Energy from Waste Technical Note
The NSW Government recognises that the recovery of energy and resources from the processing of waste has the potential – as part of an integrated approach to waste management and in accord with the waste management hierarchy – to deliver positive outcomes for the community and the environment.
The Energy from Waste Technical Note updates and replaces the 2021 NSW Energy from Waste Policy Statement. It complements the regulatory requirements for energy from waste in NSW by clearly setting out the minimum operational standards and requirements that will be applied to certain facilities proposing to thermally treat waste or waste-derived materials for the recovery of energy.
Part 4 of the Protection of the Environment Operations (General) Regulation 2022 (the Regulation) sets out the rules applying to energy from waste facilities in NSW.
The Regulation:
- establishes a general prohibition on the thermal treatment of waste if it involves or results in energy recovery from the waste (Section 143)
- sets out the definitions that apply within Part 4 (Section 142). The definitions of thermal treatment and waste within Section 142 list activities and wastes that are not subject to the prohibition.
- sets out certain exceptions to the prohibition (Section 144).
Facility Operational Requirements
Any facility proposing to thermally treat a waste or waste-derived material under the exceptions set out under Section 144 of the Regulation must show they will be using current international best practice techniques, particularly regarding:
- process design and control
- emission control equipment design and control
- emission monitoring with real-time feedback to the controls of the process
- arrangements for the receipt of waste
- management of residues from the energy recovery process.
Facilities must use technologies that are proven, well understood and capable of handling the expected variability and type of waste feedstock. This must be demonstrated through reference to existing operational facilities using the same technologies and treating like waste streams in other similar jurisdictions.
Technical criteria
Plant design and operation – incineration-based technologies
For incineration-based technologies, the gas resulting from the process should be raised, after the last injection of combustion air, in a controlled and homogenous fashion and even under the most unfavourable conditions to a minimum temperature of 850°C for at least two seconds (as measured near the inner wall or at another representative point of the combustion chamber).
The total organic carbon (TOC) or loss on ignition (LOI) content of the slag and bottom ashes must not be greater than 3% or 5%, respectively, of the dry weight of the material.
Waste feed interlocks are required to prevent waste from being fed to the facility when the required temperature has not been reached either at start-up or during operation.
The EPA will set operating conditions in environment protection licences for approved facilities.
Thermal efficiency criteria
Facilities must demonstrate that at least 25% of the lower heating value energy input of the thermally treated material will be recovered as useful energy.
Emission standards
Table 1 contains model emissions standards and monitoring requirements for incineration-based energy from waste facilities. These will be applied as a basis for assessing planning proposals and drafting licence conditions.
These standards represent what can be achieved by the application of best practice emissions management technology and are consistent with EU guidelines and the Protection of the Environment Operations (Clean Air) Regulation 2022 (Clean Air Regulation).
Facility proponents for other energy from waste technologies (e.g. gasification, pyrolysis) should contact the EPA to discuss the requirements that would apply to a proposed facility.
Air emission modelling assessment
An air quality impact assessment must be completed according to the Approved Methods for theModelling and Assessment of Air Pollutants in NSW to ensure that ambient air quality, the community and the environment will be protected across a range of operational scenarios and over the projected life of the facility.
Monitoring and reporting
The Clean Air Regulation requires testing for certain purposes to be conducted in accordance with test methods contained in the publication "Approved Methods for the Sampling and Analysis of Air Pollutants in NSW.
Validated emission monitoring data must be made available publicly through an online portal in near real time.
A weekly summary of continuous monitoring data and compliance with emissions limits must be published on the internet.
Table 1 – Model emissions standards for combustion-based EfW facilities
| Pollutant | Unit of measurement | 100th percentile concentration limit (1 hour average) | 100th percentile concentration limit (24 hour average) |
|---|---|---|---|
| Solid Particles (Total) | mg/m3 | 30 | 6.5 |
Nitrogen Oxides (NOx) | mg/m3 | 357 | 144 |
Sulphur Dioxide (SO2) | mg/m3 | 200 | 39 |
Hydrogen Chloride (HCl) | mg/m3 | 60 | 8.4 |
| Volatile Organic Compounds (VOC) | mg/m3 | 20 | 10 |
Hydrogen Fluoride (HF) | mg/m3 | 41 | - |
| Cadmium and thallium | mg/m3 | 0.021 | - |
| Mercury | mg/m3 | 0.0351 | - |
| Type 1 and Type 2 substances (in aggregate) | mg/m3 | 0.31 | - |
| Dioxins and furans | ng/m3 | 0.042 | - |
- Averaging period of a minimum of 30 minutes and a maximum of 8 hours as part of extractive testing as specified in the relevant test method, not measured continuously.
Averaging period of a minimum of 6 hours and a maximum of 8 hours as part of extractive testing as specified in the relevant test method, not measured continuously.
Expressed at dry, 273 K, 101.3 kPa and 11 % oxygen.
Proof of performance (POP)
As part of the environment protection licence conditions of all energy recovery facilities, the EPA will require operators to complete proof of performance (POP) testing to demonstrate compliance with air emissions standards. Proponents must provide a commissioning plan during the environment protection licence application stage, detailing the POP emission testing that will be undertaken.
Resource recovery requirements
Within the waste management hierarchy energy recovery sits below reuse and recycling and above disposal. It must only be used for waste streams where no other reasonable and feasible higher-order use opportunities are available for that waste. Energy from waste facilities may only receive:
- genuine residual waste from resource recovery and other waste processing facilities
- genuine residual waste from collection systems or other sources that have mandated or other appropriate resource recovery / source separation in place.
Proponents wishing to use waste or waste-derived materials for thermal energy recovery must be able to clearly demonstrate that the above requirements are met for each waste source.