PFPI-BiomassIsTheNewCoal-April-2-2014

emove obviously contaminated materials, the extraordinarily high volume of C&D that isprocessed for fuel and the dependence on visual inspection to remove contaminated materialsmeans it is inevitable that pressure-treated, painted, and glued woods get into the fuel stream.Once chipped, and delivered in high volume to a bioenergy facility (Figure 8), as a practical matter,there is little chance of detecting contamination before wood is burned.Further, since unadulterated wood in the waste stream can be recycled for mulch, wood pellets,animal bedding, and particleboard, the most contaminated materials are what is left over forburning – although, in EPA’s view, these are the very materials that are ostensibly sorted out of thebioenergy fuel stream and are not used for fuel. It seems inevitable that the EPA’s proposal to granta blanket exemption from testing of C&D wood will mean that more of this contaminated materialis burned in biomass power plants that have no restrictions on emissions of air toxics. Importantly,this includes many small “thermal only” wood boilers being installed for heat at municipal buildings,schools, campuses, and hospitals – i.e., in close proximity to sensitive individuals includingchildren, the elderly, and the sick. Many of these boilers are too small to even be covered by thearea source rule, which only regulates boilers greater than 10 MMBtu/hr. Once contaminatedwood is in circulation as fuel, it is likely to end up being burned at these small facilities, which havealmost no emissions controls.Garbage-derived fuels are EPA’s new “non-waste fuel products”Another category of materials newly classified as fuels under the waste rule is municipal andindustrial wastes that have been processed into fuel products. EPA’s “legitimacy criteria,” therequirements that a waste must meet in order to bereclassified as a non-hazardous secondary material (NHSM),include processing of the material to reduce contaminants orimprove energy content. Seizing on the opportunitiesprovided by the waste rule, a number of companies are nowprocessing municipal garbage and industrial wastes intocompressed fuel cubes (Figure 9 shows a product fromInternational Paper. 138 ) Once EPA issues a “comfort letter”approving these materials as non-hazardous, they can be usedas a coal or biomass substitute, and burned in units that areregulated as biomass boilers, rather than the more strictlyFigure 9. International Paper fuel cubes,made from compressed waste.regulated incinerators. EPA’s classification of “biomass” burners as including any boiler that burnsjust 10% biomass means that even if these fuels contain substantial fossil fuel-derived content, forpurposes of regulation, units burning them are subject to the very lax boiler rule standards forbiomass boilers.EPA’s administrative process to “transform” wastes to non-hazardous fuels is quite hands-off. Inaccordance with the Agency’s legitimacy criteria, a company wishing to get a non-waste138Photo from http://www.globalventurelabels.com/the-environment/62