Some questions for the group. We have been asked to comply to the following regulation regarding operation of our thermal oxidiser. My questions are:
1. Can any technology anywhere in the world claim to comply to this regulation ? For example 99.99% destruction efficiency means that 100 ppmw of say formaldehyde in your process off-gas has to be reduced below 0.01 ppmw, which I am sure is well below the detection limit of available detection devices. How you demonstrate 99.9999% removal is another matter again. 2. How many pyrolysis plants are using the nuclear fission reactions that would be necessary to destroy the metals in their list ! 3. What work around are people using to deal with emissions regulations that appear impossible to comply with ? New South Wales PROTECTION OF THE ENVIRONMENT OPERATIONS (CLEAN AIR) REGULATION 2010 - REG 52 52 Destruction efficiency (1) Group 6 treatment plant (other than flares) must be operated in such a way that the destruction efficiency of the plant, in relation to an air impurity entering the plant, is: (a) if the air impurity originates from material containing any principal toxic air pollutant-more than 99.9999%, or (b) in any other case-more than 99.99%. (2) An enclosed ground-level flare for the treatment of landfill gas must be operated in such a way that the destruction efficiency of the flare, in relation to landfill gas entering the flare, is more than 98%. (3) A reference in this clause to the destruction efficiency of Group 6 treatment plant in relation to an air impurity (including landfill gas) is a reference to the destruction efficiency of the plant, in relation to the air impurity, calculated by using the following equation: DE = (1 - MWout / MWin ) x 100 "DE" is the destruction efficiency, expressed as a percentage. "MWout" is the mass emission rate of the air impurity in exhaust emissions prior to its release to the atmosphere using a 1 hour rolling averaging period. "MWin" is the mass feed rate of the air impurity in a waste feedstream using a 1 hour rolling averaging period. "principal toxic air pollutant" means any one or more of the following elements, compounds or classes of compounds: (a) acrolein, (b) acrylonitrile, (c) alpha chlorinated toluenes and benzoyl chloride, (d) arsenic and arsenic compounds, (e) benzene, (f) beryllium and beryllium compounds, (g) 1,3-butadiene, (h) cadmium and cadmium compounds, (i) chromium VI compounds, (j) 1,2-dichloroethane (ethylene dichloride), (k) dioxins or furans, (l) epichlorohydrin, (m) ethylene oxide, (n) formaldehyde, (o) hydrogen cyanide, (p) MDI (diphenylmethane diisocyanate), (q) nickel and nickel compounds, (r) PAH, as benzo[a]pyrene equivalent, (s) pentachlorophenol, (t) phosgene, (u) propylene oxide, (v) TDI (toluene-2,4-diisocyanate and toluene-2, 6-diisocyanate), (w) trichloroethylene, (x) vinyl chloride.
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