BImSchV, amendment proposal (D)

Half hourlyaverage

400 400

Daily average 200 150 2)

Yearly average 100 1) 100 2)

1) for firing capacity >50 MW2) for firing capacity > 50 MW, for old plants valid off 2019

The proposal covers a reduction or introduction of limits on the half hourly level to 400mg/Nm³, on the daily3 level to 150 mg/Nm³ and on the yearly level to 100 mg/Nm³ asnewly introduced standard.

No indications for future changes of emission standards were given by OVAM.

The tendency of stricter NOx-emission standards is accompanied by the already now notunusual requirement from (German) authorities to comply with only 50% of the NOx-emission standards expressed in the current legislation (refer to part 2.1.2).

In addition, stricter or new standards are proposed for dust, ammonia and thecontinuous measurement of the mercury emissions4 (refer to Table 4-2). Especially the

3 The here given final proposal of 150 mg/Nm³ (as daily limit) is a compromise between the original UBAproposal of 100 mg/Nm³ and the industry.

4 The WI-BREF refers to 11 measurement devices, and total costs are estimated with €35,000. There areno references given for ammonia slip measurement devices. Ammonia measurement is available andapplied, for example, at MVA Bonn, Germany, by Tunable Diode Laser Absorption Spectroscopy(TDLAS) (Berg/Heidrich 2006).


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monitoring of the ammonia slip would require a technical adaption at ISVAG becausethe ammonia slip is removed to the waste water cycle by the installed wet scrubbingsystem, and the possibly remaining slip in the clean flue gas is not measured at present.Another aspect with BAT-relevance is the continuous measurement of mercuryemissions which is referred to in the WI-BREF, and it is prescribed in German andAustrian waste incinerators (WI-BREF 2006, p. 140). WI-BREF mentions even lower BAT-associated emission limits for mercury (0.001-0.02 mg/Nm³ as daily average), and theammonia slip should be less than 10 mg/Nm³ on a daily level (WI-BREF 2006, p. 440 f.).

Table 4-2 Proposed Changes of the 17. BImSchV for Further Air Pollutant Emission Limits

Time interval

Dust(total)

Ammonia Mercury(continuous)

½ hourly average 15 (new)2)

0.052)

Daily average 51)2)

(before: 10) 102)

10 (new)2)

0.032)

Yearly average - 0.01 (new)1)3)

all values in mg/Nm³

1) for firing capacity >50 MW

2) valid from 2016

3) valid from 2019

In summary, it can be concluded that the presently valid BREF document (publishedversion from 2006) is based on data for the performance of WIP going back to the year2000-2002. Technical innovation in particular in the SNCR technology are followed bystricter ELV on the national basis as shown for the German case. It can be expected thatBAT associated emission levels defined in the BREF will be reduce after the review andreporting of all European WIP which will happen in 2014 in the context of the BREFrevision..

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4.1.2 Evaluation of the NOx-Emissions from ISVAG in the Context of BAT andfuture NOx-Emission Standards

In the Figure 2-1 it has been shown already that the NOx-emissions from ISVAG have afalling tendency since 2001. In the following, ISVAG will be assessed in the context ofBAT-associated NOx-emissions and the future enforcement of NOx-emission standards(refer to part 4.1.1).

For that purpose, the NOx-emissions from ISVAG are compared to the emission limitsthat are associated with the best available technique (BAT) standard. BAT-associatedNOx-emissions range from 120 to 180 mg/Nm³ on a daily level (refer to part 2.1.2). In theFigure 4-1 and Figure 4-2, the average daily NOx-emissions (non-validated) from ISVAGline 1 and 2 have been plotted as frequency diagrams for the years 2010 and 2011.

The positions of the frequency curves confirm that the daily NOx-emissions from ISVAGare in majority below the BAT-associated limit. In detail, at line 1 the lower BAT-limit(120 mg/Nm³) was exceeded 33 times (in 2010) and 4 times (in 2011) respectively. Atline 2, this was the case for 20 days (2010) and 16 days (2011), respectively.5 Theseresults apply for NOx-emissions that are not validated.6

5 The analysis has been carried out on the basis of the half hourly emission records that have beensubmitted by ISVAG. It has to be considered that this analysis is not a simulation of the installed officialemission computer. It was assumed that all submitted entries are valid and can be used for averagingon the daily and yearly level. From the yearly record of the half hourly emissions a certain number ofentries have been skipped because they cannot be considered valid. This is the case for emissionmeasurements during the purging process of the measurement device with nitrogen which occursevery 12 hours, and for negative and extreme values that result from faulty calculation of the NOx-concentration in the dry flue gas. Due to this data skipping, the total temporal coverage for the year2011 is only about 90%, i.e. 10% of the total half hourly measurements of a complete year are missing.For comparison, at MVR Rugenberger Damm, Hamburg, the temporal coverage is 100%. A temporalcoverage of 100% should also be the goal of ISVAG.

6 If emission validation was applied in this case, i.e. by subtracting 40 mg/Nm³, the number of exceedingcould have been neglected. In this study, this way of meeting emission limits is not considered BAT-conform (refer to part 4.1.3).


17

Year No. of data Max Min Arithmetic average No. of exceeding Class width

2011 352 161.1 69.6 101.5 4 (1.1%) 62010 349 169.6 62.1 105.7 33 (9.5%) 6

Figure 4-1 Distribution of the Daily Average NOx-Emission Concentrations, Line 1

BAT-associated emission limit range

BAT-associated emission limit range

18


2011 341 165.9 36.1 103.2 16 (4.7%) 72010 345 132.9 36.1 101.5 20 (5.8%) 7

Figure 4-2 Distribution of the Daily Average NOx-Emission Concentrations, Line 2

ISVAG is clearly below the UBA proposal of 150 mg/Nm³ as new daily average limit (referto part 4.1.1).

The frequency plot of the half hourly NOx-emissions for each of ISVAG’s combustionlines reveals that the NOx-emissions have developed in two aspects during the pastyears (refer to Figure 4-3 and Figure 4-4). On the one hand, the average yearly emissionhas decreased from about 150 to 100 mg/Nm³ (non-validated). On the other hand, since2010 the distribution has become narrower, i.e. there is less scattering of measurementswhich can be associated with a more robust NOx-removal process.


