Creating Energy from Waste
21 June 2020
Australian Government
Department of Industry, Science, Energy and Resources
TECHNOLOGY INVESTMENT ROADMAP DISCUSSION PAPER – SUBMISSION
Global AFR is a developer of small to medium size energy from waste (EfW) facilities. We use proven technologies and apply enhanced construction methods. We have partnered with UK developers that have delivered fully operational facilities and we have built up a significant and strong delivery team in Australia.
Due to the modular nature of Global AFR’s preferred technologies, they can be built quicker than traditional mass burn, for example, a small facility built by Syn2gen in Warwickshire England, took just 9 months to construct from financial close, although for the larger facilities in Australia we are allowing 18 months.
This submission provides recommendations that address two matters where the Department sought comment:
- Goals for leveraging private investment; and
- What broader issues, including infrastructure, skills, regulation or, planning, need to be workedthrough to enable priority technologies to be adopted at scale in Australia.A. OverviewEfW is widely accepted as a technology that can contribute to mitigation of greenhouse gas (GHG) emissions and their contribution to climate change. When using the US EPA life-cycle assessment model, every tonne of municipal waste diverted from landfill to an EfW facility, prevents the release of around one tonne of CO2 emissions through avoidance of methane generation, offset of GHG from fossil fuel electrical production, and recovery of metals1.
According to the German Federal Environment Agency “Diversion from landfill is the main contributor to GHG mitigation in the waste management sector”2.
1 B. Bahor, M. Van Brunt, K. Weitz, A. Szurgot, “Life Cycle Assessment of Waste Management Greenhouse Gas Emissions Using Municipal Waste Combustor Data” Journal of Environmental Engineering
2 The Climate Change Mitigation Potential of the Waste Sector, Öko-Institut and IFEU on behalf of German Federal Environment Agency (UBA), 2015Global AFR Pty Ltd ACN 636 707 634
info@globalafr.com www.globalafr.com P a g e | 1
Global AFR intends to develop Energy from Waste (EfW) facilities within Eco-Industrial Parks (EIPs) which will help Australia address its waste crisis and meet renewable energy goals.
At the core of the EIP concept is a medium-scale energy generation facility that uses pre-prepared refuse derived fuel or selected residual waste to generate useable energy (in the form of heating, cooling and electricity). This energy is distributed through an embedded grid to businesses co-located in the EIP. Energy is priced lower and without demand shocks improving business certainty, competitiveness and profitability. Compared to solar or wind, EfW facilities deliver jobs through construction and ongoing operations and by virtue of attracting new industries. As noted, EfW facilities divert waste from landfill, reduce GHG emissions and fossil fuel use and increase recycling.
Global AFR’s proposed EfW facilities support clean circular economy initiatives by using those parts of municipal, commercial and industrial waste that are not suitable for sustainable recycling. There is strong evidence that EfW compliments recycling initiatives. For example, across European countries, there is a strong correlation between rates of recycling and the number of EfW facilities to accept the remaining waste.
The UK and EU also deal productively with the three solid residues from an EfW process – Bottom Ash (IBA), Fly Ash (IFA) and Air Pollution Control residues (APCr).
B. EfWBiproducts
Unlike the UK and EU, Australia does not have regulations or construction standards that allows the productive application of the three solid residues of the EfW process. Without suitable standards, IBA, IFA and APCr must go to landfill at both a substantial cost to the operator and lost opportunity to further GHG reduction by using these biproducts in construction.
To be clear, it is currently illegal in Australia to use the three solid residues because there is no end of waste procedure/regulations. There are also no specifications written to allow this material to be used in road construction or concrete products. Therefore, all three biproducts must go to landfill squandering a useful resource and at substantial cost to the EfW operator.
B.1 Bottom Ash (IBA)
Under our proposed developments, and for other potential EfW operators, IBA disposal to landfill would be the largest single operational cost and would also squander a valuable resource. IBA is composed of inert, non-combustible materials that are left over after the combustion process: sand, stones and clinker and ash from burnt material. It also contains metals that are embedded in the residual waste, such as thin aluminium that cannot be separately collected. Metals such as steel, aluminium, copper and zinc can be recycled from the bottom ash. Every 1 tonne of metal recycled from the bottom ash reduces GHG emissions by an equivalent of 2,000kg CO2 when compared with using virgin ore.
Typically, in the EU, IBA comprises:
- 80-85% mineral fraction;
- 10-12% Ferrous metals; and
- 2-5% Non-Ferrous metals of which two-thirds is Aluminium.The process in Europe is to crush the IBA, then let the material stabilise for 6-20 weeks. Then the metals are removed, further crushed and screened to size to produce quality aggregate for road construction or into concrete.Aggregate from, IBA possesses similar properties to natural aggregates and offers significant environmental, social and environmental benefits:
- Reduced quarrying of primary aggregates resulting in an overall reduction in energy consumption when extracting, processing and transporting aggregate.
