Waste-to-energy power plant in Industriepark Höchst: questions and answers

Answers to frequently asked questions

2. General questions
2.1 Why is Infraserv building a WTE power plant?
2.2 Why pick a WTE plant? Why not a gas power plant?
2.3 Why pick Industriepark Höchst as the location for the plant?
2.4 Will the plant comply with all legal requirements?

3. Refuse-derived fuel / quality control
3.1 What is refuse-derived fuel?
3.2 Does it consist of wastes that have been designated as recyclables (Gelber Sack)?
3.3 What is currently happening with the refuse-derived fuel? Why is a plant like this even necessary?
3.4 Why are RDF suppliers paying for thermal utilization?
3.5 Why isn't refuse-derived fuel being combusted in existing waste-incineration plants? What is the difference between an RDF-based plant and a conventional waste-incineration plant?
3.6 How is Infraserv going to make sure that the plant only incinerates the designated types of waste?
3.7 Will refuse have to be “imported” from abroad to fuel the facility?

4. Output / technology / general contractor
4.1 How powerful will the plant be?
4.2 Why doesn't Infraserv build a smaller plant?
4.3 What is a circulating fluidized bed?
4.4 Can the plant combust other materials, too?
4.5 Who is building the plant?
4.6 Why pick a Japanese company?

5. Emissions
5.1 What is being done to minimize pollution?
5.2 What pollutants will be emitted?
5.3 The immission limits for nitrogen oxides have not been met. Is this expected to affect human health in the region?
5.4 How does the flue-gas-treatment system work?
5.5 Will the plant also emit greenhouse gases?
5.6 Are the limits laid out in the 17th BImSchV still relevant?
5.7 Have emissions from local traffic or the airport been considered in the emission-limit calculations?
5.8 What will happen with the combustion residues?

6. Site / buildings
6.1 Where is the plant going to be built?
6.2 How high are the buildings going to be?

7. Traffic
7.1 How much more traffic should I expect?
7.2 Why isn't the fuel being delivered by barge or train?

8. Noise
8.1 How much noise is the plant expected to produce?
8.2 How much noise is the extra traffic expected to produce?

9. Odors
9.1 How much odor pollution should I expect?

10. Miscellaneous
10.1 Why wasn't the public notified sooner? Why was Christmas chosen as the time to invite public comment on the permit application?
10.2 Why was Thermal Conversion Compound Industriepark Höchst GmbH established?

1. INTRODUCTION

Infraserv Höchst is building a waste-to-energy (WTE) power plant that will incinerate 675,000 metric tons of refuse-derived fuel per year in a circulating fluidized bed. This will be the single largest investment in Industriepark Höchst's history: The budget is roughly EUR 300 million. What is more, the plant will create some 40 new jobs and provide a reliable power source for Industriepark Höchst when it comes on stream. An operating company, called Thermal Conversion Compound Industriepark Höchst GmbH (T2C), was created to carry out the project; Infraserv Höchst is a principal shareholder. The foundations are to be laid in the first half of 2007, while the facility is scheduled to be commissioned in 2009. The general contractor is Ebara, a Japanese multinational. Ebara will be responsible for building the plant and equipping it with all the necessary systems.

2. GENERAL QUESTIONS

2.1 Why is Infraserv Höchst building a waste-to-energy power plant?

Infraserv Höchst is expanding its own power-production capacity for two reasons: to minimize its exposure to the ups and downs of the energy market, and to offer its tenants energy at low, internationally competitive rates. At the moment, Infraserv Höchst can only cover around 40 percent of the park's energy needs on its own; the rest has to be purchased from outside producers. With the WTE power plant, Infraserv Höchst will be able to produce some 60 percent of the park's energy needs and reduce its dependence on the external market. Energy costs are a crucial competitive factor for manufacturers. The WTE power plant will play a major role in ensuring that Industriepark Höchst remains a viable business site – one that continues to attract new investors and create and protect jobs in the region.

2.2. Why pick a WTE plant? Why not a gas power plant?

All the relevant alternatives were thoroughly examined during the preliminary planning phase. A waste-to-energy (WTE) plant is the only way to reduce our exposure to fluctuations in the energy market since refuse-derived fuel (RDF) will remain available over the long term. RDF is also a relatively clean fuel. When this highly biogenic material is combusted, it releases around 50 to 60 percent less harmful CO2 than coal power plants and 20 to 30 percent less than gas power stations.

