Guideline A-7: Air Pollution Control, Design and Operation Guidelines for Municipal Waste Thermal
This guideline applies to new publicly or privately-owned incinerator systems designed to burn municipal waste, as well as to the expansion or modification of existing incinerators. The guideline reflects the installation of air pollution control systems, sets air emission limits for particulate matter, acid gases, metals and dioxins/furans and establishes requirements for the control, monitoring and performance testing of incineration systems.
On this page Skip this page navigation
Environmental Protection Act
R.R.O. 1990, Regulation 347 (General – Waste Management)
Ontario Regulation 419/05 (Air Pollution – Local Air Quality)
Director, Standards Development Branch Ministry of the Environment
Last Revision Date:
© 2010, Queen’s Printer for Ontario
1.0 Purpose and Introduction
The purpose of this guideline is to provide guidance to applicants applying for Certificates of Approval for municipal waste thermal treatment facilities under section 9 and Part V of the Environmental Protection Act (EPA). This guideline will set out minimum expected requirements that the Director may apply when exercising his or her discretion while considering applications on a case-by-case basis. Guideline A-7 should also be taken into account in meeting any requirements under the Environmental Assessment Act that may apply to the proposal. To the extent that this document sets out that something is “required” or “shall” be done or sets out a “requirement” or “limit”, it does so only to identify minimum expected requirements the application of which remain subject to the discretion of the Director.
During the review of applications for Certificates of Approval, the Ministry considers the requirements set out in applicable regulations as well as all applicable Ministry guidelines and policies. With this in mind, applicants for Certificates of Approval for municipal waste thermal treatment facilities should review this guideline with care while preparing their applications and supporting information for consideration by the Director.
This guideline sets out minimum recommendations for pollution control systems and maximum allowable “in-stack” contaminant emission levels from municipal waste thermal treatment facilities in Ontario. The guideline also sets out recommendations for acceptable design and operating parameters for thermal treatment facilities utilizing conventional incineration technology and other combustion equipment associated with municipal waste thermal treatment facilities.
Guideline A-7 applies to all thermal treatment facilities processing municipal waste including manufacturing facilities, such as cement and lime kilns, if they use municipal waste as an alternative fuel. This guideline also applies to other sites that combust (with or without energy recovery) any materials/ by-products resulting from the municipal waste thermal treatment process (e.g., synthesis gas, solids and/or liquids). It also covers pilot scale operations involving thermal treatment of municipal waste. However, where the operation of an experimental facility is proposed to be limited to thermal treatment of not more than 50 tonnes of municipal waste per year as a condition of a Certificate of Approval some of the requirements of this guideline may not apply.
Guideline A-7 does not apply to thermal treatment facilities where municipal waste is processed to produce gases, solids and/or liquids for use as raw material in a manufacturing process that does not involve combustion (with or without energy recovery) of those gases, solids and/ or liquids at the thermal treatment facility or the manufacturing facility. Additionally, this guideline does not apply to thermal treatment facilities that burn or otherwise thermally treat biomedical or other hazardous waste, or biomass, such as sewage sludge or woodwaste, either exclusively or in combination with a conventional fossil fuel.
The limits in this guideline for dioxins and furans, cadmium, lead, mercury, particulate matter and acid gases are technology based, developed using the maximum achievable control technology (MACT) principle, which is similar to the approach taken by other jurisdictions. In the United States major sources are expected to comply with standards that require the maximum degree of reduction in emissions of hazardous air pollutants. These MACT standards are based on the emission levels already achieved by best- performing similar facilities. This performance-based approach yields standards that are both reasonable and effective in reducing contaminant emissions.
While state-of-the-art facilities are capable of achieving very low dioxin and furan emission levels and often report values below the Level of Quantification, the numerical value for the dioxin and furan limit in this guideline remains the same (80 pg I-TEQ/Rm3) as in the previous version of Guideline A-7 (February 2004). The limit of 80 pg I-TEQ/Rm3 is also the Canada Wide Standard (CWS) and the lowest limit established by any jurisdiction for municipal waste thermal treatment facilities. The Ministry will continue to review technical advancements worldwide as well as regulatory developments in other jurisdictions, and if more stringent limits are established, including an updated CWS, Guideline A-7 may be updated accordingly.
Stringent technology based limits ensure that municipal waste thermal treatment facilities in Ontario incorporate state-of-the-art process and control equipment as well as best operational practices. This in turn will ensure that emissions discharged from municipal waste thermal treatment facilities are as low as technically feasible. Protection against potential environmental and health impacts is then confirmed through a technical review involving dispersion modeling of the estimated emissions and comparison of the results with air standards in Ontario Regulation 419/05 (Air Pollution – Local Air Quality). This Regulation also requires that all municipal waste thermal treatment facilities comply with a concentration limit for organic matter in Section 50 and a limit for opacity in section 46. All proponents of municipal waste thermal treatment facilities must demonstrate an ability to comply with Ontario Regulation 419/05 when submitting an application for a Certificate of Approval.
Thermal treatment facilities may also include other sources of air emissions, particularly odor and dust, aside from the stack that discharges emissions from the thermal treatment process. Owners and operators are expected to incorporate equipment and/ or measures to minimize contaminant emissions from all sources, including unpaved roadways, waste storage and handling, shredding equipment, ash cooling and handling etc. Emissions from all sources will be considered during the review of applications for Certificates of Approval. Proponents should refer to the document “Procedure for Preparing an Emission Summary and Dispersion Modelling Report” for guidance on preparing an Emission Summary and Dispersion Modeling report for a proposed facility.
It is noted that if the requirements set out in this guideline, including the in-stack concentration limits for contaminants, are incorporated into a Certificate of Approval, compliance with these in-stack limits is expected to result in compliance with the point- of-impingement concentration standards, i.e. air standards, for those same contaminants currently set out in Ontario Regulation 419/05 and required to be met at any point in the natural environment. In accordance with Guideline A-7, Certificates of Approval for municipal waste thermal treatment facilities can also include organic matter and opacity limits that are more stringent than in Ontario Regulation 419/05.
2.0 In-Stack Concentration Limits
2.1 Limits for Municipal Waste Thermal Treatment Facilities excluding Cement and Lime Kilns
Facilities that thermally treat municipal waste or that combust materials/ by-products from thermal treatment of municipal waste are expected to meet the emission limits in the stack (or as otherwise specified) as set out in Table 1 of this Guideline.
Most of the concentration limits are expected to be complied with in the stack that discharges contaminants to the natural environment from the municipal waste thermal treatment process. It is noted, however, that the limits for organic matter and carbon monoxide are set out for the purpose of process control, i.e. to ensure good combustion in the piece of equipment that is used for combustion of gases generated during the thermal treatment of municipal waste. Therefore, the limits for organic matter and carbon monoxide are expected to be complied within the undiluted gases exiting such combustion equipment.
If other Ministry guidelines apply to any part of a thermal treatment facility, it can be expected that the requirements and/ or emission limits in all relevant guidelines will be considered and, where any limits or other apparent requirements are to be incorporated into a Certificate of Approval, the most stringent applicable requirements and/ or emission limits from those guidelines will likely be applied.