2011 15,977 349.7 22.9 101.3 4 (0.03%) 6

2010 15,727 315.8 24.9 105.6 2 (0.01%) 6

Proposed future half hourly limit (UBA)

Proposed future yearly limit (UBA)


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Figure 4-3 Frequency of NOx-emissions from 2007 until 2011 of Line 1

Evaluating the ISVAG emission data of 20117 for the expected lower limit of 300 mg/Nm³results only in 4 (line 1) and 17 (line 2) cases in an emission limit exceeding so that thisenforcement should not mean a major challenge for ISVAG. The distribution also showsthat the an emission level of 100 mg/Nm³ is nearly met in 2010 and 2011, already (i.e.even prior validation of the emissions). The 2011 NOx-emission from ISVAG is 102mg/Nm³. Thus, the plant should benefit from a more efficient NOx-removal technologyin order to comply with expected future emission limits, safely.

For the future, the strategy of ISVAG for further NOx-reduction consists in optimizing thecontrol algorithm for the urea injection into the flue gas. This was already successfullyimplemented in Line 2 in the year 2012. This focuses mainly at decreasing the nowexisting relatively long dead time between the concentration measurement and the ureainjection at a certain height level of the boilers.


2011 15,434 379.4 3.7 103.1 17 (0.11%) 6

2010 15,602 303.9 0.0 101.4 2 (0.01%) 6Figure 4-4 Frequency of NOx-emissions from 2007 until 2011 of Line 2

7 refer to foot note 5

Proposed future half hourly limit (UBA)

Proposed future yearly limit (UBA)

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Alternative options that focus on the analysis of the local temperature distribution influe gas section for a better dosage of the reduction agent, e.g. by acoustic gastemperature measurement systems (agam), are not planned. It is assumed that the fluegas temperature is locally homogenous in a certain furnace section due to refractorytailing and insulation that provides a relatively low heat transfer. In addition, the furnacedimension in the injection area is about 4 m x 4 m (for a waste throughput of 9 t/h)which is small in comparison to other waste incinerators (>21.5 t/h at MVR RugenbergerDamm, Hamburg). These aspects contribute to a stable temperature profile. However,the potential benefit of a spatially resolved temperature profile of the flue gas for amore precise urea injection at ISVAG is not clear until confirmed by respective test trialsor measurements. Tests and trial applications that are offered by suppliers8 for flue gascleaning equipment could reveal the existing potential of applying this approach forfurther NOx-removal.

4.1.3 Confidence of the emission measurements

For compliance with stricter emission limits it cannot be considered a BAT-conformstrategy to achieve this compliance through measurement validation with the maximumallowed uncertainty (refer to 2.1.3). Instead, measurement validation should alsoexpress and contain the precision of a measurement as a quality aspect that strengthensthe confidence in measurements of emissions. In other words, validation at ISVAGshould be applied with the known measurement uncertainty. This is, in principle,realized at waste incinerators in France, Great Britain or Germany. Although the WI-BREF does not explicitly refer to measurement validation, the Reference Document onthe General Principles of Monitoring (BREF code: MON) does underline the need toreport measurement uncertainties together with the actual measurements, especiallywhen emissions are very close limits (MON 2003, p. 16 ff., 53 ff.).

In detail, MON clearly recommends a concise definition of the procedures for emissionassessment including the consideration of the measurement uncertainty. Themeasurement uncertainty is an essential part of an assessment by measurements (MON2003, p. 53).

“10. Clearly state the compliance assessment procedures, i.e. how will themonitoring data be interpreted to assess compliance with the relevant limit (asshown in Chapter 6), also taking into account the uncertainty of the monitoringresult as explained in Section 2.6.” (MON 2003, p. 18)

8 E.g. Mehldau & Steinfath Umwelttechnik GmbH, Essen, Germany; with modern SNCR-technology, NOx-emission concentrations <100 mg/Nm³ and ammonia slip <10 mg/Nm³ are considered “state-of-the-art”, also for waste incinerators (von der Heide 2008; von der Heide/Langer 2010).


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“Information about the uncertainty associated with the data, the accuracy ofthesystems, the errors, the validation of the data, etc. should be available togetherwith the data.” (MON 2003, p. 31)

Due to the country specific validation methods mentioned in part 2.1.3, reportedemission values from European plants are not directly comparable to each other.According to the German Federal Environmental Agency (Umweltbundesamt, UBA), onlynon-validated emission concentrations should be considered for a comparison ofemissions from waste incinerators. This is an important constraint for this study becauseit has led to the requirement of accessing non-validated emissions, or the respectiveapplied validation algorithm in order to back calculate to non-validated emissions. Thelatter option implies accessing data (the size of the 95%-confidence interval) from thecalibration of a specific installed measurement system of a plant.

This study has shown that these data, as a basis for a comparison of plants, are difficultto access. In the majority, these data have been requested at certain plants andinstitutions but could not be accessed at all. They do not appear in the annual emissionreports and their submission is subject to the willingness of plant operators. Lobbyorganizations such as the German Interessengemeinschaft der ThermischenAbfallbehandlungsanlagen in Deutschland e.V. (ITAD e.V.), or the Confederation ofEuropean Waste to Energy Plants (CEWEP) cannot provide these information.

As a result of this study, the validation values of three German waste incinerators havebeen obtained and are given in the Table 4-3, together with the average daily emissions.All of these plants use an SNCR. The presented validation values have been obtained byinterviews or are result of calculations with data from 2010 and 2011. The averageemissions have been obtained from environmental reports published by the referenceplants.

Table 4-3 Values for NOx-Emission Validation and Average Emissions from Reference Plants

Plant Validationvalues (VB)[mg/Nm³]

Average NOx-emission concentrations[mg/Nm³]

validatedwith actualO2

validatedwith 11% O2**)

non-validatedwith 11% O2

Ref. Plant A 95 79 78Line a 0.55Line b 1.32Ref. Plant B 80 67 61Line a 4.15Line b 10.04Line c 3.29

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Ref. Plant C 78 65 63Lines a & b 3.84Lines c & d 0.86ISVAG 40 102*) estimation on the basis of a one-day’s-record of NOx-emissions**)assuming a average oxygen concentration of 9% in the fluegas

These results show that ISVAG can operate with a relatively high tolerance regarding theNOx-emission limit. In general, with this tolerance a measured NOx-concentration of 240mg/Nm³ would not mean an exceeding of the ELV (200 mg/Nm³). For the presentedreference plants this tolerance is much lower, in some cases it is much less than 10%.The difference between non-validated and validated measurements is not very high,compared to the average emission. This means that validation cannot have a majoreffect on the reported emissions. This comparison also shows that the consideredreference plants do not have a major advantage by validating emissions. With the givencontext and data, it can be assumed that the non-validated NOx-emissions from ISVAGare higher than the non-validated NOx-emissions from the reference plants (refer toTable 4-3). This low emission are achieved by optimized SNCR systems with multi-levelammonia injection, and temperature control by acoustical temperature messurement(AGAM) and an optimized firing control over the grate length.