Moreover, Infraserv Höchst has long pursued a holistic energy strategy with a strong focus on clean energy production and environmentally friendly fuels. For example, it supports hydrogen-fuel use, generates biogas, and runs a combined heat-and-power (CHP) plant with an extremely high fuel utilization efficiency of 90 percent in Industriepark Höchst. Since recent legislation has banned the landfilling of refuse-derived fuel (RDF) and the existing plants in Germany cannot handle all the RDF, building a WTE power plant is both environmentally responsible and absolutely necessary. The legislation also requires unrecyclable wastes to be utilized thermally. Thermal utilization is environmentally beneficial since it produces electricity and steam while reducing fossil fuel consumption – by around 300,000 metric tons of coal or 200 million cubic meters of natural gas per year. This helps conserve our limited stocks of precious primary fuels for a long time to come.

2.3 Why pick Industriepark Höchst as the location for the plant?

There are many reasons why Industriepark Höchst is an ideal location for this kind of plant. There is a stable market for heat and electricity among the park's tenants. Its highway connections are ideal since there is no need for trucks to drive through neighboring city districts and add to their existing traffic levels. What is more, Industriepark Höchst already has the infrastructure needed to operate this type of plant, which will help ensure compliance with the strict emission limits.

Environmentally speaking, Industriepark Höchst is also a good location to operate a waste-to-energy (WTE) facility. Since the park's tenants consume large amounts of heat and electricity, the RDF can be used more efficiently than in electricity-only production. While conventional power plants simply emit the waste heat from combustion into the atmosphere, the WTE plant will capture the heat and feed it into the park's steam-pipeline network, where it will be used by park tenants in many of their production processes. This explains why conventional power stations have fuel-utilization-efficiency levels of 40 to 45 percent, while Industriepark Höchst's current combined heat-and-power (CHP) plant attains 90 percent. In a word: a lot of steam and electricity with relatively little fuel.

Another aspect is the outstanding infrastructure at the park, which will also be used for the WTE plant. Additionally, Infraserv Höchst, being an operator of advanced infrastructure such as the CHP station or the sewage-sludge-incineration plant, has the expertise and know-how needed to operate the new facility professionally.

2.4 Will the plant comply with all legal requirements?

The WTE power plant will be built in accordance with European "best available techniques" for waste combustion as defined in July 2005. Plant operations will consistently comply with the strict emission limits laid out in the 17th Federal Immissions-Control Ordinance (17th BImSchV). As required under the German Act on Closed Substance Cycles and Waste Management, the Federal Immissions-Control Act outlines the basic permitting procedures for a waste-incineration facility like the WTE power plant. Various ordinances have been issued to implement the Federal Immissions-Control Act, including the 17th BImSchV on waste incineration, the Technical Instructions on Air Quality Control (TA Luft), the Technical Instructions on Noise Abatement (TA Lärm), and the Guideline for Odor Dispersion and Impact (GIRL). All these regulations impose strict limits on what the plant emits – its emissions – and what actually reaches the surrounding area – its immissions. An environmental impact assessment forms an integral part of the permitting process.

The WTE power plant is required by law to ensure that the environment is well protected, that harmful immissions cannot occur, and that best practices are followed to prevent harmful immissions.

The environmental impact assessment was based on the immissions forecasts submitted with the permit application and recorded in the special assessment documents. The conclusion of the assessment: The WTE power plant will have a negligible impact on the environment.

3. REFUSE-DERIVED FUEL / QUALITY CONTROL

3.1. What is refuse-derived fuel?

Refuse-derived fuel (RDF) consists of high-calorific-value fractions of municipal and commercial waste that have been pre-sorted, prepared, and dried. These fractions have been banned from being landfilled as of June 1, 2005 by the Technical Instruction on Municipal Waste (TASi). Waste fractions that are used in RDF cannot be recycled. They have high calorific values, so they have to be utilized thermally in order to generate steam and electricity. The ban on landfilling RDF helps to conserve valuable landfill space and prevents harmful landfill gases (methane) from escaping into the atmosphere.

3.2. Does refuse-derived fuel consist of any materials that have been designated as recyclables (Gelber Sack)?

The waste-to-energy (WTE) plant will not combust any of the unsorted recyclables that are normally collected in yellow bags and recycled by Duales System Deutschland GmbH. The suppliers of the refuse-derived fuel (RDF) will sort out recyclable fractions of municipal and commercial garbage at their waste-processing centers before they convert the nonrecyclable, but high-calorific-value components into specified RDF. These fractions – which the Technical Instruction on Municipal Waste has banned from landfilling – are the only ones that will be combusted in the WTE plant. Suppliers can also produce RDF from "yellow-bag" recyclables, but only after they sort out all the recyclable components. What is left over is then used to make RDF. The RDF has a high heat value, which makes it ideal for thermal utilization.