|Parameter||In-Stack Emission Limit||Verification of Compliance|
|particulate matter (PM)||14 mg/Rm3||Results from compliance source testing or calculated as the rolling arithmetic average of four (4) hours of data before dilution with any other gaseous stream, measured by a continuous emission monitoring system that provides data at least once every fifteen minutes|
|cadmium||7 µg/Rm3||Results from compliance source testing|
|lead||60 µg/Rm3||Results from compliance source testing|
|mercury||20 µg/Rm3||Results from compliance source testing or calculated as the rolling arithmetic average of 24 hours of data measured by a continuous emission monitoring system that provides data at least once every 15 minutes|
|dioxins and furans||80 pg/Rm3||Results from compliance source testing; results expressed as I-TEQ|
|hydrochloric acid (HCl)||18 ppmdv (27 mg/Rm3)|
or an HCl removal efficiency of not less than 95%
|Results from compliance source testing or calculated as the rolling arithmetic average of 24 hours of data measured by a continuous emission monitoring system that provides data at least once every 15 minutes|
|sulphur dioxide (SO2)||21 ppmdv (56 mg/Rm3)||Results from compliance source testing or calculated as the rolling arithmetic average of 24 hours of data measured by a continuous emission monitoring system that provides data at least once every 15 minutes|
|nitrogen oxides (NOx)||105 ppmdv (198 mg/Rm3)|
|organic matter (undiluted, expressed as equivalent methane)||50 ppmdv (33 mg/Rm3)||Results from compliance source testing or calculated as the rolling arithmetic average of 10 minutes of data at the outlet of the piece of equipment where combustion of the gas stream resulting from thermal treatment of waste is completed but before dilution with any other gaseous stream takes place, measured by a continuous emission monitoring system that provides data at least once every minute|
|carbon monoxide||35 ppmdv (40 mg/Rm3)||calculated as the rolling arithmetic average of four (4) hours of data at the outlet of the piece of equipment where combustion of the gas stream resulting from thermal treatment of waste is completed but before dilution with any other gaseous stream, measured by a continuous emission monitoring system that provides data at least once every fifteen minutes|
|opacity||10 percent||calculated as the rolling arithmetic average of six (6) minutes of data measured by a continuous emission monitoring system that provides data at least once every minute|
|opacity||5 percent||calculated as the rolling arithmetic average of two (2) hours of data measured by a continuous emission monitoring system that provides data at least once every fifteen minutes|
2.2 Limits for Existing Cement and Lime Kilns Burning Municipal Waste
Regardless of the fuel burnt, cement and lime kilns discharge many of the same contaminants (e.g. particulate matter, metals, nitrogen oxides, sulphur dioxide etc.) into the natural environment as dedicated municipal waste thermal treatment facilities.
Manufacturing of one tonne of cement clinker requires approximately 1.5 tonnes of raw materials (e.g. limestone), and approximately one tenth of a tonne of coal or alternate fuel of the same heating value. As such, cement manufacturing emissions are highly influenced not only by the properties of the combusted fuel, but by the properties of the raw materials processed. As the properties of both the raw materials and the fuels vary, emissions from cement manufacturing facilities, particularly emissions of mercury, sulphur dioxide and total hydrocarbons, also vary.
In order to reduce reliance on fossil fuels energy intensive industries worldwide are continuously seeking alternative energy sources. Along with a number of different types of waste materials and residues, certain fractions of municipal waste have been used successfully to replace coal and other conventional fuels particularly in Europe and also in Quebec, British Columbia, Nova Scotia and numerous states in the United States of America. The use of these alternative energy sources will avoid emissions that would result from burning of the existing fossil fuels, mostly coal and petroleum coke.
In accordance with R.R.O. 1990, Regulation 347 burning or co-incineration of waste in cement and lime kilns is considered thermal treatment of waste. Therefore, Certificates of Approval issued to existing cement and lime kilns to burn municipal waste (except biomass type waste only) as an alternative fuel can be expected to include in-stack emission limits in accordance with Table 2 of this guideline. Requirements for cement or lime kilns burning only biomass type waste as an alternative fuel would be established on a case by case basis during review of applications for Certificates of Approval for such proposals.
The following notes apply to Table 2:
- If there is no limit for particulate matter in an existing Certificate of Approval issued to the facility, the limit of 50 mg/Rm3 can be expected to be included in the Certificate of Approval that will allow burning of municipal waste as an alternative fuel. Where a more stringent site-specific limit for particulate matter is already incorporated into an existing Certificate of Approval for manufacturing of cement or lime using existing raw materials and conventional fuels, the existing limit will be retained if it is more stringent than 50 mg/Rm3.
- Limits for cadmium, lead and mercury set out in Table 2 can be expected to be included in a Certificate of Approval that will allow burning of municipal waste as an alternative fuel, unless the proponent can demonstrate that one or more of the specified metals are present in the existing raw materials and conventional fuels in such a quantity that the relevant limit(s) would be exceeded without the use of municipal waste as a fuel. In such a case, site-specific limits for one or more of the above metals may be established and incorporated into a Certificate of Approval. The site specific limits can be expected to be developed based on a review of relevant facility specific data that includes information on the discharge of cadmium, lead and/ or mercury from the facility (e.g. source testing data, analytical data for raw materials, mass balance calculations). Such site specific limits will take into account the variability of the raw material composition.
- It is expected that cement and lime kilns can comply with the hydrogen chloride (HCl) limit in Table 2. A site-specific emission limit for HCl may, however, be incorporated into a Certificate of Approval based on HCl concentrations when using existing raw materials and conventional fuels. This will prevent any increase in HCl emissions resulting from use of municipal waste as fuel for the kiln.
- A site-specific emission limit for sulphur dioxide (SO2) can be expected to be incorporated into a Certificate of Approval based on SO2 concentrations when burning conventional fuels. This will prevent any increase in SO2 emissions resulting from use of municipal waste as fuel for the kiln. For kilns required to use continuous emission monitoring (or a method that will provide estimates of emissions that are at least as accurate as the estimates that would be provided by a continuous emission monitoring system) for SO2 under Ontario Regulation 194/05 (Industry Emissions — Nitrogen Oxides and Sulphur Dioxide), the limit will be determined based on a review of a minimum of 6-months of Continuous Emission Monitoring System (CEMS) data (or data obtained using another method) for the kiln (1-hour, 24-hour and 30-day SO2 averages in ppmdv or mg/Rm3). The Ministry will continue to monitor the development of SO2 control technology worldwide. As new proven technology is developed suitable for this industry sector, the Ministry will review this guideline to determine if limits can be adjusted.
- A site-specific emission limit for oxides of nitrogen (NOx) can be expected to be incorporated into a Certificate of Approval based on NOx concentrations when burning conventional fuels. This will prevent any increase in NOx emissions resulting from use of municipal waste as fuel for the kiln. For kilns required to use continuous emission monitoring (or a method that will provide estimates of emission that are at least as accurate as the estimates that would be provided by a continuous emission monitoring system) for NOx under Ontario Regulation 194/05, the limit will be determined based on a review of a minimum of 6-months of CEMS data (or data obtained using another method) for the kiln (1-hour, 24- hour and 30-day NOx averages in ppmdv or mg/Rm3). The Ministry will continue to monitor the development of NOx control technology worldwide. As new proven technology is developed suitable for this industry sector, the Ministry will review this guideline to determine if limits can be adjusted.
- Lime kilns that do not currently have CEMS for SO2, and NOx, can be expected to carry out a monitoring program to determine the normal ranges for the parameters when burning conventional fuels. The proponent of an alternate fuel should consult staff of the Ministry when planning such a program. The results of the monitoring program are expected to be included with an application for a Certificate of Approval to burn municipal waste as an alternate fuel.
|Parameter||In-Stack Emission Limit||Verification of Compliance|
|particulate matter (PM)||50 mg/Rm3 or a site specific emission limit where a more stringent stack concentration limit is already in place for existing raw materials and conventional fuels (1)||Results from compliance source testing or calculated as the rolling arithmetic average of four (4) hours of data measured by a continuous emission monitoring system that provides data least once every fifteen minutes|
|cadmium (Cd)||7 µg/Rm3 unless existing raw materials and conventional fuels result in higher concentration (2)||Results from compliance source testing|
|lead (Pb)||60 µg/Rm3 unless existing raw materials and conventional fuels result in higher concentration (2)||Results from compliance source testing|
|mercury (Hg)||20 µg/Rm3 unless existing raw materials and conventional fuels result in higher concentration (2)|
|dioxins and furans||80 pg/Rm3||Results from compliance source testing; results expressed as I-TEQ|
|hydrochloric acid (HCl)||18 ppmdv (27 mg/Rm3) unless existing raw materials and conventional fuels result in higher concentration (3)||calculated as the rolling arithmetic average of 24 hours of data measured by a continuous emission monitoring system that provides data at least once every 15 minutes|
|sulphur dioxide (SO2)||Site specific limit not to exceed the in-stack SO2 concentration resulting from existing raw materials and conventional fuels. (4, 6)||calculated as the rolling arithmetic average of 24 hours of data measured by a continuous emission monitoring system that provides data at least once every 15 minutes|
|nitrogen oxides (NOx)||Site specific limit not to exceed the in-stack NOx concentration resulting from existing raw materials and fossil fuels (5, 6)||calculated as the rolling arithmetic average of 24 hours of data measured by a continuous emission monitoring system that provides data at least once every 15 minutes|
|organic matter||Section 50 (2) of Ontario Regulation 419/05||calculated as the rolling arithmetic average of 10 minutes of data measured by a continuous emission monitoring system that provides data at least once every minute|
|opacity||Section 46 of Ontario Regulation 419/05||calculated as the rolling arithmetic average of six (6) minutes of data measured by a continuous opacity monitor that provides data at least once every minute|
2.3 Other Industrial Processes Involving Thermal Treatment of Municipal Waste
This guideline will also apply to other industrial processes, aside from cement and lime kilns that use thermal treatment equipment to process municipal waste. If, however, it can be demonstrated that the limits in this guideline are not consistent with the MACT principle, different limits may be set out in Certificates of Approval.