Figure 4-5 Comparison of the Effect of NOx-Measurement Validation


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This situation is illustrated by the Figure 4-5 that shows the frequency curves ofvalidated and non-validated NOx-emissions of 2011 for ISVAG and a reference plant atwhich only a very small validation is applied (0.55 mg/Nm³). For the ISVAG plant avalidation of 40 mg/Nm³ has been taken into account to represent the possibletolerance existing for ISVAG9 with regard to measurement validation. In this aspect, theISVAG waste incinerator cannot be considered as a BAT plant because validation is notcarried out with the measurement uncertainty that exists for the waste incinerator. Thisalso reduces comparability of the ISVAG plant to others.

The calibration of the NOx-measurement system installed at ISVAG from 1995 showed ameasurement uncertainty ranging only from 5 to 12 mg/Nm³ (TÜV 1995, p. 11). But ithas to be considered that this uncertainty is not equivalent to the QAL-procedures ofDIN EN 14181, and thus are not equivalent to the applied measurement validationvalues of the reference plants in the Table 4-3 (refer also to 2.1.2). Thus, applying theinformation from calibration for validation of measurements according to DIN EN 14181would bring ISVAG into a comparable position with the reference plants in terms ofvalidation. On the other hand, a validation that is based on applying the specificmeasurement uncertainty is a clear point in favor of more transparency ofmeasurements because it allows evaluating the quality and the confidence in themeasurements.

4.1.4 Ammonia slip

A study of Keppel and Segher (Villani & de Greef 2013) carried out at the ISVAG WIP in2010 could show that both, the semi-wet and the wet, cleaning system contribute to lowammonia emissions. The ammonia slip depends on the targeted NOX emission but iseven at a level of 80 mg/Nm³ the ammonia emissions below 10 mg/Nm³. This test didmeasure ammonia concentration at different spots in the installation but did not aim atproducing certified emission recordings.

4.1.5 Transparency in Communication of Emissions

In addition to the above results of the assessment, potential for improvement is seen inthe way that emissions are communicated and presented by ISVAG to the public. Incontrast to the wide spread and usual way of presenting emissions by a single numberrepresenting the average with regard to a certain period, e.g. the yearly averageemission, in this study frequency diagrams have been employed. Diagrams of this typecontain information that contributes to increase the transparency of emission

9 It has to be taken into account that ISVAG does not validate emissions automatically by implementedalgorithms, in general, but the responsible authority may make use of the mentioned tolerance that isvalid for the ISVAG plant (40 mg/Nm³) if non-validated emissions exceed the emission limits.

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communication. For example, the distribution of the daily average emissions given in theFigure 4-1 includes at the same time the information how often the respective limit hasbeen exceeded in a given period. At the same time, the applied measurementuncertainty should be indicated as in the Figure 4-5 to underline the precision of theemission measurements. These transparency aspects are not only relevant for NOx-measurements, but for emitted pollutants in general, e.g. mercury. An example forcommunicating also statistical parameters describing the distribution of measurementsis given with the waste incinerator MHKW Würzburg, Germany, operated byZweckverband Abfallwirtschaft Raum Würzburg (ZVAWS). In the monthly emissionreports the average emissions are presented together with the corresponding recordedminimum and maximum emissions for each pollutant.10 It would give a good steptowards a maximum degree of emission transparency, if ISVAG implements a form ofcommunicating the generated emissions that includes frequencies and distribution. Thistype of data reporting is in particular suitable for the further optimization of reliable lowemission levels inside ISVAG..

4.1.6 Comparison with other plants

Since the BREF document on Waste incineration (EC 2006) only gives an overview of thetechnology level and associated emissions from approx. 10 years ago. A survey of all 70waste incineration plants for MSW and 31 waste incineration plants for RDF in Germanyshowed clear differences between the RDF and the MSW incinerators. For a bettercomparison the German emission values are also normalized to 11% oxygen reference11

considering that reported values are usually not normalized to the reference contentdue to a oxygen content of less than 11% in the flue gas.

10 publically accessible in the internet on http://www.zvaws.de/emissionen/berichte/Emissionsbericht-Dezember11.html

11 Assuming a average oxygen content of 9% in the dry flue gas.


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Figure 4-6 Boxplots of the NOX emission of German Incineration plant in 2010 (median, upperand lower quartile & min and max values).

Figure 4-6 shows that RDF incineration plans show generally higher emissions and areonly operated with SNCR. Relative to that, SNCR installations with MWS show a widerrange of emission level with some installation that reduced significantly their emissionlevel. The ISVAG plant has relative to most of the German SNCR installations lowemission. Nevertheless, approx 25% of the German SNCR plants show lower or similaremissions. It is also clear that most SCR installation are below the ISVAG emission level.Nevertheless energy efficiency consideration have to be considered in this assessment.While emission data are subject to reporting duties data on energy efficiency cannot beassessed on the Basis of publicly reported data. This suggests first to analyze thesituation regarding energy recovery of ISVAG relative to other installation with lowerNOX emissions.

4.2 Assessment of Consumption and Production Data

The recovery efficiency R 1 is used as a parameter for the assessment. In order todetermine this parameter, a system boundary has to be defined and the correspondingrelevant energy flows have to be determined as yearly averages. The energy flows itselfalso allows a BAT-assessment of the ISVAG waste incinerator.

4.2.1 System Boundary and Energy Flows

As already mentioned in part 2.2, the R 1-guideline describes the two options for ISVAGof being considered as electricity generator or heat supplier for the production of

200

100

N=36/37 N=23/29

WIPfor MSW

all technologies

N=10/31

WIP forMSWSCR

WIPfor MSWSNCR

WIPfor RDFSNCR

N=63/70

Emissionvalue

ISVAG2010

Litmitvalue WID

N=number ofinstallation with

available data/totalnumber of installation

concentration[mg/m³]11 vol.-% oxygen, 273.15 K, 1013.25 hPa

26

electricity. This means that the system boundary that is valid for the ISVAG plant has tobe clarified.

