Standards and compliance guidelines

Energy from waste

The Energy from waste guideline (publication 1559) outlines how the Environment Protection Act and associated policies and Regulations are applied to the assessment of proposals that recover energy from waste (EfW).

The document provides high-level guidance for industry, government and the community on EPA’s expectations and requirements for the siting, design, construction and operation of such facilities. The guideline is consistent with the Victorian Government’s Getting full value: the Victorian Waste and Resource Recovery Policy.

The new publication is a revised version of the draft guideline (publication 1549), which was released for public comment between 6 September and 11 October 2013. Ten submissions were received and these were considered in finalising the guideline.

The table below sets out the key themes from public submissions received and EPA’s responses to them.

Summary of comment EPA response
  • As the document mainly focuses on thermal EfW, references to biological treatment should be removed in order to avoid confusion and focus relevance. Biological treatment should be covered in a separate document.

This document is the first guideline on EfW released by EPA. It is high level and includes all forms of EfW technologies so that stakeholders (including the community) have a holistic view of the topic and options.

The guideline does state that it primarily focuses on thermal technologies. It also contains useful information on biological treatment – including on the works approval assessment process, schedule categories, references to state environment protection policies and Regulations and combustion of biogas.

EPA intends to provide further guidance on biological treatment (particularly anaerobic digestion) in the future.

In relation to the statement that ‘recovery of energy should not compete with avoidance, reuse or recycling’:

  • EPA needs to elaborate on this statement and how it may be implemented. Given the significant project costs associated with EfW plants, proponents need certainty and security of supply, which will require long-term contracts to secure feedstock.

As part of the works approval process, EPA will assess the proposed feedstock, to ensure it is made of residual wastes, and the benefits and impacts of an EfW plant over the lifetime of a plant. However, once a works approval is issued, EPA will not revisit the approved waste feedstock and the removal of recyclables overtime is expected to be market-driven.

If the feedstock of an EfW facility changes to the point where emissions to the environment are likely to be altered significantly, a works approval will be required to ensure these emissions are still within acceptable limits.

EPA suggests that waste generators consider future diversion opportunities before signing long-term contracts with EfW providers and those EfW providers should not rely on a single source of supply.

  • Where EPA has documented that ‘a detailed analysis of the physical and chemical properties of the RDF should be performed’: greater clarity is required (for example, how often? how detailed?).

The detailed analysis is only required by EPA as part of the works approval process (either by the facility making the RDF, if scheduled, or by the facility using the RDF). Once the works approval is issued and the plant is operating, EPA will focus on controlling emissions to the environment by the plant using the RDF. As contaminants within the feedstock could impact these emissions, it is recommended that proponents carefully control the quality of their feedstock on an ongoing basis. 

The RDF assessment will focus on ensuring it does not contain recyclables, waste with no calorific value or contaminants. If contaminants are present (for example PIW), proponents will need to demonstrate that risks associated with these have been addressed.

  • EPA lists biofuels that can be used directly as feedstock in purpose-built boilers or as fuel replacement in existing facilities with limited risks to the environment and human health. It is unclear whether scheduled categories apply to these facilities.

The section on biofuels is called ‘waste acceptance and preparation for energy recovery’. This means that, if the waste meets the biofuel criteria, there is no need to seek approval from EPA before using it as feedstock for energy recovery. For example, untreated wood residue can be used directly in a boiler of small capacity, or biomass can be used in a small anaerobic digester. However, A07 and A08 scheduled categories still apply (due to the process rather than the feedstock). 

Thermal treatment of waste other than biofuel, even in small volumes, could trigger A02 (based on risk). 

This section has been clarified in the final document.

  • Where EPA has indicated that EfW plants need to have a thermal efficiency level of 0.65, it is suggested that this is modified to allow for smaller projects that may be less efficient.
  • A net positive thermal-efficiency level of 0.65 will only apply to sites that have larger waste streams, which will rule many smaller, regional waste streams out of contention. It is suggested to set different efficiency levels for different amounts of waste.

EPA acknowledges that the 0.65 threshold will be difficult to reach for small-scale projects, and this will be taken into consideration during the assessment of a proposal. As stated in the guideline, there will be a degree of flexibility and pragmatism in using the formulae. However, setting various thresholds would be very complex, as there are multiple factors that could cause the efficiency to drop off (such as feedstock, scale of operations or limited use of heat). Proponents are asked to aim for the highest efficiency possible, but with a degree of pragmatism and cost-effectiveness. 

The inclusion of the R1 formulae in the guideline is also a way to provide a consistent and transparent mechanism to assess the thermal efficiency of a plant.

  • The EfW guideline does not consider landfilling practices within scope (apart from landfill gas). The guideline should acknowledge that, where residual organic waste is commingled to the degree it is too costly to separate, or no market exists, the potential benefit of landfilling for renewable energy recovery is significant. Indeed, it is well established that there are potentially significant greenhouse gas benefits to modern landfills with gas capture over typical commercial composting.

Landfill gas is a by-product of the landfilling process and is therefore out of scope of the guideline. However, ‘out of scope’ does not mean EPA does not consider it as an option. It simply means it is not addressed as part of this guideline. Setting up bioreactors is already addressed in the Landfill best practice environmental management (BPEM) guideline (publication 788); therefore, there is no need to repeat the wording in this EfW guideline.

Further, recycling and recovery of energy should be considered as a preferred option, ahead of landfilling, as per the waste hierarchy. As landfilling is the last option on the hierarchy, waste that is too commingled/contaminated will end up there anyway. 

Where the harvested landfill gas is combusted to generate energy, it may become a scheduled activity (A08), depending on the capacity, and this part of the process is in scope of the EfW guideline, particularly from an air emission point of view.

Where EPA has stated that ‘the combustion of RDF as fuel replacement in an existing facility should have similar or reduced emissions to atmosphere in comparison to the emissions from the standard fuel it replaces’:

  • It would be beneficial if the guideline allowed RDF to be compared with the environmental outcomes of waste to landfill, not the gas or coal it replaces. This could be an ‘either/or’ criterion where benefits of RDF are permitted to be investigated, even if they are less favourable than traditional fuel sources.

Whilst the overall benefit to the Victorian environment is taken into account when assessing a proposal, it is difficult to directly compare two different geographical locations and two completely different technologies.

The original assessment of the air emission profile from an existing plant would have been based on a range of local factors, including the proximity of residential areas, the local environment and so on. Therefore, if this profile is likely to change, with levels of some contaminants decreasing and others increasing, a new assessment will be needed to determine whether the overall air emissions are still acceptable to the local environment. If the emission profile of an existing plant is significantly impacted, the proposals will likely be rejected, or technical modifications will be required (for example, to improve scrubbing efficiency).

Page last updated on 12 Aug 2015