- Additional tonnages of ferrous and non-ferrous metals recovered for recycling.
- Avoids landfilling of IBA, meaning only a very small percentage of the residual waste is notput to beneficial use.
- Relatively low carbon footprint owing to lower energy required for production compared toprimary aggregates and sourced close to market.
- Improved project viability
- Creates long term employmentIn the UK and EU, aggregate from IBA has “End of Waste” approvals for use in the construction industry. Government bodies favour contractors who use such recycled materials in tenders.
B.2 Fly Ash (IFA)
In the EfW process, the air from the boiler goes through a “cyclone”, that extracts fine solids before moving through a cleaning stage. These solids are known as IFA and is usually analysed to assess whether it contains any dangerous material or hazardous properties. It represents a small percentage of the biproducts. The assessment and disposal will be undertaken in accordance with State Regulations. Ideally, this should be a single standard applied across Australia to avoid the inconsistencies and misunderstanding as EfW facility developers initiate planning and projects.
B.3 Air Pollution Control Residues (APCr)
From the “cyclone”, air is chemically treated with lime and activated carbon to remove acidic gases and heavy metals respectively. The particulate and reagent are removed from the process as APCr. APCr is classified as a hazardous waste and, in the absence of further treatment and alternative application, must be collected for disposal in a suitably licensed facility.
B.4 Treatment of Fly Ash and APCr
Rather than disposal as hazardous waste, IFA and APCr can be treated for further use, including processed into manufactured limestone. Treating IFA and APCr has better environmental outcomes and the process permanently captures more CO2 than is generated during its manufacture, which makes it a carbon-negative aggregate.
Again, in other countries, such as the UK, the processed IFA and APCr holds “end of waste” approvals for use as an aggregate in concrete products and in asphalt.
C. Funding the Australian Road Research Board (AARB)
The AARB is Australia’s peak body to research and establish end of waste standards and specifications for use of the three solid residuals. We believe that for a relatively modest outlay, establishing these standards and specifications will deliver major environmental and economic benefits.
Following discussions, the ARRB provided Global AFR with an estimate of $2.5M and $5M to fund research and develop a new specification on the use of IBA in construction. A similar cost is likely for an IFA and APCr specification. We have shared this letter with the Federal Assistant Minister for Waste Reduction and Environmental Management.
Under the new National Cabinet initiative, we would then seek national recognition of the specifications produced by the AARB as they have for other specifications. Then the three solid residues are no longer classified as waste and may be diverted from landfill to the construction industry. This has the potential to improve significantly recycling outcomes and count towards recycling and other environmental targets.
D. Private investment and regulation and planning initiatives
Developing EfW facilities is a complex and currently high-risk initiative in Australia. As developers, we must deal with three levels of Government as well as each States’ environmental and planning agencies who, though sometimes enthusiastic, have no experience in EfW facilities.
There are no regulations around matters that can be the difference between a viable EfW facility and 250,000 tonnes of waste going to landfill a year.
If actioned, Global AFR’s recommendations around “end of waste3” approvals would both encourage private investment in new EfW facilities, provide planning/licensing certainty as well as deliver smarter recycling, environmental and economic outcomes that can:
- Reduce GHG emissions;
- Reduce waste to landfill (and eliminate associated toxin and methane gas production);
- Increase recycling;3 End-of-waste criteria specify when certain waste ceases to be waste and obtains a status of a product (or a secondary raw material) from Directive 2008/98/EC on waste (Waste Framework Directive)
- Reduce reliance on virgin materials
- Provide import substitution;
- Minimise intergenerational burden of dealing with today’s waste (such as the leachate);
- Improve viability of EfW facilities and attract greater private investment; and
- Provide significant local investment and employment.Recommendations:To support development and private investment outcomes, we recommend:
- That the Australian Government fund the AARB to develop specifications, similar to those in place in the EU and UK:
- for the use of IBA as an aggregate, such as in roads and concrete; and
- for the use of treated APCr and IFA as an aggregate in concrete and roads.
- That the States’ Environmental Protection Agencies adopt the ARRB specifications, and for complying material agree, establish uniform regulations for end of waste use of IBA aggregateas well as treated IFA and APCr, in road and concrete products.
- That the Australian Government procurement practices favour use of recycled material ingovernment construction and funded projects.
Given the size of Government commitments to accelerating infrastructure development in response to the CoVid economic damage, procurement that favours recycled material would create a paradigm shift in Australia’s approach to these materials.
~~~
Finally, through our experience in the UK and modelling of Australian projects, we can demonstrate that investment in developing “End of Waste” specifications and adoption by State EPAs can improve environmental outcomes and encourage private industry solutions.
EfW facilities can be an important addition to Australia’s waste management and energy solutions. We would be pleased to discuss any aspect of our submission further.
Yours faithfully,
David G Hooper
Chief Executive Officer Global AFR
GlobalAFRPtyLtd ACN636707634
info@globalafr.com www.globalafr.com