The R 1-guideline document gives two statements that support the view that ISVAGshould be considered as electricity supplier.

“The inclusion of the turbine into the R1 system boundaries is underpinned by the WIDrequesting combined heat and power recovery from waste to the extent possible (formore details see BREF document).” (EC 2011, p. 10)

“The technical unit used in the definition of the “incineration plant” (according to Art 3(4)WID) dedicated to the thermal treatment of wastes with recovery of the generatedcombustion heat, as specified in the corresponding WID permit, shall be the decisivefactor as regards inclusion or exclusion of scope of a turbine for generation of electricityand their consideration in the calculation of the R1 efficiency.” (EC 2011, p. 11)

In conclusion, an assessment of the BAT-status of ISVAG should take into account theelectricity production as produced energy and not the delivered heat to the turbine. Inaddition, the turbine forms part of the technical unit that is defined in the operationpermit of ISVAG (refer to 2.2). This is also an argument in pro of a system boundary thatcorresponds to ISVAG as electricity supplier. Therefore, the following calculations andresults are based on the energy flows that correspond to such a system boundary. In theFigure 4-7 the system boundary and relevant energy flows are given for the case ofISVAG.

The flow scheme contains Ew, Ef, Ei and Ep-elec as energy input streams into the system(refer to 2.2). As Ep-elec is the self-demand of electricity for ISVAG (excluding pumpdemand) supplied by the grid (and not by the electricity production on site), it will beconsidered as imported energy in the flow Ei. The self-demand of the pump is coveredby the produced electricity. Therefore, this energy flow is considered by subtractionfrom the gross produced energy (Ep-elec (bruto)), resulting in the electricity that is exportedto the grid (Ep-elec (grid)).


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Source: ISVAG (modified)Figure 4-7 Flow Scheme for ISVAG as Electricity Producer

The total delivered heat by the boiler (Ep-heat (bruto)) cannot be counted in order to avoiddouble counting (EC 2011, p. 13). As a consequence, the energy of the main condensatebackflow cannot be accounted for, either. Extracted steam flows from the turbine forfeed water pre-heating are considered produced process steam, and carrier of energyrecovered from the waste and used on site (Ep-heat 1, Ep-heat 2). According to the R 1-guideline, the condensate backflow from this internal source has to be considered bysubtracting the corresponding energy flow from Ep-heat 1 and Ep-heat 2 (EC 2011, p. 14).12

The energy input by imported fuels (in this case natural gas) for the steam generationprocess, boiler start-up and shutdown, and temperature maintenance is accounted forwith Ef. Natural gas is also used for other purposes than steam generation, and thisamount has to be accounted for as imported energy Ei.

The energy input by the waste is considered by Ew and is calculated by the yearlyaverage waste mass flow and the net calorific value (NCV) of the waste. At ISVAG, theNCV is determined by two approaches that lead to equal results for the NCV of thetreated waste. One realized approach is the application of the empirical determinationmethod given in the WI-BREF (2006, p. 83). Another calculation method used at ISVAG is

12 The R 1-guideline explicitly excludes „energy uses influencing the steam/heat production” from beingconsidered as produced energy Ep (EC 2011, p. 13). As pre-heating of feed water has an influence onthe steam and heat production, it can be discussed if it may be considered in Ep. Here, Ep-heat 1, and Ep-

heat 2 are accounted for because the criteria for “influence” are not clear from the guideline, andbecause they are recovered energy that is used on site.

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based on an energy balance of the plant. This approach is considered the best methodfrom the perspective of the R 1-guideline. In this context, the R 1-guideline also refers tospecific documentation and standards for the calculation of the NCV of waste in waste-to-energy plants.13

4.2.2 Energy Recovery Efficiency R 1

With the data of the total energy flows over the year 2010 provided by ISVAG, R 1 canbe determined (refer to part 3.3). The calculation of R 1 is given in the Table 4-4.

Table 4-4 Annual Energy Flows for the Determination of R 1 for 2010

Energy flows*) Unit RemarkEp-elec (grid) [GJ/a] = Ep-elec (bruto) - Ep-elec (self-demand) 301,380

Ep-elec (bruto) [GJ/a] Gross electricity production 314,945Ep-elec (self-demand) [GJ/a] Pump demand 13,566

Ep-heat [GJ/a] 154,570Ep-heat 1 [GJ/a] MP-steam extraction 41,183Ep-heat 2 [GJ/a] LP-steam extraction 29,095Ep-heat, backflow 1&2 [GJ/a] Condensate return 39,987

Ep [GJ/a] = Ep-elec (grid) x 2.6 + Ep-heat x 1.12.6 and 1.1 are the correspondingequivalence factors 953,614

Ef [GJ/a] Natural gas consumption for steamproduction 11,514

Ei [GJ/a] 100,044Ei-elec (self-demand) [GJ/a] Electricity demand of the boiler plant 37,518Ei-others [GJ/a] Natural gas consumption for other

usage than steam production 2,498Ew [GJ/a] = mwaste x NCVwaste 1,440,731

mwaste [t/a] Treated waste throughput 137,824

NCVwaste [MJ/t] Net calorific value of waste**) 10.5

R 1 [-] R 1 = E − (E + E )0.97 x (E + E ) 0.598

*) Energy flows are calculated for an average electricity output of 10 MWel in 2010**) NCV is determined according to the empirical method presented in WI-BREF (2006, p. 83)

Source: ISVAG (modified)

This result leads to the conclusion that the ISVAG waste incinerator, from a BAT-perspective, does not qualify for a plant that carries out energy recovery operationsaccording to WFD because it is operating below or very close to the threshold value 0.6.

13 Standard EN 12952-15, and ‘Acceptance Testing of Waste Incineration Plants with Grate Firing System’Guideline Edition 04/2000 by FDBR.


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This can be observed in the Table 4-5 that shows the yearly development of R 1 forISVAG, calculated as best case scenario, i.e. neglecting the energy demand of the pump(Ep-elec (self-demand)), the internally used energy for pre-heating (Ep-heat 1, Ep-heat 2) and thedemand for natural gas for non-steam-production usage (Ei-others).

