Just had a chat with Robin on emission limits. The table below is what we are working with now. If I am informed correctly, this comes from Toyo Thai and later is confirmed by TEAM. It shows that only the MILENA combustion exit has the strict waste incineration limits, the rest is somewhat more relaxed and follows the Industrial Emission Standards.
Same thing happened in the UK for the ETI project. Robin told me that in the UK, in order to have the more relaxed limits, you needed an “end-of-waste” prove. That means that the cleaned syngas needs to be clean enough and there was a list of components for that. Apart from the fact that this needs to be monitored, it was impossible to reach some of those criteria. Robin mentioned the tar concentration needed to be zero. It may be low, but not zero in our case.. It certainly is not zero for the syngas to the boiler. Furthermore, dioxins will be there (if tars are there, dioxins will be there). For the ETI project, this all resulted in the incineration directive for all flue gases. The question now is whether the Thai situation is different from the UK. In any case, it would be good to double check the assumption that the industrial emission standard is the one, and incineration limits are not. This includes the question what the statement is based on. We might have said “clean syngas” once, but what does clean mean in the laws in Thailand?
If all exits would have to comply with waste incineration limits, the sulphur starts to be a real bottle neck. Also Hg (mercury) might become an issue.. Both will cost much money to repair. Can you have a good discussion with TEAM to clear this issue?