PFPI-BiomassIsTheNewCoal-April-2-2014

permitting authorities, especially in states like Georgia that tend to look favorably on forestryrelatedindustries. Since EPA as a whole does not review many of the permits where these NCASIfactors are being used, the Agency appears to be turning a blind eye to the variety of methods beingused to lowball HAPs emissions. One of the most egregious examples is the proposed 50 MW(net) ecoPower facility in Hazard, Kentucky, which invented their own emissions factorsusing selected emissions data, thus estimating less than ten tons of HAPs overall for a 745 MMBtuboiler. Even calculated using the suspect NCASI factors, the total HAPs emissions for the facilitywould have been more than twice that amount.The industry-supplied emission factor for HCl likely underestimates actual emissionsAre the NCASI emission factors credible? To evaluate this question, we analyzed actual emissionsof hydrochloric acid (HCl) from currently operating plants. 81 We focused on HCl because it isemitted by biomass burning in large quantities, and can thus push a facility over the threshold frombeing an area source to a major source of HAPs.The AP-42 emission factor for HCl is 0.019lb/MMBtu (1.9E-02 using scientific notation).Using EPA’s emissions factor, a 121 MMBtuboiler (approximately, an 8 MW facility) wouldAnalysis of actual HCl emissions datasuggests the industry-supplied emissionsfactor under-represents emissions attypical biomass plantshave the potential to emit ten tons of HCl per year, and would thus be a major source for HAPs. Incontrast, the NCASI emission factor for HCl is 0.00067 lb/MMBtu (6.7E-04), just 3.5% the EPA’sAP-42 value. A boiler would have to be 2,840 MMBtu (199 MW) to have a PTE of ten tons peryear using the NCASI factor. This is far larger than any facility in our database.To determine which emissions factor is more representative of HCl emissions from currentlyoperating facilities, we averaged data for the 46 facilties for which EPA has collected recent testdata on HCl emissions, grouping data by the year in which the data were collected, 82 and arrangedthe averages by percentiles (Table 9). Our analysis suggests that the NCASI emissions factorsignificantly underrepresents typical HCl emissions at most biomass plants. The median andaverage emission rates of HCl for the EPA dataset are 1.00E-03 and 8.00E-03 lb/MMBtu,respectively 200% the value of NCASI’s reported median of 5.0E-04 lb/MMBtu, and 1,194% ofthe NCASI average of 6.7E-04 lb/MMBtu. In fact, the NCASI median and average emission factorsfor HCl are both lower than the 30 th percentile of the recent EPA test data, as seen from the actualdistribution of HCl emissions from the EPA dataset. 83 This strongly suggests that the NCASI factorunder-represents HCl emissions at currently operating plants.81EPA called for information on actual emissions to assist in formulating the boiler rule. The database is, Draft EmissionsDatabase for Boilers and Process Heaters Containing Stack Test, CEM, & Fuel Analysis Data Reported under ICR No. 2286.01& ICR No. 2286.03 (version 8) May, 2012. Available at http://www.epa.gov/airtoxics/boiler/boilerpg.html (database labeled“Boiler MACT Draft Emissions and Survey Results Databases”)82 Three of the facilities were represented by three years of data; eight were represented by two years of data.83It is interesting to note that since EPA published its new dataset, NCASI has updated its set of emissions factors. The groupclaims that the new data were integrated with existing data using an “elaborate statistical procedure”.48