Table 4-5 Development of R 1 (simplified calculation)

Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

R 1 [-] 0.499 0.510 0.559 0.518 0.527 0.526 0.527 0.540 0.556 0.564 0.555

With regard to an initial application for the R 1-status, the guideline recommends that“the plant operator shall demonstrate to its competent authority that the R1 thresholdwas met over the past three years, using the mean value over the whole period (“glidingaverage” using two decimal places)”, if it is operating close to the threshold (EC 2011, p.19).

However, achieving the R 1-status for ISVAG seems to be not a major challenge as thethreshold value is already met so that measures aiming at raising the production and/orreducing the consumption should be designed. In general, WI-BREF suggests combinedheat and power production as BAT-aspect (WI-BREF 2006, p. 434 f.). It would needfurther in-detail assessment of measures that could be effective for achieving the R 1-status.

The R 1-guideline offers the option to calculate and apply R 1 for each combustion line,separately, “when the line(s) operate independently or the flows of each part of theplant can be clearly distinguished and calculated separately” (EC 2011, p. 18). Thisoption could lead to different results but it has to be considered that both combustionlines supply steam for one turbine so that an adequate allocation of the electrical poweroutput to each combustion line would be necessary.

4.2.3 Production and Consumption of Energy

A waste incinerator can also be assessed on the basis of the data that have been usedfor the calculation of R 1. The specific gross electricity production of the ISVAG plantcontinues on a very high level in 2011 (refer to Figure 4-8). About 620 kWhel have beenproduced per ton of waste, which is a very good result in comparison to the BAT-associated production, ranging from 415 to 644 kWhel/twaste (WI-BREF 2006, p. 196).

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Figure 4-8 Specific Gross Electricity Production

Still, if the self-demand for the pump is subtracted from the gross production, thespecific exported electricity is 610 kWhel/twaste. Taking into account also the electricityself-demand of the boiler plant gives a specific electricity export value of 534kWhel/twaste. This clearly exceeds the maximum BAT-associated value of 458 kWhel/twaste,and it leads to the conclusion that the electricity demand of the whole ISVAG site is verysmall compared to BAT-levels. Indeed, with the average electricity consumption being103 kWhel/twaste in 2010, ISVAG is in the lower BAT-range from 62 (minimum) to 142(average) kWhel/twaste (WI-BREF 2006, p. 198). This is still true for the period from 2001to 2011, if the electricity consumption of the whole plant14 is taken into account. TheFigure 4-9 shows that the electricity consumption figures have been very stable for thepast years.

14 The annual electricity demand of Electrabel, i.e. the turbine plant, is assumed to be equal tothe consumption of 2010 for all the years (on average 27.9 kWhel/twaste).


31

Remark: The annual electricity demand of Electrabel, i.e. the turbine plant, is assumed to beequal to the consumption of 2010 for all the years (on average 27.9 kWhel/twaste).

Figure 4-9 Specific Electricity Consumption

For 2010, the electricity production, energy input by waste and natural gas for steamproduction correspond to an electrical efficiency of 18.2% (net) and 21.7% (gross) whichis very close to the maximum BAT-figures.

The strongest reduction of an energy flow could be observed for the yearly specificconsumption of natural gas. This has decreased from about 120 kWhth/twaste andcontinues now in a range between 20 and 30 kWhth/twaste (refer to Figure 4-10). Still,there is a lack of information with regard to the BAT-range of fuel consumption in wasteincinerators. As a reference, for MVR Rugenberg Damm, Hamburg, the primary energyuse, delivered by oil and natural gas, was 130 and 260 kWhth/twaste in 2009 and 2010,respectively (MVR 2011, p. 26). But the comparability of these figures is reducedbecause MVR, as a CHP plant, does also supply hot water and steam.

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Figure 4-10 Specific Natural Gas Consumption


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5 Conclusions and Recommendations

5.1 NOx-Emissions

5.1.1 NOX reduction potential

The ISVAG waste incinerator clearly continues the trend of the past years that NOx-emissions are decreasing since 2001. A major step in reducing emissions has beenrealized between 2009 and 2010. A further improvement that is shown by thedistribution of the NOx-emissions is less deviation from the average emission, i.e. anindication for process optimization.

From a BAT-point of view, ISVAG is operating mainly below the BAT-associated dailyemission limit of 120 mg/Nm³.

The assessment of the NOx-emissions from ISVAG came to the result that the plantwould be clearly below the proposed new daily limit of 150 mg/Nm³.

In the context of the revision of the BREF document it can be expected that BAT will belower on the basis of a new assessment of European plants. This confirms that ISVAGshould proceed in monitoring and improving the performance of its SNCR plant..

Switching to SCR technology would undoubtedly lower the emissions further, but wouldhave negative impact on energy efficiency and thus is not recommended.

5.1.2 Emission measurement techniques

ISVAG does not report validated emission data but only pure data with reference tostandard conditions. When comparing with other installation e.g. in Germany usuallyonly validated data are reported. The measurement uncertainty according to the QAL1-procedure and DIN EN 14181 is not determined for emission validation at ISVAG. Thisreduces the comparability of the ISVAG plant to other plants. The Reference Documenton the General Principles of Monitoring (MON) emphasizes the need to reportmeasurement uncertainties together with the actual measurements. This leads to therecommendation that the measurement uncertainty should be determined and appliedaccording to the existing standards, as it is realized for example in France, Great Britainor Germany. For ISVAG this would give the advantage that own emissions can be easiercompared with installation in other countries.

Together with the expected enforcement of the NOx-emission standards, a monitoringof the ammonia emissions may be expected. At ISVAG, the ammonia slip in the cleanflue gas is not measured at present. So, this would mean that technical adaption isrequired by implementing a new measurement device for this pollutant for emission

34

monitoring. First occasional measurements show that ISVAG will clearly stay below thelimit of 10 mg/Nm³ Ammonia slip.

With regard to the mercury emissions, continuous monitoring is explicitly referred to inthe document for best available technique (BREF), and it is already applied successfullyin certain European countries. Continuous mercury monitoring would add moretransparency to the emission profile of ISVAG. Also here the present emission valuesindicate that ISVAG stays significantly below the ELV. The specifics of the ISVAG Flue gascleaning system and the achieved values suggest a very good compliance with BATassociated emission levels.

5.1.3 Data reporting and communication

An emission presentation like in the examples of this study, i.e. including frequenciesand distribution parameters (e.g. minimum, maximum values, number of exceeding),would mean a rather progressive implementation of public emission reporting. Inparticular this is a good tool to monitor the progress in continuous emission reduction.