3.3 What is currently happening with the refuse-derived fuel? Why is a plant like this even necessary?

Refuse-derived fuel is being used at cement factories or in the auxiliary firing systems at coal-based power stations. However, it can be utilized more efficiently in waste-to-energy plants that are specifically designed to burn refuse-derived fuel (RDF). At the moment, there is simply not enough plant capacity in Germany to combust all the RDF being produced on a continual basis in keeping with the legal requirements. Building a WTE power station in Industriepark Höchst will add valuable capacity to this tight market. However, the facility must be large enough to capitalize on economies of scale. That makes it hard for the local governments overseeing waste management to readily appropriate the funds for such a project, especially since taxpayers and fee payers would end up shouldering the financial risk.

3.4 Why are RDF suppliers paying for thermal utilization?

Suppliers pay a fee to Infraserv Höchst for thermally utilizing their refuse-derived fuel because the equipment needed to combust RDF is significantly more expensive to purchase, maintain and operate than coal or gas firing systems. This is the only financially feasible way to meet the environmental targets laid out in the 17th BImSchV, TA Luft and all the other regulations that govern plant operations.

3.5. Why isn't refuse-derived fuel being combusted in existing waste-incineration plants? What is the difference between an RDF-based plant and a conventional waste-incineration plant?

RDF-based plants like Infraserv's WTE power station are specifically designed to handle high-heat-value RDF. Unlike conventional incinerators, RDF-based plants only fire pre-sorted, high-quality, and high-calorific-value fractions of municipal and commercial waste. Conventional facilities, on the other hand, cannot combust fuels with high calorific values. In fact, they have to use a lot of extra inputs, including fossil fuels such as natural gas for coal, in order to combust the various types of waste. RDF-based plants, by contrast, are more efficient: Being designed specifically for high-heat-value RDF, they produce more electricity and steam from a given quantity of fuel.

As a rule, waste incineration is ecologically more sound than landfilling and is required under the current environmental policies.

3.6. How is Infraserv going to make sure that the plant only incinerates the designated types of waste?

14 certified suppliers have signed long-term contracts to supply the plant with prepared, quality-controlled refuse-derived fuel. The fuel will only be used if it has been sorted and processed by the suppliers in accordance with detailed quality specifications. Regular testing will ensure the fuel is compliant. The fuel will also be examined in a quality control inspection at the power plant. The waste producers and the WTE power plant will closely coordinate and interlink their quality-management systems to ensure the RDF consistently meets specified quality standards. This commitment clearly differentiates the WTE power plant from conventional waste-incineration plants.

3.7 Will refuse have to be “imported” from abroad to fuel the facility?

No. The facility will be supplied with fuel based on long-running contracts with 14 RDF suppliers. Some of the suppliers are local, but all are located in Germany and collect their waste streams in this country. There is no reason to believe that this material will have to be acquired abroad. Under the contracts with the RDF suppliers – which are certified specialized waste-management companies –the refuse-derived fuel does not have to come from a particular region. As such, the possibility of delivering small amounts from other European countries has not been totally ruled out in individual cases. However, given the current RDF availabilities, tight processing capacities and high logistics costs, it would not make much sense for RDF suppliers to acquire refuse-derived fuel from remote sources, let alone in other countries.

4. Output / technology / general contractor

4.1 How powerful will the plant be?

The plant will consume 675,000 metric tons a year and supply 70 megawatts of electrical power and up to 250 metric tons of steam to Industriepark Höchst's power grid and pipeline network.

4.2 Why doesn't Infraserv build a smaller plant?

The size of the plant depends on two things: satisfying existing demand and providing a reliable supply of electricity and steam for Industriepark Höchst. Among the regular plant providers, this means a design with three combustion trains and a fairly high capacity. Even after the WTE power plant comes online, manufacturers at the park will still only draw 60 percent of their power from on-site energy-generation facilities. A smaller plant would be unable to increase on-site energy production by a sufficient amount. Since it is so close to consumers, on-site energy production is highly efficient and thus better for the environment.

4.3 What is a "circulating fluidized bed"?

The refuse-derived fuel is fed into a circulating, fluidized bed of red-hot quartz sand that is suspended on jets of hot air. This advanced technology provides efficient, low-pollution burnout: The tiny, red-hot sand particles mix with the combustion air and the RDF. This creates a particularly intense heat and mass transfer. With a circulating, fluidized bed, plant operators can respond quickly and efficiently to changes in fuel properties, allowing them to incinerate refuse-derived fuels with both low and high heat values. The minimum temperature in the combustion chamber is 850 degrees Celsius.

