The Air Quality NES

An Industry Perspective

Experience with the NES to date

> Several proposals for incineratorso Sewage sludgeo Biosecurity destruction of animal carcasseso Existing plant (old)

> Choosing sites for coal-fired industry

> Dealing with applications for timber mills

Incinerators - What is “hazardous waste”

> NES:- o characteristics in Annex III, OR o belongs to categories in Annex I but does not have

characteristics in Annex III

> BASEL, Article 1(a) :- o any category in Annex I, unless they do not possess any of the

characteristics in Annex III.

What is “hazardous waste”?

> Are the following wastes “hazardous”?

Sewage sludge yes (NES) no (Basel)

Dead stock yes (NES) no (Basel)

Untreated wood waste yes (NES) no (Basel)

Treated wood waste yes (NES) no (Basel)

> Was this intended. No?

What is a “high temperature” incinerator?

“designed and operated principally for burning hazardous waste at a temperature greater than 850 C as measured … ”

> Is a woodwaste boiler designed “principally” to make steam or to burn woodwaste?

> Where to measure?

> Okay to “operate” below 850?

Which combustion chamber?

Represent temperature in incinerator?

Okay to operate Below 850 C?

> Dioxinso Result from incomplete destruction of dioxins contained in

waste o In-furnace formation - from intermediate combustion products o De novo synthesis - generally 200-450C, possibly 1000-450 C

> EU Directive on Incineration of waste - operate above 850 C or 1100 C, depending on waste

> Operating below 850C may produce more discharges than the same incinerator operating above 850C

Resource Consents for PM10

> Discharge PM10 into an airshed?

> Likely to cause PM10 concentration to be above straight line path?

> Likely cause the airshed to breach the standard for PM10?

Discharge into airshed? - How far away?

Town

Site Option

Airshed boundary

Discharge into airshed?

Breach Straight Line Path or NES?

Hypothetical Projection of PM10 Concentrations

0

20

40

60

80

100

120

140

2000

2002

2004

2006

2008

2010

2012

2014

2016

2018

2020

Year

Pea

k C

on

cetr

atio

n

Actual

Straight line path

Consent term

Overall Impressions

> Amendment to definition of hazardous waste may help

> Questions will remain for some “incinerators”

> Uncertainty for any significant PM10 source located in or near urban areas

> Council or Ministry definitions of “airshed” and “straight line path” may not reduce this uncertainty

> Potential for significant differences in interpretation