Finally, the temporal coverage of NOx-measurements at ISVAG is 90%, meaning that 10%of all half hourly average NOx-emissions of a year is not available due to the initiatedcleaning of the measurement device that is initiated every 12 hours. In the moment line1 is equipped with continuous measurement which is 100% online. On line 2 there is abadging process, with a measuring every 2 minutes. The results from this are also 100%online. In 2013, ISVAG will install measuring unit on Line 1 and 2 for continuousmeasuring.

5.2 Energy Flows

5.2.1 Status Energy Efficiency performance

With regard to BAT-indicators for electricity production and consumption, ISVAG resultsto be a waste incinerator that can be considered BAT.

The energy recovery efficiency in general is also a relevant BAT-parameter. There is stillnot a fully consistent way of determining e.g. by the WI-BREF or the WFD. The lattermethod has been used in this study to determine the recovery efficiency parameter R 1that showed to be a good indicator for the assessment of the ISVAG plant. Beingregulated by a European directive, R 1 is widely used and has legal character. For thatpurpose the EU published in June 2011 Guidelines on the R1 energy efficiency formula inAnnex II of Directive 2008/98/EC (EU, 2011).

It can be concluded from the R 1-guideline that the ISVAG waste incinerator should beconsidered as electricity producer, with the according system boundary that comprisesthe whole installation (including turbine and generator). Under these constraints ISVAGdoes not qualify for the R 1-status.


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5.2.2 Improving the Energy Efficiency performance

Beyond the uncertainties of systems boundaries, an analysis of the R1 performance ofISVAG over the years the years 2001-2010 shows variations between 0.53 and 0.59under consideration of one and the same calculation algorithm. This indicatesoperational differences of the energy efficiency performance over time. A further in-detail assessment for the reasons of those variations could help to identify measureseffective for achieving the R 1-status which in turn would confirm a BAT-status of ISVAG.In addition, this analysis allows to assess the options of improving NOX emissionsrelative to a potentially worse performance regarding the energy efficiency.

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References17. BImSchV (2003): Siebzehnte Verordnung zur Durchführung des Bundes-

Immissionsschutzgesetzes (Verordnung über die Verbrennung und die Mitverbrennungvon Abfällen - 17. BImSchV), Germany.

Amtsblatt (2011): „Unterrichtung der Öffentlichkeitüber die Ergebnisse derEmissionsmessungen im Müllheizkraftwerk Ruhlebender Berliner Stadtreinigungsbetriebe(BSR)für das Jahr 2010. Bekanntmachung vom 13. Mai 2011“, in: LandesverwaltungsamtBerlin (Hrsg.): Amtsblatt für Berlin. ABl. Nr. 21 / 27. 05. 2011, p. 932.

Berg, Peter/Heidrich, Rüdiger (2006): „Online optimiert - Rauchgas-Reinigung in derMüllverbrennung“, Deutscher Fachverlag (DFV), available online under: http://www.ask-eu.de/default.asp?Menue=20&ArtikelPPV=14011, accessed on: 2 Feb 2012.

Bianchin, Roland (2011): “Behördliche Emissionsüberwachung und alternative Verfahren“, in:Karl J. Thomé-Kozmiensky, Matthias Dombert, Andrea Versteyl, Wolfgang Rotard, MarkusAppel (Hrsg.): Immissionsschutz. Band 2– Planung, Genehmigung und Betrieb vonAnlagen –, Neuruppin: TK Verlag Thomé-Kozmiensky, p. 435-456.

BMU (2010): Bundeseinheitliche Praxis bei der Überwachung der Emissionen - RdSchr. d. BMU v.13.06.2005 - Az.: IG I 2 - 45053/5 und RdSchr. d. BMU v. 04.08.2010 - Az.: IG I 2- 51134/0.Bundesministerium für Umwelt, Naturschutz und Reaktorsicherheit (BMU), Germany.

BVA (2012): “BVA-digitaal”, digital table calculation sheet for the application of Besluitverbranden afvalstoffen (BVA), version 2012-1, provided through InfoMil for AgentschapNL, Ministerie van Economische Zaken, Landbouw en Innovatie, The Netherlands,available online under: http://www.infomil.nl/onderwerpen/klimaat-lucht/stookinstallaties/bva/, accessed on: 1 Feb 2012.

EC (2011): Guidelines on the Interpretation of the R1 Energy Efficiency Formula for IncinerationFacilities Dedicated to the Processing of Municipal Solid Waste According to Annex II ofDirective 2008/98/EC on Waste. Directorate-General Environment. EuropeanCommission. http://ec.europa.eu/environment/waste/framework/pdf/guidance.pdfaccessed on: 18 Dec 2012

IED (2010): “DIRECTIVE 2010/75/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of24 November 2010 on industrial emissions (integrated pollution prevention andcontrol)”, in: Official Journal of the European Communities, 17.12.2010, L 334/17-119.

Jaron, Andreas (2008): “Entwicklung neuer Rahmenbedingungen für die ThermischeAbfallbehandlung“, in: Bernd Bilitewski, Arnd I. Urban, Martin Faulstich (Hrsg.): 13.Fachtagung Thermische Abfallbehandlung. Schriftenreihe des Fachgebietes Abfalltechnik,Universität Kassel, Kassel: kassel university press GmbH, p. 9-20.

MON (2003): Integrated Pollution Prevention and Control. Reference Document on the GeneralPrinciples of Monitoring. European Commission.http://eippcb.jrc.es/reference/BREF/mon_bref_0703.pdf accessed on: 18 Dec 2012

MVR (2011): Sicher entsorgen – Sinnvoll verwerten. MVR Müllverwertung Rugenberger DammGmbH& Co. KG, Hamburg, Germany.

TÜV (1995): Bericht über die Ergänzungsprüfung der Mehrkomponenten-MesseinrichtungCEMAS-FTIR für H2O, CO2, SO2, CO, NO, HCl und NH3 der Firma Hartmann & Braun AG;Frankfurt am Main. TÜV-Bericht 936/803018/E. Institut für Umweltschutz undEnergietechnik, TÜV Rheinland.


