PFPI-BiomassIsTheNewCoal-April-2-2014

PM 2.5 , including condensable PM, be evaluated to assess a facility’s impact on air quality. 50 Incontrast, the only emission rate requirement included in most permits for synthetic minor facilitiesis the federal New Source Performance Standard (NSPS) for filterable particulate matter, whichsimply limits filterable PM 10 emissions to less than 0.03 lb/MMBtu, 51 and specifically exemptsfacilities during periods of startup and shutdown.Just because a facility is allowed to emit a certain amount of pollution doesn’t mean it will. Fabricfilter and electrostatic precipitator technologies should reduce filterable PM 10 emissions to less than0.03 lb/MMBtu (though emission rates can spike dramatically during startup and shutdown, whenmost synthetic minor facilities are specifically exempted from meeting an emissions limit – Table3). However, because synthetic minor source permits contain no consideration or limits oncondensable PM or PM 2.5 , total emissions of PM are likely to greatly exceed emissions of justfilterable PM. In fact, permitting agencies don’t seem to have a consistent concept of theimportance of condensable PM, even though it is an important part of total PM emissions.Regulation of condensable PM is chaotic. In our analysis of 23 permits where condensable PMrates were specified or could be estimated by subtracting filterable PM from total PM emissions,we determined that the ratio of allowable condensable emissions to filterable emissions variedsignificantly, with condensable PM rates ranging from 50% to 200% of filterable PM emissionrates.Particulate matter emissions from biomass power plants could be reduced considerably byrequiring use of one of the many high efficiency filtration products that EPA certifies. 52 Table 6shows how, for a representative 500 MMBtu/hr wood-burning boiler with an uncontrolled PMemission rate of 0.56 lb/MMBtu, 53 adding just tenths or one-hundredths of a decimal point in theefficiency of a filtration system can significantly decrease the amount of particulate matter emitted.The higher efficiency fabric filters produce a dramatic reduction in emissions even relative to thecontrol efficiencies of 98% or 99% that are often promised in modern permits, and actuallyrepresent the “best available” technology for particulate matter control. Unfortunately, becauseEPA rules are so weak, with synthetic minor source permits only requiring that facilities meet the0.03 lb/MMBtu NSPS limit for filterable PM, state-level permit writers have little regulatory basisfor requiring facilities to use high-efficiency filters, even if they want to.50Many permits use PM 10 emissions as a proxy for PM 2.5 , assuming that treating all PM as if it is in the smaller size class is themost conservative form of the analysis.51U.S. EPA. 40 CFR Part 60. Standards of performance for electric utility steam generating units, industrial –commercialinstitutionalsteam generating units, and small industrial-commercial-institutional steam generating units; final rule. FederalRegister Vol. 71, No. 38, Feb. 27, 2006.52 EPA lists currently certified products at http://www.epa.gov/etv/vt-apc.html#bfp53 Value of 0.56 lb/MMBtu for uncontrolled PM emissions taken from Table 1 of background document to EPA’s AP-42compilation of emission factors (Eastern Research Group. Background document report on revisions to 5 th Edition AP-42,Section 1.6, Wood Residue Combustion in Boilers. July, 2001).36