PFPI-BiomassIsTheNewCoal-April-2-2014

material classified as a commercial or industrial waste 60 it is regulated under the Commercial andIndustrial Solid Waste Incinerator rule (CISWI).Under the boiler rule, a facility is considered a “major” source for HAPs if it has the potential toemit more than 10 tons of any one HAP or more than 25 tons of all HAPs in a year. If potentialemissions are anticipated during the permitting process to be less than this, a facility is classified as aminor source, known as an “area” source in MACT parlance. In some cases, the MACT standardsset emission limits directly for the HAP in question; in the boiler rule, however, only HCl andmercury are regulated directly, and other HAPs are regulated indirectly by setting limits onemissions of PM and CO, which EPA has claimed can serve as “surrogates” for emissions of variousco-emitted HAPs. 61While the term “maximum” achievable control technology (MACT) for hazardous air pollutantswould imply that HAP emissions are controlled to the greatest degree possible, EPA’s approach,and the way data are manipulated to set standards, have not resulted in protective standards. As anarea source, the only limit a biomass burner greater than 30 MMBtu 62 must meet under the rule is afilterable PM emissions rate of 0.03 lb/MMBtu, the same rate as required under the NSPS, asdescribed above in the section on PSD avoidance. The biomass area source rule does not set anyemissions limits on dioxins, other organic HAPs like benzene and formaldehyde, metals likemercury, arsenic, and lead, or hydrochloric acid (HCl) and other acid gases.Since the area source standard is so weak, it mightbe expected that emissions standards for majorsources of HAPs (those that anticipating exceedingthe 10/25 ton limit) would be more rigorous, butin fact, the filterable PM standard for stokerUnder the boiler rule, the majority ofbiomass power plants have almost norestrictions on the amount of toxicpollution they can emit.boilers under the major source rule is also 0.03 lb/MMBtu, the same as for area sources, althoughthe filterable PM standard for bubbling fluidized bed boilers is one third the standard for stokers, at0.0098 lb/MMBtu. In general, the MACT standards are far more lax than what can be routinelyachieved using present-day technology. For example, the 0.03 lb/MMBtu filterable PM limit formajor source stoker boilers (and area sources) is orders of magnitude higher than filterable PMemissions levels that can be achieved using high-efficiency fabric filters discussed above, as shown inTable 6. The CO standard set by the major source MACT rule is higher than rates commonly setby BACT determinations, as we discuss in more detail below. The major source MACT limit forHCl, which is supposed to serve as a proxy for emissions of other acid gases like hydrogen fluoride,is set at 0.022 lb/MMBtu, about an order of magnitude higher than emissions that can be achievedusing sorbent injection. The limit is so high, it allows facilities that have declared themselves majorsources for HAPs, like the 31 MW unit being added at the Sierra Pacific Anderson plantin Anderson, California, to be built without HCl controls. That facility projects emitting 45 tons60 Municipal waste, medical waste, sewage sludge, and certain other types of waste are regulated separately.61 There is considerable debate as to whether these proxies are at all valid, and much evidence that emissions of certain HAPs aredecoupled from their proxies.62The rule sets the filterable PM rate at 0.07lb/MMBtu for biomass burners that are 10 – 30 MMBtu in capacity.40