37

VLAREM (2012): Titel II van het VLAREM – gecoördinerde versie 13 januari 2012. TheEnvironment, Nature and Energy Department, Flanders, Belgium.

von der Heide, Bernd (2008): „Ist das SNCR-Verfahren noch Stand der Technik?“, in: Karl J.Thomé-Kozmiensky (Hrsg.): Energie aus Abfall. Band 4, Neuruppin: TK Verlag Thomé-Kozmiensky

von der Heide, Bernd/Langer, Peter (2010): „Effizienz und Wartungsfreundlichkeit des SNCR-Verfahrens – Ein Erfahrungsbericht –“, in: Karl J. Thomé-Kozmiensky (Hrsg.): Energie ausAbfall. Band 7, Neuruppin: TK Verlag Thomé-Kozmiensky

WFD (2008): “DIRECTIVE 2008/98/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of19 November 2008 on waste and repealing certain Directives”, in: Official Journal of theEuropean Communities, 22.11.2008, L 312/3-30.

WI-BREF (2006): Integrated Pollution Prevention and Control. Reference Document on the BestAvailable Techniques for Waste Incineration. European Commission.

WID (2000): “DIRECTIVE 2000/76/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of4 December 2000 on the incineration of waste”, in: Official Journal of the EuropeanCommunities, 28.12.2000, L 332/91-111.

Rotter et al. (2010): Technical and Environmental Assessment of the Waste Incineration Plant ofISVAG Antwerp. Report. Chair of Solid Waste Management, Institute of EnvironmentalTechnology, Technical University of Berlin, Germany.

Villani, K.; de Greef J.: Performance limits of non-catalytic DeNOx in Waste-to-Energy plants . InEnergie aus Abfall, Band 10 TK Verlag: Neuruppin , 2013.

38

Annex

Annex A Excerpt from TÜV-Report: Uncertainty of NOx-measurementAnnex B Overzicht Exploitatie ISVAG periode 2001-2011Annex C Energie balans ISVAG 2010


39

Annex A Excerpt from TÜV-Report: Uncertainty of NOx-measurement

40

Annex B Overzicht Exploitatie ISVAG periode 2001-2011 (I)O

verz

icht

Exp

loita

tie IS

VA

G p

erio

de 2

001

- 201

1

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

Aan

voer

[ton/

j]11

7944

1203

9513

7860

1309

5213

8945

1448

1914

8050

1440

2714

2206

1392

2014

0563

Cal

oris

che

waa

rde

[GJ/

ton]

99.

59.

59.

910

.010

.710

.45

10.3

810

.26

10.1

310

.00

Doo

rzet

[ton/

j]11

6831

1191

6613

5718

1339

6413

8487

1453

2114

6871

1420

9213

9785

1372

1213

7824

[ton/

h]8.

137.

958.

188.

458.

728.

628.

988.

718.

648.

508.

60

Bes

chik

baar

heid

[%]

82%

86%

95%

90%

91%

96%

93%

93%

94%

94%

93%

Ben

utte

cap

acite

it[%

]78

.4%

80.0

%91

.1%

89.9

%92

.9%

97.5

%98

.6%

95.4

%93

.8%

92.1

%92

.5%

Bod

emas

[ton/

j]26

603

2516

927

749

2861

227

358

2859

331

141

2862

629

818

2868

325

941

[kg/

ton]

227.

721

1.2

204.

521

3.6

197.

519

6.8

212.

020

1.5

213.

320

9.0

188.

2

Sch

root

[ton/

j]32

2230

5330

7727

6632

1533

7929

2924

7525

0326

2727

74[k

g/to

n]27

.625

.622

.720

.623

.223

.319

.917

.417

.919

.120

.1

Ket

elas

[ton/

j]17

5512

270

00

082

00

00

[kg/

ton]

15.0

10.3

0.0

0.0

0.0

0.0

0.6

0.0

0.0

0.0

0.0

Vlie

gas

[ton/

j]10

1411

5826

7125

4526

4331

3929

6135

6032

8334

4733

31[k

g/to

n]8.

79.

719

.719

.019

.121

.620

.225

.123

.525

.124

.2

Res

idu

[ton/

j]12

4714

1913

8613

4815

6219

4920

9224

4221

7019

5518

36[k

g/to

n]10

.711

.910

.210

.111

.313

.414

.217

.215

.514

.213

.3

Kal

k[to

n/j]

1152

1163

969

862

1125

1281

1278

1356

1338

1157

1228

[kg/

ton]

9.9

9.8

7.1

6.4

8.1

8.8

8.7

9.5

9.6

8.4

8.9

Act

ieve

koo

l[to

n/j]

9192

4738

5046

5353

5067

36[k

g/to

n]0.

80.

80.

30.

30.

40.

30.

40.

40.

40.

50.

3

NaO

H[to

n/j]

316

402

629

518

393

683

719

582

524

525

448

[kg/

ton]

2.7

3.4

4.6

3.9

2.8

4.7

4.9

4.1

3.8

3.8

3.3

Ure

um[to

n/j]

223

293

170

360

341

782

576

612

672

650

609

[kg/

ton]

1.9

2.5

1.2

2.7

2.5

5.4

3.9

4.3

4.8

4.7

4.4

Pro

cesw

ater

[m³/j

]O

nvol

ledi

g84

239

6767

916

884

7239

781

524

8375

179

036

8800

484

626

7955

5[l/

ton]

Onv

olle

dig

707

499

126

523

561

570

556

630

617

577

Sta

dsw

ater

[m³/j

]O

nvol

ledi

gO

nvol

ledi

g21

494

7260

716

326

414

013

125

017

626

87[l/

ton]

Onv

olle

dig

Onv

olle

dig

158

542

12

11

21

19

Aandeel verbranding Aandeel rookgasreiniging


41

Annex B Overzicht Exploitatie ISVAG periode 2001-2011 (II)S

tof

[mg/

Nm

³]1.

081.

155

1.65

51.

171.

141.

195

1.12

0.99

50.

580.

720.

89[to

n/j]

0.86

839

0.97

816

1.72

181.

1285

51.

141

1.32

228

1.22

196

1.07

487

0.61

054

0.74

894

0.92

371

[g/to

n]7.

48.

212

.78.

48.

29.

18.

37.

64.

45.

56.

7[g

/kW

h]0.

013

0.01

50.

022

0.01

40.

014

0.01

50.

014

0.01

20.

007

0.00

90.

011

CO

[mg/

Nm

³]15

.811

.09.

211

.010

.314

.815

12.2

059.

7710

.41

13.4

110

.94

[ton/

j]12

.516

869.

4521

9.31

552

10.4

798

10.3

1115

.195

4712

.457

489.

7006

610

.415

3813

.532

7610

.657

24[g

/ton]

107.

