Waste to Energy Focus: Achieving R1 Status
Energy Recovery
Efficient waste to energy (WtE) plants can now achieve ‘energy recovery’ status calculated using the R1-formula. How many facilities across Europe will reach this stage? Ahead of a deadline for member states to introduce the R1-formula, supported by guidance, Dr Ella Stengler looks at European efforts so far.
Efficient waste to energy plants can be classified as energy recovery operations rather than waste disposal, according to the Waste Framework Directive (WFD). The ‘energy recovery’ status can be obtained in compliance with the ‘recovery’ definition in the WFD, which came into force on 12 December 2008. As a result waste could replace fossil fuels, which would have been otherwise used for energy production.
With regard to “incineration facilities dedicated to the processing of Municipal Solid Waste” a certain energy efficiency factor, calculated using the now famous “R1-formula” has to be achieved. This poses no problem for countries like Sweden and Denmark. They are much beyond the threshold, and for Sweden it was never in question that their highly efficient WtE plants were ‘energy recovery’ operations.
However, for the rest of Europe one has to calculate, and the devil - as often is the case - is in the detail. Therefore, the European Commission (DG Environment) was asked to draft a guidance, so that the formula is applied in a harmonised way across Europe, in order to guarantee a level playing field. This guidance should be adopted by the end of 2010 as Member States have to implement the WFD by 12 December 2010.
Application of the R1 formula in the Member States
Germany drafted a guidance and proposed it to the Commission as a basis for the European guidance, without applying it nationally. France took the R1 formula as a basis (but not 1:1) for taxation: lower incineration tax for energy efficient WtE plants if they also fulfil one of the following conditions: either environmental certificate ISO 14001 or NOx emission values below 80 mg/Nm3.
The Netherlands went ahead, calculating the formula the “Dutch way”, providing 62% of the existing capacity of plants and lines with the “R1 status”, effective from 25th March 2010. This happened in return for a moratorium on new capacity up to 2020. This raises the question of why the industry did not want to wait until the European guidance is adopted. “R1 plants” may also import combustible waste more easily from other countries. Operators near coastlines are looking to the UK, which is busy working to reduce its high landfill rates in order to meet the targets set in the European Landfill Directive.
Impacts of energy recovery status
The ‘energy recovery - R1 status’ gives operators the opportunity to accept waste more easily from abroad as competent authorities may raise objections to waste shipments, based on proximity and self-sufficiency principles, only for disposal. However, for shipments of mixed municipal waste (waste collected from private households, including where such collection also covers waste from other producers) the same provisions as shipments of waste destined for disposal may be applied, also with regard to recovery facilities, according to Article 3(5) of the Waste Shipment Regulation.
This means that the competent authorities may raise objections to shipments of mixed municipal waste, based on the proximity and self-sufficiency principles, even if they are destined for a WtE plant that is classified as ‘energy recovery’. In order to avoid abuse, i.e. taking out just a piece of paper from mixed municipal waste and claiming that now it is no-longer “mixed” municipal waste with the consequence of enabling free shipment, the legislator introduced recital 33 in the Waste Framework Directive.
This directive states that mixed municipal waste remains mixed municipal waste even when it has been subject to a waste treatment operation that has not substantially altered its properties. Member States may limit incoming shipments of waste destined to incinerators that are classified as recovery only where it has been established that such shipments would result in national waste having to be disposed of, or waste having to be treated in a way that is not consistent with their waste management plans.
This provision was introduced due to a demand from Denmark, fearing that waste from abroad, particularly Germany, could occupy Danish WtE plants, so that there would not be enough capacity left to treat Danish waste. It is questionable whether this fear is realistic, though, as taxation in Denmark is high. This reduces the attractiveness to ship waste to Denmark, despite the exceedingly high energy efficiency of Danish WtE plants.
Outgoing shipments of waste can be limited only on environmental grounds, as set out in the Waste Shipments Regulation. Although waste shipment is sometimes looked at critically, it can be beneficial for the environment if the waste is shipped from a country where it would be landfilled to an efficient state-of-the-art WtE plant in a neighbouring country.
