PFPI-BiomassIsTheNewCoal-April-2-2014

is regulated under the boiler rule, therefore requires converting the bioenergy MACT standard(which is expressed on an input basis, as lb/MMBtu) to an output basis. 67Assuming a 24% conversion of energy to electricity for bioenergy, which is a typical value forlarge-scale bioenergy facilities, for filterable particulate matter:The biomass boiler MACT standard of 0.03 lb/MMBtu for a stoker boiler translates to arate of 0.427 lb/MWh on an output basis, 474% the standard for a coal plant regulatedunder the EGU rule,The biomass boiler MACT standard of 0.0098 lb/MMBtu for a fluidized bed boilertranslates to a rate of 0.139 lb/MWh on an output basis, 68 154% the standard for a coalplant.Thus, even subject to the “maximum achievable” control technology standard for hazardous airpollutants, biomass power plants are allowed to emit dramatically more particulate pollution thancoal plants.EPA rules let biomass plants emit more air toxics than waste incineratorsUnder the Clean Air Act, how much pollution an industrial boiler is allowed to emit depends inpart on whether it is classified as a biomass burner (an ICI unit) or a waste incinerator (a CISWIunit, which burns commercial and industrial waste). 69 Waste incinerators are generally betterregulated than biomass burners, as the CISWI standards apply to all units regardless of their size,based on potential to emit, and because the rule regulates a larger number of the pollutants likely tobe present in waste, and generally regulates them more tightly (Table 7). This seems reasonable,given that burning wastes is likely to emit more toxins than burning wood and other fuels typicallythought of as “biomass,” but as we explain below, EPA’s new rules blur the line between biomassand waste, allowing a greater amount of contaminated fuels to be burned as biomass in area sourceboilers, which have no emission limits for HAPs.As shown in Table 7, while the CISWI rule is not especially rigorous, it does recognize thepotential for heavy metals and dioxin emissions from burning waste materials, regulating a coupleof metals directly (an important exception is that the CISWI rule does not set an emission limit forarsenic, which is one of the main ingredients in the copper-chromium-arsenate (CCA) cocktail thatis used to pressure-treat wood). Unlike the incinerator rule, the boiler rule only regulates nonmercurymetals indirectly, by setting emission standards for filterable particulate matter, whichEPA considers a proxy for metals emissions.67 To do this, one divides boiler capacity by the efficiency of the conversion from heat input to electricity, and converts units ofMMBtu to MWh. The conversion from btu to MWh is made assuming 3,413,000 btu per MWh68These conversions assume 24% efficiency for the biomass boilers.69Municipal waste, medical waste, sewage sludge, and certain other types of waste are regulated separately.42