179

.368

.678

.274

.510

4.6

84.8

68.3

74.5

98.6

77.3

[g/k

Wh]

0.18

90.

142

0.11

70.

133

0.12

60.

168

0.13

90.

110

0.11

70.

155

0.12

5

HC

l[m

g/N

m³]

0.6

0.5

0.4

0.3

0.2

0.3

0.3

0.5

0.6

0.2

0.2

[ton/

j]0.

5012

30.

4859

30.

4456

0.29

347

0.19

40.

3310

60.

3311

70.

5027

50.

6162

40.

2320

90.

1636

2[g

/ton]

4.3

4.1

3.3

2.2

1.4

2.3

2.3

3.5

4.4

1.7

1.2

[g/k

Wh]

0.00

80.

007

0.00

60.

004

0.00

20.

004

0.00

40.

006

0.00

70.

003

0.00

2

SO

2[m

g/N

m³]

9.4

4.7

12.1

13.7

13.8

6.6

4.4

1.9

0.8

2.7

2.0

[ton/

j]8.

0647

93.

9847

512

.130

4112

.976

213

.86.

9286

54.

4322

21.

8598

30.

7676

22.

9121

82.

0051

3[g

/ton]

69.0

33.4

89.4

96.9

99.6

47.7

30.2

13.1

5.5

21.2

14.5

[g/k

Wh]

0.12

20.

060

0.15

20.

165

0.16

90.

076

0.04

90.

021

0.00

90.

033

0.02

3

NO

2[m

g/N

m³]

177.

618

4.4

168.

615

4.1

188.

811

4.6

139.

914

8.4

134.

510

3.5

102.

2[to

n/j]

140.

8906

315

8.89

013

172.

4619

814

6.63

811

188.

384

118.

3891

714

3.65

507

149.

0654

113

7.92

2610

8.63

2610

1.55

25[g

/ton]

1205

.913

33.4

1270

.710

94.6

1360

.381

4.7

978.

110

49.1

986.

779

1.7

736.

8[g

/kW

h]2.

125

2.39

52.

158

1.86

82.

308

1.30

71.

598

1.68

71.

552

1.24

21.

189

CnH

m[m

g/N

m³]

0.4

0.2

0.1

0.2

0.1

0.1

0.1

0.2

0.1

0.3

0.1

[ton/

j]0.

3034

70.

1991

0.07

006

0.20

166

0.08

70.

1554

60.

1287

80.

1958

50.

1534

50.

2503

40.

1398

3[g

/ton]

2.6

1.7

0.5

1.5

0.6

1.1

0.9

1.4

1.1

1.8

1.0

[g/k

Wh]

0.00

50.

003

0.00

10.

003

0.00

10.

002

0.00

10.

002

0.00

20.

003

0.00

2

Dio

xine

s[n

g/N

m³]

0.03

260.

0249

0.01

760.

0145

0.02

080.

0122

0.01

080.

0130

0.00

720.

0074

0.00

69[g

/j]0.

0208

0.01

750.

0139

0.01

050.

0149

0.01

440.

0087

0.01

030.

0057

0.00

580.

0052

[g/to

n]2E

-07

1E-0

71E

-07

8E-0

81E

-07

1E-0

76E

-08

7E-0

84E

-08

4E-0

84E

-08

[g/k

Wh]

0.00

030.

0003

0.00

020.

0001

0.00

020.

0002

0.00

010.

0001

0.00

010.

0001

0.00

01

Afv

alw

ater

[m³/j

]86

0516

6034

915

710

347

90

00

00

[l/to

n]73

.713

.92.

61.

20.

73.

30.

00.

00.

00.

00.

0

Ene

rgie

prod

uctie

[kW

h]66

3118

3066

3433

6579

9328

1578

5038

5981

6212

7090

5746

0689

9026

7188

3376

7888

8663

8887

4847

8185

4417

66[k

Wh/

ton]

567.

655

6.7

589.

058

6.0

589.

462

3.3

612.

162

1.7

635.

763

7.6

619.

9

Ele

ktric

iteit

uit n

et[k

Wh]

1009

4038

1013

4687

1016

5432

1043

5070

1031

8923

1105

3532

1110

5130

1084

9478

1080

5411

1042

1594

1058

4095

[kW

h/to

n]86

.485

.074

.977

.974

.576

.175

.676

.477

.376

.076

.8

Aar

dgas

uit

net

[kW

h]14

0289

6146

0605

021

7558

256

5506

934

6055

427

5898

330

4639

228

0756

836

1780

638

9221

036

2482

8[k

Wh/

ton]

120.

138

.716

.042

.225

.019

.020

.719

.825

.928

.426

.3

Aandeel elektriciteitLozingEmissies lucht

42

Annex C Energie balans ISVAG 2010

Overzicht 2010 verbruik en produktie energie te ISVAG cv.

TotaalEnkel voor scenario 1 365Ew

Huisvuil verbruik GJ/mnd 1,440,731

Ep-Elec Self demand ISVAGOpgenomen ELEC-ISVAG kWh/mnd 10,421,594

GJ/mnd 37,518Ef-Usage of steam

Opgenomen AARDGAS kWh/mnd 3,198,242GJ/mnd 11,514

Ei-Without usage of steamOpgenomen AARDGAS kWh/mnd 693,968

GJ/mnd 2,498Ep-Heat Self demand (LP&MP)

Turbine aftap 1&2 MJ/mnd 194,556,654LP ton/mnd 29,095

MP ton/mnd 41,183GJ/mnd 194,557

Ep-Condensaat return (LP&MP)Ketelvoedingswater MJ/mnd 39,986,642

GJ/mnd 39,987Ep-Elec Self demand EBEL

Opgenomen ELEC-EBEL kWh/mnd 3,768,249GJ/mnd 13,566

Ep-Elec bruto produced MWel/h 10.0Geproduceerde ELEC-Bruto kWh/mnd 87,484,781

GJ/mnd 314,945

Enkel voor scenario 2Ep-Heat bruto

Outlet boiler 1&2 MJ/mnd 1,436,136,172GJ/mnd 1,436,136

Ep-Condensaat returnInlet boiler 1&2 MJ/mnd 283,685,309

GJ/mnd 283,685

Documents

Development of a monitoring concept for continuous BAT .... 2007-2011 Update of the... · for its Waste incineration installation and regularly prove the BAT ... eventhough ISVAG