4.4 Can the plant combust other materials, too?

The WTE power plant can handle a wide range of fuels and is specifically designed for the materials specified in the permit application. This design will allow the plant to be operated for a long time to come.

4.5 Who is building the plant?

Ebara is the general contractor and will be responsible for building the plant and equipping it with the necessary systems. Ebara is a multinational corporation based in Japan that boasts a long, extensive track record with circulating fluidized beds and this type of facility.

4.6 Why pick a Japanese company?

Ebara has been building fluidized-bed combustors for waste-to-energy applications for 30 years. All told, it has erected around 200 facilities using this approach. The experience Ebara has gained over the years has gone into continuously refining its fluidized-bed technology. Its systems utilize combustion heat extremely efficiently to produce steam and electricity.

5. EMISSIONS

5.1 What is being done to minimize pollution?

This is a state-of-the-art facility. The technologies that Infraserv Höchst has selected for combusting the non-hazardous waste and treating the flue gas conform to European "best available techniques" for waste combustion as defined in July 2005. In fact, the technology could, but will not, be used to combust hazardous waste. The WTE power plant meets or falls below the strict emission limits of the Federal Immissions-Control Act (17th BImSchV) that form part of any operating permit. The emission limits are mandatory and ensure that people and the environment are adequately protected. Germany has the strictest standards in the world when it comes to waste-incineration plants.

The plant has already undergone an EU audit called the Eco-Management and Audit Scheme (EMAS). EMAS is a tool developed by the European Community in 1993 for companies who want to improve their environmental performance. To register under EMAS, companies have to identify significant environmental impacts, set up an environmental-management system and issue an environmental statement. T2C GmbH has met all these requirements. The actual audit was conducted by an outside environmental expert.

5.2 What pollutants will be emitted?

The flue gas will consist of typical combustion products such as carbon monoxide, sulfur dioxide, and nitrogen oxides as well as minute amounts of dioxins, furans, heavy metals and fine dust. However, the gas emissions will comply consistently with all the limits laid out in the 17th Federal Immissions-Control Ordinance (17th BImSchV) to protect human health and the environment.

5.3 The immission limits for nitrogen oxides have not been met. Is this expected to affect human health in the region?

According to the immission forecast, the overall contamination from nitrogen oxides will statistically be exceeded at one assessment point in Frankfurt-Höchst that is located within the facility's defined "exposure zone". However, not only has the City of Frankfurt's clean-air plan been designed to reduce nitrogen-oxide immissions over the next several years, but the immission forecast is also based on contamination parameters that actual operations will probably not even reach.

Because of this, it is safe to assume that nitrogen-oxide immissions will also meet the requirements laid out in the Technical Instructions on Air Quality Control (TA Luft). There is thus no reason why the plant should have any negative impact on human health in the region.

5.4 How does the flue-gas-treatment system work?

The combustion produces flue gases that are directed to a powerful multi-stage gas-purification system that removes the pollutants. The treatment process uses ammonia (to reduce nitrogen oxides), slaked lime and activated coke. The slaked lime and activated coke are intermixed with the flue gas to bind sulfur dioxide, volatile heavy metals and organic compounds. These substances are adsorbed and then pass through a baghouse, which removes almost all of them from the exhaust gas. This is a semi-dry process that does not produce wastewater or contaminate any bodies of water.

5.5 Will the plant also emit greenhouse gases?

Like any other form of combustion, RDF-based energy generation gives off carbon dioxide. However, since 40 to 60 percent of the carbon in the RDF is biogenic (i.e., comes from renewable raw materials), the WTE power plant will be far more carbon-neutral than a coal- or natural gas-based power plant. This benefit has not been lost on the legislature, which has expressly required nonrecyclable waste fractions to be thermally utilized (i.e., incinerated). Lawmakers believe this option not only is more ecologically sound than landfilling, but it also brings us closer to the Kyoto targets.

5.6 The plant is supposed to be licensed under the 17th BImSchV. Are the limits laid out in this regulation still relevant? Can't current technology deliver much better results?

The 17th Federal Immissions-Control Ordinance (17th BImSchV), which was amended as recently as in 2003, has emission limits that specifically require plant operators to restrict exhaust-gas emissions using modern technology. These mandatory limits ensure that people and the environment are protected from any detrimental effects. The plant will consistently meet these limits, and in some cases will fall far below them.

5.7 The Rhine-Main region is already heavily polluted due to all the factories and exhaust emissions. Why does this kind of plant have to be built here, of all places? Have emissions from local traffic or the airport been considered in the emission-limit calculations?