2.4 Thermal Treatment Equipment Used to Process Municipal Waste Together with Other Waste
If municipal waste is proposed to be processed together with some other type of waste in a thermal treatment facility, the owner and operator of the facility can expect that the Director will develop his or her conditions of approval based on the waste type that warrants the most stringent limits and/ or other requirements.
Non-hazardous waste that is predominantly wood but does not meet the definition of woodwaste provided in Regulation 347 is considered to be municipal waste. For instance, rail ties and utility poles are usually treated with chemicals that place them outside the definition of woodwaste. This guideline applies to thermal treatment of rail ties and utility poles when they are proposed to be thermally treated either alone or together with other municipal waste.
On the other hand, if a proponent wishes to thermally treat a mixture of woodwaste and waste that is predominantly wood, such as railway ties or utility poles, the air emission requirements for such a facility will be established on a case by case basis. Special attention should be paid to chlorine content of the waste, presence of chlorinated organics and trace metals, particularly copper, all of which may contribute to increased emissions of dioxins and furans. Proponents should also include suitable control and monitoring equipment in the application for a Certificate of Approval. Additionally, the application should include proposed emission and operational limits that take into consideration the technology and its capabilities and that are based on credible emission data from the existing facility or emissions from a similar facility. Submissions must include detailed information to support development of site specific limits. It is also important to note that a “woodwaste combustor site”, as defined in Regulation 347, can thermally treat only “woodwaste”. A waste approval under part V of the EPA would be required for a mixed waste facility.
3.0 Continuous and Long-term Monitoring
3.1 Continuous Monitoring and Control Systems
Thermal treatment facilities, including facilities that combust materials/ by-products from thermal treatment of municipal waste, are expected to be equipped with control and monitoring systems to indicate and confirm compliance with the limits of this guideline, as set out in conditions included in a Certificate of Approval as well as with requirements in any applicable regulations. Such systems are expected to be capable of readily indicating any aspect of a substandard operation, i.e. excursions outside the acceptable operating window established during initial performance testing. They are also expected to be capable of adjusting or modifying appropriate operating conditions to maintain compliance with the limits of this guideline, regulations and conditions of approval at all times.
Continuous monitoring systems at municipal waste thermal treatment facilities typically include many operational parameters all of which may not be specifically mentioned in this Guideline. For instance, continuous monitoring may be necessary for a pressure drop across air pollution control equipment, pH level for scrubbing media, flow rates etc. In addition, continuous monitoring and data acquisition systems typically include alarm functionality to alert operating personnel of any situations that have resulted or are likely to result, if not corrected, in operation outside the acceptable operating window. Certificates of Approval may include requirements for visible and audible alarms for operational parameters as well as for contaminants, with details determined during the approval process. Similarly waste feed cut off and facility shut down requirements based on continuous monitoring results may be determined during the approval process for inclusion of appropriate conditions on the facility’s Certificate of Approval.
Continuous monitoring systems are expected to be capable of providing accurate and representative measurements of the relevant parameters, and they are expected to be equipped with recording devices for subsequent reference and analysis to assist in confirming compliance with conditions of approval and generally assessing performance of the thermal treatment facility. The continuous monitoring systems shall comply with the principles of the Environment Canada document “Protocols and Performance Specifications for Continuous Monitoring of Gaseous Emissions from Thermal Power Generation” (Report EPS 1/PG/7, as amended in December 2005 or later) or any equivalent protocols as well as performance specifications approved under section 9 of the EPA. While EPS 1/PG/7 is written for power generation facilities and for monitoring of specific parameters, the principles apply to other facilities and other continuous monitoring instruments and parameters. Detailed performance specifications for all continuous monitoring systems can be expected to be set out in the Certificates of Approval issued to facilities that are required to include such systems.
Location of the measurement points for various parameters will depend on the parameter itself as well as the design and layout of the thermal treatment facility. For some of the parameters the measurement location is the stack that discharges contaminants from the municipal waste thermal treatment facility into the atmosphere. However, for operational parameters the monitoring locations will be dictated by the need to have control over the operating conditions; i.e. the parameter needs to be monitored where the parameter is considered to be critical for the performance of either the thermal treatment process or associated pollution control equipment. For instance, the Director may decide that it is important to have a temperature limit not only for the combustion zone but also for some other locations at the facility, such as the entrance to and/ or exit from a pollution control device. Similarly levels of oxygen, carbon monoxide and/ or organic matter are usually monitored in the undiluted gases exiting a combustion device, such as a secondary chamber of a conventional two-stage incinerator with the data being fed into a computerized control loop to ensure good combustion control. The instruments that monitor process parameters are expected to be part of a system that can adjust the operation of the facility in order to ensure the operation remains within the acceptable operating envelope determined during commencement of operation and initial performance testing.
3.2 Continuously Monitored Parameters
Parameters that will be considered for continuous monitoring include:
- organic matter
- carbon monoxide
- residual oxygen
- volumetric flow rate of the flue gas
- hydrogen chloride
- sulphur dioxide
- nitrogen oxides
- particulate matter
Other parameters that may also be considered for continuous or long-term monitoring include:
- carbon dioxide
- hydrogen fluoride
- dioxins and furans
Proponents for municipal waste thermal treatment facilities are advised to carefully consider the purpose of each monitor when preparing applications for Certificates of Approval such that appropriate monitoring requirements can be set out as a condition of approval. When monitoring of a certain parameter is considered advantageous, the intent of the monitor may be implemented either by installing a device for direct measurement of the parameter or of a suitable surrogate.
Final selection of required analyzers will be determined on a case by case basis at the time of review of the application for a Certificate of Approval. For instance, it may not be essential to include continuous monitoring devices for both organic matter as well as carbon monoxide since these parameters are used as performance indicators of the combustion process. It is noted, however, that there is not always a direct correlation between the two parameters and that carbon monoxide may be the simpler parameter to monitor but that organic matter is the parameter which has a limit also in Ontario Regulation 419/05. Additionally, dedicated continuous monitoring of sulphur dioxide may not be necessary if hydrogen chloride is monitored continuously and the control method for hydrogen chloride ensures control of sulphur dioxide as well.
Where opacity monitoring is problematic due to a saturated plume, consideration may be given for installing the opacity monitor before the wet pollution control device if the main particulate collection device is dry and located before the wet device. Alternatively, opacity may be monitored in a heated slip stream. Another option is to install a continuous particulate matter monitor instead of an opacity monitor. The Ministry encourages the use of high sensitivity continuous particulate matter monitoring systems over opacity monitoring since particulate emissions have a direct environmental impact. Owners and operators may not be required to install an opacity monitor if the thermal treatment facility is equipped with a continuous particulate matter monitor.
Proponents for thermal treatment of municipal waste are encouraged to explore technical developments with respect to continuous or long-term sampling/ monitoring techniques and consider installation of such devices for measurement of emissions of mercury and dioxins/ furans. Methods such as Adsorption Method for Sampling of Dioxins and Furans (AMESA) can provide information on the ongoing performance of, as well as emission trends at a thermal treatment facility to support evaluation of the facility performance year round.
Owners and operators of thermal treatment facilities may also be able to monitor a variety of other parameters periodically, continuously or on a long-term basis to support the results of source testing and/ or to provide better data on annual emissions. For instance, where a continuous or long-term monitoring system provides samples for measurement of one pollutant, it may be possible to periodically analyze these same samples for quantification of other pollutants, e.g. a filter catch of particulate matter could also be analyzed for a variety of metals.
The onus on ensuring good performance, based on best practices in the municipal waste thermal treatment field, and compliance with the regulations and all conditions included in the facility’s Certificate of Approval, lies with the owner and operator of the thermal treatment facility. Therefore it is the responsibility of those persons to incorporate the appropriate continuous control and monitoring systems in the design of the facility and to provide justification for the selection or omission of equipment while ensuring that sufficient safeguards are in place to ensure good performance at all times. An application for a Certificate of Approval is expected to include a detailed proposal for a monitoring and control system.
