Biomass industry comments on EPA emissions plan

Aug. 30,
2010, Washington, D.C. – U.S. federal regulations designed to limit emissions
from industrial boilers may be unattainable for many biomass facilities because
the standards were developed using limited data sets that may not be
representative of the industry, according to comments filed on the rules. The
U.S. Environmental Protection Agency (EPA) is under court order to complete
four rules regulating emissions from industrial boilers by December 16, 2010:
the Industrial Boiler Maximum Achievable Control Technology (MACT), the Area
Source Boiler Rule, the Nonhazardous Secondary Materials that are Solid Waste
rule, and the Commercial Industrial Solid Waste Incineration rule. However,
those rules need to be significantly re-tooled to avoid discouraging the use of
biomass as a renewable fuel, industry sources say. According to critics, the
problems with the rules center on a lack of data and unrealistic assumptions.

“EPA has
‘cherry picked' the best data in setting each standard, without regard for the
sources from which the data come. The result is a set of standards that reflect
the performance of a hypothetical best performing source that simultaneously
achieves the greatest emissions reductions” for every pollutant, the American
Forest Products Association wrote in comments filed to EPA. This mythical
Frankenstein boiler modeled in EPA's rule does not exist in reality, the
association says. Emissions controls involve trade-offs, and EPA does not take
that into account in its rule, the association says.

A primary
concern of the rules' industrial critics is that EPA used a limited data set
collected over a short period of time. EPA used emissions data from less than
1% of the U.S.'s industrial boilers, and from that data set gathered the
lowest-emitting 12% to determine the appropriate limit for each category of
pollutant. The data set for mercury contains only nine coal boilers and only
two biomass boilers. The carbon monoxide data set is almost as limited, with
just five coal boilers and 30 wood boilers included.

The
limits EPA took from these small data sets may be unachievable for a majority
of boilers, especially if startup and shutdown events are included in the
emissions averaging, according to the Florida Electric Power Coordinating
Group. The limits may make it difficult to build complying biomass electric
generators, the group says.

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“The
stringent limits and requirements in the proposed industrial boiler MACT
decrease the prospect of producing reliable renewable energy from biomass … EPA
should encourage the combustion of biomass as substitute fuel for coal or oil
as a matter of good public policy,” wrote Robert Klemans, the director of the
group.

The
limits that EPA derived for new smaller boilers are also unachievable,
according to the Michigan Biomass group.

Smaller
wood boilers are often used by community groups, churches, and schools, and may
only be run a few times a week, according to Pellet Fuel Institute spokesman
Seth Voyles. Installing a baghouse on an infrequently used small boiler does
not make economic sense and will push these groups away from using biomass,
which is otherwise an environmentally friendly renewable energy choice, Voyles
said.

The
nonhazardous solid waste rule, which was proposed in conjunction with the
boiler MACT, could also create problems for the biomass industry. EPA has
proposed to classify any biomass that moves out of control of the producer as
solid waste. So sawdust sold by a sawmill to a pellet maker would become solid
waste, Voyles said. Anything burning solid waste is considered an incinerator
and subject to additional controls.

“They
have no data on smaller boilers,” and a really tight time limit on getting
these rules done, Voyles said.

EPA
acknowledged that additional data would be helpful in shaping the industrial
boiler MACT. “We requested that additional data be provided to EPA [in the
comments] so that the standards can be based on a robust data set that
accurately portrays the emission reductions achieved by the best performing
sources, including variability. We will incorporate new data into our analyses
as we develop the final standards,” said EPA spokeswoman Enesta Jones.

Also:

Read
comments from the U.S. Pellet Fuels Institute:
pelletheat.org/wp-content/uploads/2010/08/PFI-Press-Release-on-Comments-on-Boiler-MACT-GACT-final_1.pdf.

Read
comments from the U.S. Biomass Power Association:
www.usabiomass.org/docs/BPA%20Urges%20EPA%20to%20Reconsider%20Stringent,%20Misguided%20Emissions%20Rule%20for%20Biomass%20Facilities.pdf;
www.usabiomass.org/docs/BPA%20comments%20to%20the%20EPA.pdf.