There are other important drivers for the ‘R1 energy recovery status’ such as the waste hierarchy set in the WFD. Classifying WtE as a disposal operation rather than ‘recovery’ would mean that it is placed on the same level as landfilling. As in many countries landfilling is the cheaper option, there would be no incentive to divert waste from landfill. It would also help introduce a level playing field with the co-incinerating industry (e.g. cement kilns). Importantly, from a financial point of view, it is likely that banks would be more willing to issue loans to investors building an “energy recovery plant”.
The R1 energy efficiency formula
Incineration facilities dedicated to the processing of municipal solid waste are considered to achieve the ‘energy recovery - R1 status’ if their energy efficiency is equal to or above: 0.60 for installations in operation and permitted in accordance with applicable Community legislation before 1 January 2009, and 0.65 for installations permitted after 31 December 2008, using the R1 formula of the WFD, Annex II.
The formula takes into account the annual energy which is produced by the plant (Ep) and puts it into relation to the calorific value of the municipal waste (Ew). The energy, which is introduced into the combustion process from outside, e.g. fossil fuels (Ef) or electricity (Ei), is subtracted. Ef means annual energy input to the system from fuels contributing to the production of steam (GJ/year) while Ew means annual energy contained in the treated waste calculated using the net calorific value of the waste (GJ/year). The energy efficiency can be improved, e.g. by reducing the input of fossil fuels.
This formula shall be applied in accordance with the reference document on Best Available Techniques for waste incineration. It should be noted that, for thermodynamic reasons, Ef should be deleted in the nominator of the equation as it is included twice - in the nominator and the denominator. Due to the equivalence factors for electricity (multiplication with factor 2.6) and for commercially used heat (multiplication with factor 1.1) the R1 factor can be greater than 1. Therefore, it is important to clarify in the introduction of the guidance for the application of the R1 formula, that it is not a physical or thermodynamic efficiency that is calculated by the R1 formula.
Guidance: how to calculate the R1 formula
The Commission (DG Environment) created an expert working group, consisting of representatives from the Commission and its Joint Research Centre, Member States and stakeholders (industry and NGOs). The aim was to draft a guidance for the application of the formula to make sure it is calculated in a harmonised way across Europe. A consultant (BiPRO) advised the Commission and drafted the different versions of the guidance. After three meetings of the Working Group the guidance was almost finished and presented to the Member States in the Technical Adaptation Committee (TAC).
One of the most important items discussed is the system boundary of the calculation. The following was agreed by the Working Group (WG): “The boiler/furnace, the flue gas cleaning system and the turbine (as long as it is under the responsibility of the WtE operator) are in the system boundaries. Pre-treatment and post-treatment of waste (particularly bottom ash treatment) is not considered in the system boundaries.”
Another major point of discussion was if it should be the gross energy produced that counts as Ep (Energy produced) and if the energy used by the WtE plant itself should be subtracted in Ei (Energy introduced) from Ep in the nominator. This would diminish the R1 factor. The WG’s conclusion was: “The energy used in the WtE plant shall not be subtracted from Ep as this part of the energy produced from the waste also replaces fossil fuels which would have been used otherwise.”
Another important aspect is if all waste input treated in “incineration facilities dedicated to the processing of Municipal Solid Waste” shall be regarded as recovered. This is because WtE plants normally also accept other kind of waste besides Municipal Solid Waste. The WG added that: “The calculation of the R1 formula is done of the waste in the composition which is actually incinerated in a facility, not only the part of the waste which is classified as municipal waste.” Any other approach would mean subtracting the non municipal waste from the total waste input Ew (Energy in the Waste) in the denominator, and this would not be feasible in practice.
The European guidance on the R1 formula will not be endorsed by the Member States in the TAC, and therefore will not be legally binding. However, as it will be adopted by the Commission’s DG Environment after consultation with the other services, including the legal service of the Commission, the Member States and experts, it is expected that Member States will follow the guidance as a helpful tool for a harmonised interpretation of the R1 formula. It is, after all, an expert opinion, which will be taken into consideration by the courts.
