PFPI-BiomassIsTheNewCoal-April-2-2014

La Pine, Oregon, used the NCASI factor to estimate its HCl emissions, claiming to be an areasource for HAPs. The plant is not going to use any sorbent system for HCl, even though up to 20%of its fuel will be construction and demolition wood. 86 This suggests this facility should acutally beregulated as a major source for HAPs.The AP-42 HCl emissions factor of 0.019 lb/MMBtu (1.9E-02), which is based on the average ofolder data collected by the Agency, falls between the 80 th and 90 th percentiles of the new set of EPAemissions data that we analyzed, suggesting that it is a relatively protective factor that adequatelycharacterizes emissions of many new facilities. Since so many facilities are being permitted withouta sorbent system to reduce HCl emissions, the need to estimate emissions using properlyconservative factors is even greater.Overall, the evidence suggest that the NCASI emission factor for HCl significantly underestimatesHCl emissions at most facilities. Of the 88 facilties in our permit database, all but three had boilersthat were greater than 121 MMBtu in capacity, meaning that if their emissions had all beencalculated using the EPA’s AP-42 factor, all these facilities would have been regulated as majorsources for hazardous air pollutants on the basis of their potential to emit HCl emissions alone.When states issue permits and allow permit applicants to pick and choose what emissions factors touse for air toxics, including the low-ball NCASI factor for HCl, the result is that facilities areerroneously permitted as “area” sources under the boiler rule.Loophole 6: Weak testing requirements mean air toxics limits aren’t enforceableOnce a facility that has been permitted as an area source for HAPs is operating, lax to non-existenttesting requirements for air toxics mean it may be able to exceed allowable emissions thresholdsand pollute with impunity. While facilities that avoid PSD by declaring themselves minor sourcesfor criteria pollutants are required to at install continuous emissions monitors (CEMs) for a fewcriteria pollutants such as NOx and CO, there isalmost no monitoring required for emissions of Facilities are supposed to estimate allhazardous air pollutants, and thus no way to ensure emissions of air toxics when claimingthat permit limits are or can be enforced. Some minor source status, but few dopermits require facilities to perform one-time stack tests for certain air toxics 180 days afterstartup, then possibly once every few years thereafter, although this is not always enforced. Forexample, although the wood- and garbage-burning 33 MW(gross) EvergreenCommunity Power facility in Reading, Pennsylvania started operation on August 17,2009, the plant still had not conducted required stack testing for dioxins, metals, HCl, PM, NOx,SOx, and other pollutants 87 as of September 2011, more than two years later, due to86 Oregon Department of Environmental Quality, Eastern Region. Standard air contaminant discharge permit review report forBiogreen Sustainable Energy Co., LLC. Permit No. 09-9557-ST-01.87Required pollutant tests from letter to Mr. Cliff Heistrand, Evergreen Community Power, from George N. Liddick,Pennsylvania Department of Environmental Protection, June 1, 2009.50