3.3 Quality Assurance and Quality Control
Owners and operators of municipal waste thermal treatment facilities are responsible for providing accurate data to the Ministry as well as to the public. In order to ensure data accuracy, the owners and operators are expected to take several steps in order to demonstrate due diligence. The following sequence of steps will ensure an increasingly higher level of confidence for the CEMS data.
3.3.1 Initial Certification
CEMS are expected to be certified after installation to ensure that the equipment meets the required performance specifications as set out in the Certificate of Approval. Certification involves passing the first Relative Accuracy Test which will mark the “in-service” date for the CEMS and will allow the owner/ operator to start reporting data.
3.3.2. Ongoing Quality Assurance Quality Control
Following initial certification, a written Quality Assurance Quality Control (QA/QC) Manual is expected to be developed to set out all the procedures in relation to daily, quarterly, semi-annual and annual performance evaluations, including annual Relative Accuracy Test Audits (RATAs). Once the Manual is developed, it is expected to be implemented. Guidance for developing the QA/QC procedures is provided in “Protocols and Performance Specifications for Continuous Monitoring of Gaseous Emissions from Thermal Power Generation”, Environmental Protection Series, Report EPS 1/PG/7 (Revised) December 2005 or a later published version (EPS 1/PG/7).
3.3.3 Annual Audit
In order to enhance credibility of the CEMS data, a third party can be requested to carry out an annual audit to verify that the QA/QC Manual has been implemented and that the data from the CEMS can be considered reliable and accurate.
Certificates of Approval can be expected to include conditions relating to QA/QC.
3.4 Data Reporting for Continuously Monitored Parameters
3.4.1 Calculation of Average Emissions
While the measurement of a parameter may occur several times within a minute, the data acquisition systems associated with the continuous monitoring systems may record the measured data once every minute or less frequently.
Minute by minute data recording will be required whenever the averaging time for a parameter limit is less than an hour. In such cases, the data acquisition system is expected to “roll the data” minute by minute to produce a series of rolling averages, such as 6-minute, 10-minute and 30-minute averages.
Where the parameter limit is associated with an averaging time of at least one hour, valid hourly data obtained in accordance with EPS 1/PG/7 can be used to derive the concentration for the required averaging time (such as one-hour, two-hour, four-hour, 24-hour rolling averages). For shorter averaging time (such as 6-minute, 10-minute, 30-minute) an exemption of up to 30 continuous minutes could be allowed for the purpose of daily calibrations. Such an allowance implies that the concentration or emission rate reported to cover a period of time when calibration has occurred can be the average of the minute-by-minute data which includes the last valid reading before the calibration started and the first valid reading after the calibration was completed. Alternatively the missing data can be substituted with another acceptable value, e.g. that generated by a Predictive Emission Monitoring System (PEMS).
Continuous monitoring systems may also experience malfunctions during which data is not available. When any continuous monitoring system is out of service due to failure or malfunction, the data substitution method discussed in EPS 1/PG/7 is expected to be followed. It is expected that backfilling procedures are developed and included in the facility’s written QA/QC Manual in accordance with EPS 1/PG/7.
Certificates of Approval issued for thermal treatment facilities can be expected to specify the limits, together with the required averaging times, for all parameters that are required to be monitored continuously. Additionally, Certificates of Approval can be expected to set out reporting requirements for all continuously monitored parameters and action levels for operation such as waste feed reduction and complete facility shut down.
3.4.2 Shut Downs and Start Ups
Owners and operators of thermal treatment facilities are expected to achieve a stable, continuous operation and to take all possible steps to avoid shut down of the facility unless necessary due to breakdown of equipment. Certificates of Approval issued to municipal waste thermal treatment facilities may include conditions that require reduction of waste feed rate if a continuously monitored parameter is approaching its limit. If an operator is unable to bring the parameter back to the normal operating level within a reasonable time period, further waste feed rate reductions and ultimately waste feed cut off may be required. Incremental waste feed rate reductions and other measures to stabilize the process are intended to avoid the need for a complete shut down whenever possible.
Operators and operators of thermal treatment facilities should report all data generated by continuous monitoring systems from start up of the unit before any waste has been fed into the unit until all waste has been fully treated and the equipment is shut down. When reporting on compliance with the limits in this guideline, as set out in conditions included in a Certificate of Approval, the owners and operators may report the data for a period of up to three hours (or another period of time as may be set out in conditions of approval) from the start of the waste feed into the thermal treatment equipment separately from data generated during normal operation. Data for this transitional period, as well as for the period prior to start of waste feed, must be included in the monthly and annual reports. Owners and operators of thermal treatment facilities are expected to address the transitional periods in the monthly, quarterly and/ or annual reports on facility operations as required by conditions of approval.
In the event of frequent shut downs, malfunctions and start ups, i.e. shut downs, malfunctions and start ups that happen more often than at other facilities of similar design, the owners and operators of the thermal treatment facility are expected to carefully investigate the reasons for the underlying operational issues and correct any problems as soon as possible to ensure that the facility operates with minimum transitional periods. In this regard the Ministry’s expectation is that the number of transitional periods remains within a range typically experienced at other well- performing, state-of-the-art municipal waste thermal treatment facilities of similar design. Careful attention is expected to be paid to preventability of equipment outages with proper maintenance and operating procedures as well as back up measures and back up equipment.
Owners and operators are expected to show due diligence under all circumstances with detailed procedures written in an operations manual which is reviewed and updated, as necessary. Due diligence includes intensive training of staff with periodic refresher courses taught by experts on thermal treatment, air pollution control, environmental legislation and the requirements of Certificates of Approval.
Frequency of shutdowns, startups and malfunctions may be higher at newly constructed facilities and particularly at new facilities based on technologies that are not well proven in the municipal waste thermal treatment sector. Facilities intended for technology development would be issued a Certificate of Approval that is valid only for a limited period of time (e.g., pilot or demonstration facilities referred to in section 5.0.1 of Regulation 347). This guideline is not intended to address the operation of such facilities where technology development has not been fully completed and frequent changes to the facility are necessary due to ongoing operational issues and/ or process development. In the case of these developing facilities, the Ministry’s local offices play a key role in determining if and when a facility can continue operations.
Detailed requirements for reporting of shut downs, malfunctions and start ups can be expected to be included in the Certificates of Approval issued to municipal waste thermal treatment facilities.
4.0 Source Testing
Owners and operators of thermal treatment facilities, including those that burn materials/ by-products from thermal treatment of municipal waste, can expect to have emission testing requirements included in the Certificates of Approval for their facilities in order to determine compliance. Completion of testing in accordance with the Ontario Source Testing Code under maximum approved feed rates for the equipment will likely be required first within six months of start up and annually thereafter, as a minimum, all subject to the Certificate of Approval issued for the facility. The frequency recommended in this guideline may be increased as appropriate on a case by case basis (large capacity, type of municipal waste, new technology etc.) as determined during the approval process.
The Director under section 9 of the EPA may also require that source testing be repeated in the event that the testing has not been carried out in accordance with conditions of the Certificate of Approval issued for the facility, the specific recommendations at the time of the acceptance of the pretest plan and/ or for any other reason that renders the test results unreliable in the opinion of the Director. Owners and operators should under no circumstances discard any test results and repeat the testing without prior written agreement with staff of the Ministry.
The Ministry typically requires, as a condition of approval, source testing for many other contaminants aside from the ones included in Tables 1 and 2. This will assist in the evaluation of the performance of the facility and verification of compliance with Ontario Regulation 419/05 and any other relevant regulations and/ or guidelines. List of typical test contaminants is included in Appendix 1 of this Guideline.
When a test parameter is not detected, the emission rate or concentration must be reported based on the detection limit for that parameter. This will ensure that the facilities strive towards use of low detection limits and that reported emissions are conservative.
In cases where municipal waste being thermally treated belongs to a narrow category of municipal waste with a known composition and characteristics, the Director under section 9 of the EPA, may omit the requirement for testing of a parameter that is known to be absent from the waste feed into the thermal treatment facility.
4.2 Reporting Dioxin and Furan Emissions
Source testing for compliance with the dioxin and furan limit shall be conducted by determining the rate of emission for all of the dioxin and furan congeners for which International Toxicity Equivalency Factors (I-TEFs) have been established by NATO/CCMS. These I-TEFs are used in calculating the overall concentration expressed as I-TEQ which must comply with the limit set in Table 1 or Table 2, as applicable. I-TEFs and the calculation methodology have been included in Appendix 1 of this guideline.