The licensing application included an immission forecast that fully and completely considered pre-existing pollution levels in the region using parameters provided by the Hesse State Environmental and Geological Agency (HLUG), the government agency who is responsible for such issues. It makes sound economic and environmental sense to build this kind of plant at a place like Industriepark Höchst since the tenants can use both the electricity and the heat it produces.

As to the air quality in the Rhine-Main region, we recommend consulting the City of Frankford's clean-air plan. It lays out several emission-reduction programs that will significantly lessen nitrogen-oxide emissions over the next several years.

5.8. What will happen with the combustion residues?

Combustion residues – ash consisting of inorganic materials such as quartz sand – and dusts removed by the flue-gas-treatment system will be deposited at appropriate landfills outside Industriepark Höchst. If large quantities of iron are found in the combustion residues, they can be separated out and recycled.

6. SITE / BUILDINGS

6.1 Where is the plant going to be built?

The new plant will be erected in the southwest section of Industriepark Höchst.

6.2 How high are the buildings going to be?

The boiler house will be 50 to 60 meters high; the stacks around 80 meters high. The actual power unit will be 30 to 35 meters high.

7. TRAFFIC

7.1 How much more traffic should I expect?

RDF will be delivered at a separate gate at the southernmost edge of Industriepark Höchst. Thanks to the good highway links, traffic will not increase for the neighboring city districts: The trucks will not have to pass through the towns. There will be around 200 to 240 more trucks per day in addition to the regular traffic. So even if there were twice as many trucks per day, the additional traffic would be less than 1 percent of the current traffic levels on the B 40, B 40a and B 43 highways.

7.2 Why isn't the fuel being delivered by barge or train?

The RDF suppliers do not have private sidings or river ports, leaving trucks as the only viable form of transportation. However, if RDF suppliers start offering delivery by rail or barge, Industriepark Höchst has excellent infrastructure in place for those modes of transportation, too.

8. NOISE

8.1 How much noise is the plant expected to produce?

According to the Technical Instructions on Noise Abatement (TA Lärm), noise pollution will be negligible for the surrounding residential areas. The plant will fall below the noise immission limits stipulated by TA Lärm.

8.2 How much noise is the extra traffic expected to produce?

All the trucks will be driving on highways. So there is no reason why the residential areas should experience any perceptible increase in noise pollution from traffic.

9. ODORS

9.1 How much odor pollution should I expect?

An extensive odor-containment program will ensure that essentially no odor pollution will affect either employees at Industriepark Höchst or local residents. The RDF is transported in tightly sealed trucks which drive into an unloading hall and dump the fuel directly into a separate storage bunker. The unloading hall and the fuel storage bunker are fully enclosed areas that are only opened to allow a truck to drive in. Air in the unloading hall and the storage bunker is drawn off and used in the boiler as combustion air. The entire RDF quality control process is also conducted in enclosed rooms, so it does not pose any pollution problems for the local community, either. This fact has been confirmed by an odor-immission forecast that is included in the permit application.

10. MISCELLANEOUS

10.1 Why wasn't the public notified sooner? Why was Christmas chosen as the time to invite public comment on the permit application?

The project was presented in April 2005 to the Darmstadt Regional Council, the regulator in charge of these kinds of projects. As with other, similar projects, we got all the relevant government agencies, local governments and associations involved in the process in order to jointly define a basic investigatory framework for the licensing process. The application was actually submitted in January 2006 to the Regional Council, who then enlisted all the parties needed to process the application. This was the same procedure used with all the subsequent supplements to the application – up to the day when the public was invited to comment on the application. Public comments were officially solicited by the Regional Council in local newspapers, the State Bulletin, and on the homepage of its website. From that point on, citizens were able to inspect the permit application themselves. In this case, the various factors at play in the overall permitting process essentially determined the schedule for preparing and submitting the permit application.

Besides these official measures required by law, Infraserv Höchst also presented the project at the public meeting of the Industriepark Höchst Neighbors' Association in February 2006, and to the Sindlingen Citizens' Team in June 2006. In addition to the invitation for public comment (Dec. 4, 2006 to Jan. 4, 2007, objection filing deadline: Jan. 18, 2007), the public has been notified about the project several times: Press conferences were held on December 6 and 12, and news releases were issued on December 13 and January 8.

10.2 Why was Thermal Conversion Compound Industriepark Höchst GmbH established?

Thermal Conversion Compound Industriepark Höchst GmbH is a project company that will finance and carry out the project. Infraserv Höchst is one of its principal shareholders.

Contact

Michael Müller
Communications
Phone: +49 69 305-7952
Fax: +49 69 305-80025
michael.mueller3 (at) infraserv.com