PFPI-BiomassIsTheNewCoal-April-2-2014

elatively high filterable PM standard of 0.03 lb/MMBtu, with no limits on HCl, dioxins, mercury,or other heavy metals, even as they burn potentially contaminated fuels.Some plants will be fueled almost exclusively by waste wood. The 37.5 MW (net) PlainfieldRenewable Energy plant in Plainfield, Connecticut is permitted to burn up to 495,305tons per year of wood, including “waste wood from industries” and construction and demolitionwaste. The wood is supposed to be sortedto remove materials like plastics, gypsumwallboard, and “wood which contains creosoteor to which pesticides have been applied or whichThe majority of “area” source permits, whichlack any emissions limits for air toxics, allowpotentially contaminated waste wood as fuel.contains substances that have been defined as hazardous,” 109 but it is not clear how effective such sortingcan be, given that the sorting facilities rely on visual inspection to remove contaminated materialsfrom a fast-traveling conveyor belt loaded with tons of debris. Any testing program to check forcontamination is bound to be statistically invalid, given that on average the Plainfield plant will burnmore than 60 tractor-trailer loads of wood chips per day. In Massachusetts, the state commissioneda health risk assessment for burning “sorted” construction waste after a construction and demolitiondebris burner was proposed for the city of Springfield, citing concerns about emissions of heavymetals and other hazardous air pollutants, 110 but Connecticut has commissioned no equivalentstudy.Many other facilities will depend on at least some waste wood, even when forestry wood isapparently available. Two biomass cogeneration expansion projects associated with paper mills onthe Olympic Peninsula in Washington, the 20 MW (net) Nippon Paper facility at PortAngeles, 111 and the 24 MW (net) boiler at the Port Townsend Paper Company plant, 112will both burn waste wood as fuel, along with forestry wood (the Nippon facility also burnswastewater-treatment sludge from the paper-making process).Why would biomass facilities want to burn contaminated fuels? There are a number of reasons.Pass-through of tipping fees for waste disposal to biomass power plants can produce a lucrativerevenue stream for a facility. In some cases, facilities may fear that “clean” wood sources arelimited, or might become more distant over time , increasing transportation costs. Finally, certainwaste fuels burn hotter and produce more energy than green forestry chips. Construction anddemolition-derived wood tends to be drier, which increases its heating value per unit mass, andpaper-based and especially plastic-based fuels can have significantly higher heating values than wood– for instance, the proposed 25 MW (net) Taylor Biomass plant, a wood and garbage-109Connecticut Department of Energy and Environmental Protection. Bureau of Air Management. New Source Review Permitfor Plainfield Renewable Energy LLC. Permit modification date December 8, 2011.110This study was not completed because the developer of the Palmer Renewable Energy plant in Springfield elected to reapply asa facility that would only burn “clean” wood derived directly from trees, rather waste wood.111 Olympic Region Clean Air Agency. Order of Approval – Notice of Construction 10NOC763, Issued to Nippon PaperIndustries USA Co. Ltd. June 21, 2011.112Washington Department of Ecology. Notice of Construction for Port Townsend Paper Corporation, NOC Order No. 7850.October 22, 2010.56