In determining the I-TEQ emission level, where the analytical results indicate that the amount of a particular dioxin or furan congener is less than the detection limit reported by the laboratory analyzing the source testing samples, the I-TEQ concentration of the particular dioxin or furan congener shall be calculated using the reported detection limit as the amount present for that congener. The reported detection limits are expected to be determined by the laboratory at the time that the source testing samples are analyzed based on analysis of appropriate replicate low level samples or blanks.
The Ministry also recommends dioxin-like PCBs to be included in source testing campaigns to assist in determining whether or not facilities are likely to comply with the dioxin and furan air standard proposed to be included in Ontario Regulation 419/05 and to plan for early action in the event of potential non-compliance. The proposed air standard for dioxins and furans is expressed as WHO2005TEQ, based on the developmental effects associated with exposure to dioxins, furans and dioxin-like PCBs.
4.3 Report on Source Testing
A report on the source testing performed in accordance with section 4 of this guideline, can be expected to be required as a condition of a Certificate of Approval. Such a report should contain all of the test data and information as required by the Ontario Source Testing Code and the Certificate of Approval issued to the facility.
5.0 Design and Operation
The objective of this section is to provide guidance on the design and operation of thermal treatment facilities in order to achieve an environmental performance that is comparable to the best in the world. This section also covers proper management of ash or other residue.
For a facility or equipment that combusts (burns) gases generated by thermal treatment of waste, minimum design and operating parameters for combustion temperature, residence time and combustion air distribution are recommended to provide guidance to proponents in designing a thermal treatment facility that will achieve high combustion efficiencies. However, it is emphasized that these requirements are not intended to restrict technology development or dictate the equipment selection. The Ministry will consider alternative systems and alternative operating conditions for approval provided that these systems are designed and operated to achieve the contaminant emission limits set out in Table 1. Proponents proposing to use technologies that deviate from recommendations in this guideline are expected to include detailed justification for any alternative operational limits or deviation from other recommendations in the application for a Certificate of Approval. Each such application will be evaluated based on its own merits.
The Ministry will evaluate the design and operating parameters of thermal treatment facilities during the review of applications for Certificates of Approval for these facilities. Detailed engineering drawings, specifications and calculations to support the design and operating parameters are required for the evaluation. Drawings are not expected to be construction drawings, but they should include details that are needed for determining whether or not the proposed facility is capable of complying with the emission limits and other requirements set out in this guideline and Ontario Regulation 419/05.
The requirements in Section 5.1 apply only to the portion of the thermal treatment facility that combusts gases or other materials/ by-products from thermal treatment of municipal waste and include requirements for combustion temperature, combustion gas residence time, combustion air distribution, oxygen availability, gas-phase turbulence and mixing, and range of operation.
Other requirements are provided in Sections 5.2 to 5.4 and include requirements for continuous operation of air pollution control systems, ash management and organic content of ash, pressure control and emergency exhaust.
5.1 Recommendations for Combustion
5.1.1 Combustion Temperature
Combustion temperature in the equipment used to burn gases generated during thermal treatment of municipal waste is critical to achieving high-efficiency combustion and destruction of organic compounds.
The Ministry acknowledges that temperatures in the combustion chamber or zone of municipal waste incinerators and other combustion equipment will vary with the design. A minimum temperature of 1000°C is considered adequate to ensure high-efficiency combustion and destruction of products from thermal treatment of municipal waste. The equipment that is used, at least in part, to destroy organic compounds, including products of incomplete combustion, and to meet the organic matter and the carbon monoxide limits set out in Table 1, shall be capable of sustaining, on a continuous basis, a temperature that is 100°C degrees greater than the minimum required operating temperature. This capability to operate at a temperature of up to 1100°C is expected to provide an adequate safety margin as the actual operating temperature should always be more than 1000°C unless an alterative temperature is approved.
An auxiliary burner is expected to be incorporated into the design to ensure that the minimum operating temperature is maintained:
- at start-up before the commencement of the thermal treatment cycle, i.e. before any waste is fed into the equipment;
- during shutdown until all thermal treatment of waste has ceased; and
- at all times when waste is being thermally treated.
5.1.2 Combustion Gas Residence Time
The Ministry recognizes that there are municipal waste thermal treatment facilities in operation throughout the world with a wide range of combustion gas residence times in the portion of the facility that combusts gases from thermal treatment of waste. A minimum residence time of one second in the combustion zone at the minimum combustion temperature specified in this guideline is anticipated to be sufficient for providing high-efficiency destruction of the chemical species that may be present in the gas stream entering the combustion zone or equipment.
It is acknowledged, however, that performance of a combustion system is dependent on the combination of the temperature and the residence time together with equipment design that may affect gas turbulence. Therefore a combustion temperature that is lower than 1000°C may be acceptable if the residence time is increased accordingly. Additionally, certain combustion equipment used to burn materials/ by-products from thermal treatment may not be designed to achieve the combustion temperature specified in this guideline but its use in selected applications has proven to result in good combustion of the compounds present in those applications. It is the responsibility of the proponent to justify the temperature-residence time combination being proposed for an incineration or other combustion system.
The residence time shall be calculated from the point where most of the combustion has been completed and the combustion temperature has fully developed. If air is introduced downstream of the burner flame front, residence time shall be calculated from the final air injection point to the location of the thermocouple that is used to verify combustion temperature. In some cases, such as large mass burn units, overall design review, including temperature profiles, may need to be carried out to determine the portion of the unit that is considered to be the combustion zone for the purposes of residence time calculations.
If a proponent is of the opinion that residence time within a certain combustion device is not relevant for compliance with the in-stack contaminant concentration limits set out in Table 1, the proponent is expected to provide a detailed rationale for the opinion, preferably with manufacturer’s data, relevant test data and information on requirements in other jurisdictions for facilities similar to the one being proposed. An application for a Certificate of Approval for such a facility will be reviewed on a case by case basis.
5.1.3 Combustion Air Distribution
Combustion air systems shall be designed to control air distribution within the thermal treatment equipment and/ or the device that combusts gases generated during thermal treatment of municipal waste. Ideally, control systems shall have the capability of adjusting the distribution of combustion air in order to provide adequate mixing of the gases and the desired level of residual oxygen in the exhaust gases under all loading conditions. The Ministry recognizes that these systems vary widely.
5.1.4 Oxygen Availability
Lack of sufficient oxygen during combustion of any combustible material, including gases generated during thermal treatment of municipal waste, is a contributing factor to the discharge of products of incomplete combustion. Components of thermal treatment facilities shall be designed and operated to ensure that there is sufficient residual oxygen in the flue gases from the component used for combustion of gases from thermal treatment of waste. Availability of oxygen and ability to control the amount of oxygen are intended to minimize the discharge of products of incomplete combustion at all times when waste is being thermally treated. A sufficient level of residual oxygen in the exhaust gases is critical with respect to meeting the organic matter and carbon monoxide limits set out in this guideline.
Thermal treatment facilities are typically expected to be designed and operated to provide an oxygen rich atmosphere in the combustion zone or dedicated piece of combustion equipment with residual oxygen level of at least six (6) percent by volume on dry basis in the undiluted gases leaving the combustion zone.
The Ministry acknowledges that the recommendation of six (6) percent residual oxygen may be too conservative for some designs, such as those where the gases from the solid waste are a product of a carefully controlled gasification process, followed by elaborate cleaning and refining of the gases to the point of the gases becoming a gaseous fuel with consistent quality rather than being a complex mixture of products of incomplete combustion. In order to establish an appropriate oxygen level, there will be a need to balance between energy recovery, emissions of oxides of nitrogen and the system’s ability to deal with variations in waste feed quality. The composition of waste can vary significantly depending on factors such as the extent and type of industrial activity, seasonal activities and level of recycling, and so will the gases from the thermal treatment of that waste. It is also noted that a proposal may involve use of “engineered fuel”, solid or gaseous, made from municipal waste that meets certain specifications and is therefore expected to be of more consistent quality. In this case, the combustion process may not be subject to great challenges and an oxygen level below six (6) percent may be acceptable.
5.1.5 Gas-Phase Turbulence and Mixing
The design and operation of a thermal treatment facility shall provide a high degree of gas-phase turbulence and mixing in the combustion zone. This can usually be achieved through appropriately located/directed air jets, changes of flue gas flow direction, baffling, and constriction of cross-sectional flue gas flow area.