There is no doubt that a WtE plant without the R1 status is still allowed to operate. One should not confuse the classification of a waste treatment operation according to the WFD with the operation permit, which has to be in line with the Waste Incineration Directive and the IPPC Directive (now merged in the new Industrial Emissions Directive). A WtE plant that does not achieve the ‘R1’ is still a plant that treats waste in an environmentally sound way, achieving low emissions as required by the Waste Incineration Directive. It can always be operational as ‘D10’ - disposal of waste (Annex I WFD) - although with market disadvantages. In the future, however, it can be expected that new plants are being built in such a way that they will achieve ‘R1’ status. And it is the environment that will benefit.
How many WtE plants achieve the energy recovery status in Europe
In its second Energy Efficiency Report 2009 CEWEP assessed the energy efficiency of 231 WtE plants from 16 European countries (15 EU + Switzerland). The investigated plants account for a combined capacity of 45.5 million tonnes of municipal waste, representing more than 70% of the total amount of municipal waste incinerated in Europe.
Out of 231 plants, 169 WtE plants are classified as ‘energy recovery’ as they achieved an R1 factor greater than 0.60. The Energy Efficiency on average was 0.75, which seems to be high. However, one must bear in mind that it is likely that only the most efficient WtE plants in Europe (e.g. from Sweden and Denmark) participated in this survey, and those who did not could potentially be less efficient plants.
Taking the reference year 2006, the total amount of WtE plants in Europe (EU27+Switzerland+Norway) was 420. From this number 252 WtE plants in Europe are below the R1 factor 0.60 or did not participate. In other words - so far only 40% of plants are proven to reach R1. The investigation shows strong correlations between the values of R1 and the type of energy recovery, the size of the plant and the geographical location respectively.
Correcting the climate
There is a request from Southern European countries to apply a climate correction factor. A proposal from Portugal was delivered to the Commission proposing to add a certain factor (based on heating degree days, reported by EUROSTAT) to the R1 result. It is not clear yet if the Commission and the majority of the Member States see the need to take climatic conditions into account. This is still under discussion.
Legally it would be possible according to Art. 38(1) WFD which states that: “Local climatic conditions may be taken into account, such as the severity of the cold and the need for heating insofar as they influence the amounts of energy that can technically be used or produced in the form of electricity, heating, cooling or processing steam.” Such a “climate correction factor” would have to be adopted in regulatory procedure with scrutiny (better known as ‘comitology’). This process is quicker than an ordinary legislation process, but it is more formalised than the development of a guidance.
There is also another important issue: the target is to maximise energy recovery and the utilisation of waste heat, in order to substitute fossil fuels consumption. In Southern countries there is an absence of customers for heat. It is often claimed that they should produce cooling rather than heating, but in this case infrastructure for the supply is also necessary and often not available. Cooling sounds promising, but still needs some time to be developed. However, there are some successful cooling projects from WtE plants, for example in Madrid and Brescia.
Although Vienna is not in Southern Europe it is worth mentioning the success of the Spittelau WtE plant, which supplies heat and cooling to a nearby hospital, thus achieving high efficiency. However, not all WtE plants have a hospital nearby that they can supply. The energy recovery status provides incentives for future investments in WtE plants located close to energy customers. For existing plants it will be necessary to seek potential customers and attract them to move next to the WtE plant. Industrial users which could be supplied with steam from WtE would be ideal. Innovative ideas will certainly come up in the near future.
Outlook
“Even if it seems rather obvious, it has to be said time and time again that to virtually eliminate wastes and produce energy in its place is a win-win situation”, said Giles Chichester, MEP (UK), at the CEWEP congress 1st July 2010 in Antwerp. Producing more and more energy from the waste that remains after waste prevention and recycling is the challenge that WtE operators face. The R1 formula provides incentives to do so and the guidance makes sure that the R1 formula is applied in a harmonised way, guaranteeing a level playing field.
In the first report that intervenes by 12th December 2014, the Commission shall review the implementation of the Waste Framework Directive, including the energy efficiency provisions, and will present a proposal for revision if appropriate (Art. 37(4) WFD). This gives WtE operators and Member States some time to gain experience with the application of the R1 formula. The energy efficiency criteria for the recovery status for WtE plants could be just a starting point for EU waste legislation in order to create quality standards for waste recovery. Dr Ella Stengler is managing director of the Confederation of European Waste-to-Energy Plants (CEWEP). e-mail: ella.stengler@cewep.eu
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