The RPS Rant
In today’s world the urgent need to reduce consumption of the Worlds resources, in particular energy, and reduce pollution, particularly greenhouse gases, is being driven by mountains of regulation. Often this regulation is not meticulously reviewed and the law of unintended consequences applies. Sometimes regulation appears to have been written by heavy handed zealots with no consideration of the way the real world works.
we invite you to submit your pet rant against this mind numbing tide.
Here are just a few of our own pet rants:
1. ATEX/DSEAR.
We like all sane people are in favour of a safe working environment but have some problems with the way DSEAR has been implemented by the landfill gas industry. Is there really a problem in the landfill gas industry which wasn’t being adequately controlled by the existing zoning requirements? If there was, we haven’t seen it in over 20 years of working in the industry.
Clearly SIRA and the steering group behind the ESA ICoP2 think there is. In our opinion this has to be one of the poorest pieces of guidance to hit the industry. For instance the ICoP includes a formula to calculate the mass flow rate from a leak. This formula was developed for the natural gas industry. The formula is based on the assumption that there is an infinite supply of gas to continue feeding the leak. This is a good approximation where the leak rate is much smaller than the total flow through the pipe. However where the leak rate is significant compared to the gas flow in the pipe or even approaches or exceeds the total flow in the pipe this formula is useless. As the leak occurs the pressure in the pipe will drop, thus leading to a reduction in pressure, again leading to a reduction in leak rate, etc. It can therefore only be applied to minor leaks on large flow pipe work. In the ICoP the equation is applied to large diameter leaks (i.e. from a dipping point) on low flow pipe work (i.e. a gas wellhead). It therefore significantly over estimates the leak rate where the leak is anything other than minor. This leads to the bizarre situation where a well with the dip cap removed supposedly has a larger zone extent than one with the entire wellhead removed!
The ICoP rather sensibly decides that the surface of the landfill has a zone of negligible extent. However it then rather foolishly decides that where a well is drilled the bentonite seal may form a pathway for gas to escape. It then applies its nonsensical formulas to the theoretical gas production rate from a well under suction and determines that the zone surrounding a bentonite seal should be 2.2 m. You then end up with the perverse situation that the area of an uncapped landfill where there is a 3m thick impermeable clay barrier has a zoning classification and the totally permeable waste surface has no zone.
I wonder what effect the ICoP will have in tipping areas where leachate wells are bought up with the waste and no vehicle is allowed within 2.2 m of the wells (unless any one knows of a zone 2 rated compactor?).
2. Using Chip Fat to Generate Electricity
You would think that making use of old chip fat to generate electricity would be a good thing and generally beneficial to the environment. Well it may be but a friend of ours who runs a landfill gas generation project in East Anglia found it was not to the liking of the Environment Agency.
Our friend has run a landfill gas generation station since 1996 initially using some slow speed dual fuel compression ignition engines. Recently these were replaced with a modern spark ignition Caterpillar generator but the dual fuel engines were retained as a back up.
Rather than see the dual fuel engines idle he devised a scheme to collect used chip fat from the many costal fish and chip shops in the area and run the duel fuel engines on this. Although the duel fuel engines ran perfectly well on the processed chip fat the EA were not happy.
Apparently, though the chip fat has been heated many times in the cooking process and would be burnt in the engine, it may have been in contact with meat and so falls foul of the animal by-products regulation and he was shut down.
Some little while later our friend happened to see a news article describing a project where used chip fat was to be collected and processed and used to fuel 20 or so buses running around the streets of a local seaside town. Since the exhaust fumes were so dangerous everyone could share them!
The EA’s view on this? We understand they struggled to find a sensible comment. I have to say it leaves us speechless.
3. In-Vessel Composting
In vessel composting is another result of the animal byproducts regulations. Parliament decided that anything that may have once seen an animal must be treated akin to a toxic biohazard. Previously composted waste (e.g. vegetable peelings from the kitchen) now could not be collected and composted in windrows but must be in a rat and bird proof sealed system. This had the effect of diverting all this waste to landfill sites. As anyone who has been on one knows these are hardly rat or bird free!
Councils now are developing expensive in-vessel composting facilities to deal with this type of waste. The environmental benefits of composting are therefore much reduced due to the high construction and operating costs (and consequent energy inputs). In the composting process carbon dioxide (and some methane) is released with no net output of energy. Anaerobic digestion on the other hand would produce a similar result (soil conditioner compost) but would allow renewable electricity to be generated as well. Yet councils still continue to build in-vessel composting facilities when anaerobic digestion has a clear environmental benefit and would add to the renewable electricity generation target. Another example of joined up government thinking? We think not!