5.1.6 Range of Operation
Municipal waste thermal treatment facilities shall be designed and operated to achieve the required temperature, residence time, oxygen availability and turbulence over the expected range of operation, taking into account feed rate variations, as well as ultimate analysis, heating value, ash and moisture content of the waste together with combustion air requirements and heat losses.
5.2 Continuous Operation of Air Pollution Control Systems
Air pollution control systems for thermal treatment facilities are expected to be designed to operate on a continuous basis whenever there is waste being processed in the thermal treatment facility. The design of the system should consider:
- conditions that could lead to an unscheduled shutdown of the air pollution control system or the entire facility;
- means of ameliorating such conditions; and
- means for system venting when there is a need to bypass the air pollution control equipment.
Control systems at a thermal treatment facility shall be designed to ensure the shutdown of the thermal treatment facility immediately upon an unscheduled shutdown of the air pollution control system in a manner that will minimize air emissions, unless the system allows redirection of flue gases into equipment that operates and provides control that is equivalent to the control provided by the equipment that was shut down. The control system shall also be designed to record pertinent information for subsequent reporting to the Ministry’s local district office and for an assessment of the reasons for the shutdown and potential measures to prevent a recurrence.
5.3 Ash Management and Organic Content of Ash
Municipal waste thermal treatment facilities typically generate residues that are collected from various parts within the facility. One such residue, often referred to as bottom ash, is typically removed from the chamber, vessel or other equipment into which the municipal waste is introduced. Some designs offer a capability to vitrify (solidify into a glass-like substance) this residue. Residue can also be collected from equipment used for energy recovery from gases from thermal treatment and from air pollution control equipment (fly ash). Owners and operators of thermal treatment facilities are encouraged to consider beneficial use of any residues where possible.
Under Regulation 347, fly ash from an incinerator’s energy recovery and pollution control system must be handled separately from the bottom ash generated in the zone where municipal waste is incinerated. Similarly, for other types of thermal treatment facilities, the fly ash should be kept separate from the bottom ash or any other residue. Thermal treatment facility operators are expected to test the ash and other residues in accordance with the conditions included in a Certificate of Approval issued under Part V of the EPA (waste approval) before the ashes and/ or residues are transferred from the site of the thermal treatment facility.
Testing of bottom ash involves determination of organic content in all cases to confirm that it meets the definition of incinerator ash set out in Regulation 347. The organic content in ash should be determined using Loss on Ignition testing on dry ash samples with ferrous metals absent or as otherwise required by conditions included in a Certificate of Approval. Owners and operators of municipal waste thermal treatment facilities are expected to develop a detailed protocol for sampling and analysis of residues that are to be tested. The protocol is expected to be periodically reviewed and amended as experience with the facility is gained and test results are available. The operation of a thermal treatment facility is expected to be controlled such that the organic content of the bottom ash is minimized to the greatest degree possible.
In accordance with Regulation 347 incinerator ash (bottom ash), as defined, resulting from the incineration of waste that is neither hazardous waste nor liquid industrial waste is not a hazardous waste and may be disposed of at a site that is approved to receive solid non-hazardous waste. Owners and operators of thermal treatment facilities processing municipal waste are not required to carry out Toxicity Characteristic Leachate Procedure (TCLP) on the bottom ash that meets the definition of incinerator ash (i.e. has an organic content of less than 10 percent). Testing using TCLP, however, is required if the organic content exceeds 10 percent unless the bottom ash is to be disposed of at a waste disposal site approved to accept hazardous waste. In the absence of testing, the owners and operators must assume that the bottom ash is hazardous waste and handle it accordingly.
Fly ash from thermal treatment of municipal waste, on the other hand, is assumed to be hazardous waste unless otherwise proven. Therefore, if an operator of a thermal treatment facility wishes to classify the fly ash, or any other residue aside from bottom ash, as non-hazardous, the ash or other residue must be tested to determine if it is leachate toxic. The Ministry’s testing protocol, TCLP, is referenced in Regulation 347 while the sampling procedure and results evaluation procedure is in the Ministry’s publication “Protocol for Sampling and Evaluating Fly Ash from Non-Hazardous Solid Waste Incineration Facilities” October 1990 as may be amended.
5.4 Pressure Control and Emergency Exhaust
Thermal treatment facilities shall be designed to operate under negative pressure during all phases of operation so that gaseous products from the thermal treatment of waste do not leak out of the thermal treatment facility. The requirement for negative pressure does not apply to equipment that may be designed to operate under pressure. A Certificate of Approval issued for the thermal treatment facility will include conditions relating to abnormal operating conditions, shut down and cessation of waste feed during abnormal operating conditions as well as use of the emergency exhaust.
6.0 Special Considerations
6.1 Small Experimental Facilities
At times, proponents may wish to submit applications for experimental facilities to advance development of new technologies. When such facilities are intended to treat not more than 50 tonnes of municipal waste per year, the Ministry may not require compliance with all aspects of this guideline. Depending on the nature of the proposal, Certificates of Approval issued for experimental facilities may not include in-stack concentration limits and continuous monitoring as well as source testing requirements but they will limit the total waste throughput to not more than 50 tonnes during an approved one-year period.
It is noted however that if the results of the experiments are intended to support a future application for a Certificate of Approval for a thermal treatment facility, it will be necessary to gather data on emissions and operational parameters during the experimentation. Need for data requirements will be determined on a case-by-case basis during the review of the application for the experimental facility.
No Certificate of Approval will be issued to any facility, including an experimental facility, unless the applicant can demonstrate that the facility is capable of complying with Ontario Regulation 419/05 on a consistent basis.
6.2 Small Batch-Type Units in Remote Locations in Northern Ontario
While this Ministry does not promote the use of small batch-type thermal treatment facilities for the sake of convenience, it is recognized that such facilities are a good option for safe disposal of municipal waste in remote locations. In places such as mining/logging camps in northern Ontario, landfill may not be feasible and hauling of waste to off-site disposal is costly and generates transportation related emissions to the environment. Therefore, it may be appropriate to apply the intent of this guideline with common sense such that safe waste management does not become prohibitively expensive with no real benefits to or perhaps even to the detriment of the environment due to illegal dumping, use of burn barrels or other inappropriate waste disposal practices.
Candidates for relief from application of this guideline, namely from extensive monitoring and source testing requirements, include thermal treatment facilities that do not employ energy recovery and that discharge into the atmosphere at a temperature of at least 600°C or that will not employ any pollution control device or other system component where gases from thermal treatment are maintained within the temperature range from 200°C to 600°C. Since the system components at the above facilities avoid the temperature range that is known to promote formation of dioxins and furans, their emissions are not expected to be an issue. Good combustion control is considered sufficient to minimize release of organics including dioxins and furans.
Units that may qualify for deviation from some of the requirements of this guideline are expected to be batch-type units with a daily design capacity of not more than three tonnes of municipal waste. They must be equipped with the manufacturer’s recommended combustion and air pollution controls as well as basic continuous monitors, such as temperature, oxygen and carbon monoxide, and operated in accordance with the manufacturer’s recommendations. Owners and operators of a batch-type unit can expect to be required, as a condition of approval, to carry out one-time source testing to determine compliance unless the proponent and/ or the manufacturer can provide satisfactory confirmation based on third-party testing and certification that the unit is capable of complying with the contaminant emission limits of this guideline when operated in accordance with the manufacturer’s recommendations and with minimal requirement for operator attention.
If the proponent wishes to be relieved of the one-time source testing requirement, an application for a Certificate of Approval must be supported by a report on testing by a competent third party. Such a report must include full details of operation as well as sampling and analytical procedures in accordance with the Ontario Source Testing Code to allow staff of the Ministry to evaluate the findings of the third party.
6.3 Other Experimental Facilities
From time to time existing industrial facilities may wish to carry out experiments with municipal waste to determine its suitability as an alternative fuel. Applicability of the best practices suggested in this guideline will be determined on a case-by-case basis. Aside from the amount of municipal waste and nature of the experiments, the overall duration of the experiments will be considered when establishing the appropriate conditions of approval.
6.4 Protection of Environment
All applications for certificates of approval for all facilities will be reviewed in detail to ensure protection of environment, e.g. compliance with this guideline and the air standards set out in Ontario Regulation 419/05. It is noted that the limits for the parameters in this guideline are stringent and compliance with these in-stack limits is expected to result in compliance with the current air standards (at points of impingement) for those same parameters in Ontario Regulation 419/05.
