Covanta Energy Corporation
40 Lane Road
Fairfield, NJ 07004
Telephone: (973) 882-2768
Facsimile: (973) 882-4167
Via Electronic Mail to: lcfs@nescaum.org
November 10, 2009
Northeast States for Coordinated Air Use Management
89 South Street, Suite 602
Boston, MA 02111
Re: Northeast/Mid-Atlantic Low Carbon Fuel Standard
To Whom it May Concern:
We are pleased to offer comments on the Northeast and Mid-Atlantic Low Carbon Fuel Standard (LCFS). Efforts to reduce the emissions of transportation fuels, such as the LCFS, are crucial to overall efforts to reduce emissions of greenhouse gases (GHGs) and mitigate the future impacts of climate change.
We are also pursuing exciting emerging technologies that convert waste into renewable diesel. Covanta has begun construction of an innovative waste-to-diesel demonstration project at one of our existing facilities in New England. Once operational, the waste-to-diesel process will generate non-ester renewable diesel fuel through catalytic depolymerization of a variety of different waste feedstocks, including MSW.
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LCA of MSW in Waste-to-Diesel Process
Covanta has begun construction of an innovative waste-to-diesel demonstration project at one of our existing facilities. Once operational, the process will produce renewable diesel fuel from a variety of different waste feedstocks, including, but not limited to, MSW.
Covanta’s waste-to-diesel process is a catalytic depolymerization process that can be applied to a variety of feedstocks, including post-recycled MSW, plastic wastes, biomass, hydrocarbon sludges, and tires. Prior to reaction, feedstocks are processed for size to less than 2 inches and metals and glass are separated. The catalytic depolymerization process is simpler than many competing processes, relying on a patented “friction turbine” which provides necessary heat in the process while creating turbulent mixing needed for the catalytic reactions. (ALPHAKAT-GLOBAL ENERGY) By-products are predominately CO2 and H2O with a small amount of volatile organic compounds (VOCs). Exhaust gases from the demonstration project are routed to the existing energy from waste (EfW) boilers and air pollution control to ensure destruction of any VOC emissions from the process.
A life cycle analysis (LCA) performed reveals that, for a wide range of biogenic fractions of MSW, the process generates a fuel with significantly lower GHG emissions than the diesel baseline (Figure 4).
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