7.0 Approval of Thermal Treatment Facilities
7.1 Approvals for a site where municipal waste is received and thermally treated
The EPA requires that a proponent of a facility that thermally treats municipal waste apply for approval to install and operate the facility. A Certificate of Approval is required under section 9 of the EPA (air approval) for air and noise emissions. Additionally an approval under Part V of the EPA (waste approval) is required to deal with waste receiving, handling, storage and other waste management issues as well as financial assurance for the facility. Full details of the approval process are available in Guide for Applying for Approval (Air & Noise) and Guide for Applying for Approval of Waste Disposal Sites both of which are available for downloading on the Ministry’s website.
Proponents must also determine if the Environmental Assessment Act (EAA) applies to the planned facility. Generally, a proposed thermal treatment facility that produces energy is subject to Environmental Screening Process under Ontario Regulation 101/07 (Waste Management Projects) under the EAA, but this may not always be the case (e.g. some exemptions may apply, such as for a manufacturing facility using not more than 100 tonnes of waste per day for its own energy needs). Also, the provisions of Ontario Regulation 116/01 (Electricity Projects) under the EAA do not apply to anything that is designated under Part II or III of Ontario Regulation 101/07. Proponents should review and be aware of the requirements in Ontario Regulations 101/07 and 116/01. It should be noted that, if a proposal is subject to the requirements of the EAA, no approvals under the EPA can be issued until all of the requirements under the EAA have been met.
7.2 Approvals for a site where materials/ by-products from thermal treatment of municipal waste are combusted
It is recognized that some thermal treatment facilities may generate materials/ by-products that may be proposed for use as fuel at other facilities located outside the generating site (i.e. at off-site facilities). In all such cases the requirement for an air approval, in accordance with the provisions of section 9 of the EPA, will apply.
In view of the definition of “municipal waste” in Regulation 347, solid materials/ by- products from thermal treatment of municipal waste are classified as municipal waste and therefore a waste approval under part V of the EPA is required if such materials/ by-products are combusted at an off-site facility.
The need for a waste approval under part V of the EPA for off-site facilities that burn liquid materials/ by-products generated through thermal treatment of municipal waste will be determined on a case-by-case basis taking into account factors such as the quality of the liquid material/ by-product.
Waste approval under part V of the EPA is not required for off-site combustion of gaseous materials/ by-products generated through thermal treatment of municipal waste.
7.3 Conditions of Approval
Certificates of Approval issued by the Ministry for thermal treatment facilities typically incorporate emission limits, and monitoring and operating requirements, based on the limits and criteria set out in this guideline. The certificate(s) may also incorporate other requirements specific to the location and the nature of the application for approval.
The following definitions are used in this guideline:
- Biomass has the same meaning as in Ontario Regulation 160/99 made under the Electricity Act, 1998.
- Burner Flame Front
- The visible luminous front zone of the flame, formed by the burner, in which intense localized gas phase combustion occurs.
- Combustion Air
- The air supplied to the incinerator for the burning of the waste and/or the fuel.
- Combustion Zone
- Combustion zone means the space where gaseous products from incineration, incomplete combustion, gasification, pyrolysis or any other thermal treatment method of the waste itself, undergo a complex sequence of exothermic reactions with an oxidant, such as oxygen. More specifically, the combustion zone in a piece of equipment associated with a municipal waste thermal treatment facility is the space where the combustion gas temperature remains within the specified combustion temperature referenced in this guideline.
- Each different structurally related chemical compound from a distinct chemical family such as the polychlorinated dibenzo-p-dioxins, polychlorinated dibenzofurans, polychlorinated biphenyls or other chemical group is referred to as a congener.
- Dioxins mean polychlorinated dibenzo-p-dioxins.
- Director means any Ministry employee appointed in writing by the Minister pursuant to section 5 of the EPA as a Director for the purposes of section 9 and/ or Part V of the EPA.
- Experimental facility
- Experimental facility means a thermal treatment facility which is not operated commercially and/ or which does not provide a waste disposal service for a municipality, industry or a person but is operated to test feasibility of a system or to experiment with operating parameters or various pieces of auxiliary equipment in order to develop or improve a technology in accordance with a defined experimentation plan that has clear objectives for the experiments. An experimental facility is not expected to operate on an ongoing basis but periodically and not longer than one year.
- Feed Rate
- The weight of waste introduced or fed into the thermal treatment equipment per unit time.
- Fly Ash (as defined in Regulation 347)
- Fly ash means particulate matter removed from combustion flue gases.
- Furans mean polychlorinated dibenzofurans.
- Gas-Phase Turbulence
- Turbulence in the combustion gases, denoting an irregular fluctuation (i.e. mixing and eddying) superimposed on the main stream. Good mixing of the products of incomplete combustion (primarily carbon monoxide and hydrocarbons) and of the combustion air is promoted by a highly turbulent flow of the gases.
- Incinerator Ash (as defined in Regulation 347)
- Incinerator ash means the ash residue, other than fly-ash, resulting from incineration where the waste is reduced to ashes containing by weight less than 10 per cent of combustible materials.
- Level of Quantification (LoQ)
- Level of quantification means, in respect of a substance, the lowest concentration that can be accurately measured using sensitive but routine sampling and analytical methods.
- Loss on Ignition
- Loss on Ignition means an analytical test to determine the amount of combustible carbonaceous material in a sample, such as bottom ash.
- Ministry means the Ontario Ministry of the Environment.
- Municipal Waste (as defined in Regulation 347)
- Municipal waste means,
- any waste, whether or not it is owned, controlled or managed by a municipality, except,
- hazardous waste,
- liquid industrial waste, or
- gaseous waste, and
- solid fuel, whether or not it is waste, that is derived in whole or in part from the waste included in clause (a)
- any waste, whether or not it is owned, controlled or managed by a municipality, except,
- Municipal Waste Thermal Treatment Facility
- Municipal waste thermal treatment facility means all pieces of equipment, mechanisms and things necessary for operation and control of a thermal treatment process, including the structure, vessel or thing in which thermal treatment of municipal waste takes place as well as all associated pollution control and/or gas cleaning equipment, energy recovery equipment, all equipment used for process control and/or monitoring and all auxiliary equipment necessary for proper functioning of all of the main pieces of equipment.
- Negative Pressure
- A pressure that is less than ambient pressure.
- Operating Parameters
- The variables in thermal treatment process that impact the performance and operation of a thermal treatment facility. These may include: the waste feed rate, composition, and heating value; combustion air feed rate(s); and heat production and losses.
- Reference conditions:
- Reference flue gas conditions are defined as follows:
- Temperature 25°C
- Pressure 101.3 kPa
- Oxygen content 11 percent
- Water content nil (dry conditions)
- Relative Accuracy Test
- Relative Accuracy Test has the same meaning as in Environment Canada document “Protocols and Performance Specifications for Continuous Monitoring of Gaseous Emissions from Thermal Power Generation” (Report EPS 1/PG/7, as amended in December 2005 or later).
- Stack means the physical structure through which contaminants generated during thermal treatment of municipal waste are discharged into the natural environment. A stack to which in-stack contaminant concentration limits apply includes the main stack and it may also include a by-pass stack or an emergency vent.
- Thermal Treatment (as defined in Regulation 347)
- Thermal treatment includes incineration, gasification, pyrolysis or plasma arc treatment.
- Thermal Treatment Facility
- For the purposes of this guideline thermal treatment facility includes all vessels and equipment at the site where thermal treatment of waste is carried out.
- Toxicity Characteristic Leaching Procedure (as defined in Regulation 347)
- Toxicity Characteristic Leaching Procedure means the Toxicity Characteristic Leaching Procedure, Method 1311, that appears in United States Environmental Protection Agency Publication SW-846 entitled “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods”, as amended from time to time, or a test method that the Director has approved in writing as equivalent.
- Woodwaste (as defined in Regulation 347)
- Woodwaste means waste,
- that is wood or a wood product, including tree trunks, tree branches, leaves and brush,
- that is not contaminated with chromated copper arsenate, ammoniacal copper arsenate, pentachlorophenol or creosote, and
- from which easily removable hardware, fittings and attachments, unless they are predominantly wood or cellulose, have been removed,
but does not include,
- an upholstered article, or
- an article to which a rigid surface treatment is affixed or adhered, unless the rigid surface treatment is predominantly wood or cellulose.
- Canadian Council of Ministers of the Environment
- [NATO] Committee on Challenges to Modern Society
- International Toxic Equivalency Factor derived for each dioxin and furan congener by comparing its toxicity to the toxicity of 2,3,7,8 tetrachloro dibenzo-p-dioxin, as recommended by the NATO CCMS in 1989 and adopted by Canada in 1990
- International Toxic Equivalent of dioxins and furans calculated using the I-TEFs, as recommended by the NATO CCMS in 1989 and adopted by Canada in 1990
- milligrams per reference cubic metre
- North Atlantic Treaty Organization
- picograms per reference cubic metre
- parts per million by dry volume
- reference conditions
- micrograms per reference cubic metre
- Toxic Equivalent of dioxins and furans calculated using the toxic equivalency factors (TEFs) derived for each dioxin and furan congener by comparing its toxicity to the toxicity of 2,3,7,8 tetrachloro dibenzo-p-dioxin, as recommended by the World Health Organization (WHO) in 2005
Typical Test Contaminants At Municipal Waste Thermal Treatment Facilities
Measured in stack unless otherwise noted
- Hydrogen Chloride
- Hydrogen Fluoride
- Oxides of Nitrogen expressed as Nitrogen Dioxide
- Sulphur Dioxide
- Carbon Monoxide
- Total Hydrocarbons
- Carbon Dioxide
Total suspended particulate matter, including condensables
Chlorobenzenes (Dioxin/ furan precursors)
- Monochlorobenzene (MCB)
- 1,2-Dichlorobenzene (1,2-DCB)
- 1,3-Dichlorobenzene (1,3-DCB)
- 1,4-Dichlorobenzene (1,4-DCB)
- 1,2,3-Trichlorobenzene (1,2,3-TCB)
- 1,2,4-Trichlorobenzene (1,2,4-TCB)
- 1,3,5-Trichlorobenzene (1,3,5-TCB)
- 1,2,3,4-Tetrachlorobenzene (1,2,3,4-TeCB)
- 1,2,3,5-Tetrachlorobenzene (1,2,3,5-TeCB)
- 1,2,4,5-Tetrachlorobenzene (1,2,4,5-TeCB)
- Pentachlorobenzene (PeCB)
- Hexachlorobenzene (HxCB)
Chlorophenols (Dioxins/furan precursors
- 2-monochlorophenol (2-MCP)
- 3-monochlorophenol (3-MCP)
- 4-monochlorophenol (4-MCP)
- 2,3-dichlorophenol (2,3-DCP)
- 2,4-dichlorophenol (2,4-DCP)
- 2,5-dichlorophenol (2,5-DCP)
- 2,6-dichlorophenol (2,6-DCP)
- 3,4-dichlorophenol (3,4-DCP)
- 3,5-dichlorophenol (3,5-DCP)
- 2,3,4-trichlorophenol (2,3,4-T3CP)
- 2,3,5-trichlorophenol (2,3,5-T3CP)
- 2,3,6-trichlorophenol (2,3,6-T3CP)
- 2,4,5-trichlorophenol (2,4,5-T3CP)
- 2,4,6-trichlorophenol (2,4,6-T3CP)
- 3,4,5-trichlorophenol (3,4,5-T3CP)
- 2,3,4,5-tetrachlorophenol (2,3,4,5-T4CP)
- 2,3,4,6-tetrachlorophenol (2,3,4,6-T4CP)
- 2,3,5,6-tetrachlorophenol (2,3,5,6-T4CP)
- Pentachlorophenol (PeCP)
Co-Planar PCBs (Dioxin-like PCBs)
- PCB-077 (3,3',4,4'-TCB)
- PCB-081 (3,4,4',5-TCB)
- PCB-105 (2,3,3',4,4'-PeCB)
- PCB-114 (2,3,4,4',5-PeCB)
- PCB-118 (2,3',4,4',5-PeCB)
- PCB-123 (2',3,4,4',5-PeCB)
- PCB-126 (3,3',4,4',5-PeCB)
- PCB-156 (2,3,3',4,4',5-HxCB)
- PCB-157 (2,3,3',4,4',5'-HxCB)
- PCB-167 (2,3',4,4',5,5'-HxCB)
- PCB-169 (3,3',4,4',5,5'-HxCB)
- PCB-189 (2,3,3',4,4',5,5'-HpCB)
Polycyclic Organic Matter
- 9,10 - Dimethylanthracene
- 7,12 - Dimethylbenzo(a)anthracene
- Indeno(1,2,3 - Cd)pyrene
- 3 - Methylcholanthrene
- 2 - Methylanthracene
- 2 - Methylnaphthalene
- 1 - Methylnaphthalene
- 9 - Methylphenanthrene
- 1 - Methylphenanthrene
Volatile Organic Matter
- Butadiene, 1,3 -
- Butanone, 2 -
- Carbon Tetrachloride
- Dichloroethane, 1,2 -
- Dichloroethene, Trans - 1,2 -
- Dichloroethene, 1,1 -
- Dichloropropane, 1,2 -
- Ethylene Dibromide
- Methylene Chloride
- Trichloroethane, 1,1,1 -
- Trichloroethylene, 1,1,2 -
- Vinyl Chloride
- Xylenes, M-, P- and O-
Dioxins and Furans
Congeners listed in Table A below should be tested and the results used to calculate the toxic equivalent using the International Toxic Equivalency Factors (I-TEFs) as indicated in the table.
In order to calculate a concentration that reflects the overall toxicity of the dioxin and furan emissions from a source, I-TEFs are applied to 17 dioxins and furan congeners of concern set out in Column A of Table A. The most toxic of all dioxin and furan congeners is 2,3,7,8-TCDD (tetrachlorodibenzo-p-dioxin) and therefore its I-TEF is identified as 1.0 in Column B of Table A. The toxicity of the other dioxin and furan congeners is identified in Column B of Table A relative to 2,3,7,8-TCDD. For instance, 2,3,4,7,8-Pentachlorodibenzofuran is half as toxic as 2,3,7,8-TCDD and therefore its I-TEF is 0.5.
The actual toxic equivalent (TEQ; to be inserted in Column D) of each congener in relation to 2,3,7,8-TCDD is calculated by multiplying the measured concentration of the congener (to be inserted in Column C) by the I-TEF of that congener (set out in Column B). The measured concentration to be inserted in Column C is the concentration that has been calculated based on sampling and analysis of a gas stream as part of a source testing campaign.
The total toxic equivalent of dioxins and furans discharged in the gas stream from a source is then obtained by summing up all of the individual TEQ values in Column D for each congener of concern in Column A as shown at the bottom of Column D (Total Toxicity Equivalent).
Compliance with the stack concentration limit for dioxin and furan emissions is achieved if the calculated Total Toxic Equivalent is less than the limit set out in the Certificate of Approval (the toxic equivalent of dioxins and furans in the undiluted gases at the outlet of the combustion source). A similar approach shall be used to assess whether or not the measured emissions, as applied in a dispersion model, comply with the point of impingement concentration limit for dioxins and furans.
|Dioxin and Furan Congeners of Concern||International Toxic Equivalency Factors (I-TEFs)||Concentration pg/m3 (sampled and analysed)||Toxic Equivalent (TEQ)|
|A||B||C||D (D = B × C)|
|Total Toxic Equivalent|
Download Table A as Word Document.
- footnote Back to paragraph Compliance source testing as set out in the facility’s Certificate of Approval.
- footnote Back to paragraph Compliance source testing as set out in the facility’s Certificate of Approval. Owners and operators of cement and lime kilns can expect to be required, by conditions in Certificates of Approval, to maintain CEMS for SO2, NOx, THC, HCl and opacity.
- footnote Back to paragraph measured in stack as well as in the undiluted gases exiting the chamber or zone where final combustion of gases generated through thermal treatment of municipal waste has taken place (operational parameter usually monitored continuously)
- footnote Back to paragraph measured in stack as well as in the undiluted gases exiting the chamber or zone where final combustion of gases generated through thermal treatment of municipal waste has taken place (operational parameter measured continuously)
- footnote Back to paragraph expressed as methane on wet basis and measured in the undiluted gases exiting the chamber or zone where final combustion of gases generated through thermal treatment of municipal waste has taken place (operational parameter; may be measured continuously)