PFPI-BiomassIsTheNewCoal-April-2-2014

Another concern about burning plastic-based fuels like SpecFUEL is their dioxin emissions. Whilethe incinerator rule sets limits for dioxins, the boiler rule does not regulate dioxins directly (aninitial draft of the boiler rule did include direct limits on dioxins, but EPA removed these in thefinal rule, presumably due to objections from the bioenergy industry). Instead, the major sourceboiler rule regulates CO emissions as a proxy indicator of incomplete combustion, which can leadto dioxin formation. The CO limits in the major source boiler rule are extremely lax, and in anycase, almost irrelevant to the facilities we reviewed, since so few plants admitted to being majorsources for HAPs. The area source rule, which regulates the majority of the facilities we reviewed,contains no limit on dioxins or CO. The result of EPA’s new waste rule is that if waste-derivedfuels like SpecFUEL are burned in biomass units, there are no restrictions or accountability fordioxin emissions, or indeed for any HAPs other than HCl. According to the letter from EPA,Waste Management plants to build SpecFUEL plants all over the United States. 143Case study of a biomass power plant burning waste: Evergreen Community PowerThe 33 MW (gross) Evergreen Community Power/United Corrstack facility inReading, Pennsylvania is an example of the kinds of waste-burning biomass projects that EPArules encourage and the bioenergy industry wishes to promote. This combined heat and powerplant associated with United Corrstack, a paper product manufacturing company, cost $140 millionto build. It received a $39 million “clean”energy grant from the federal government atstartup. 144 An evaluation by the Departmentof Energy states that the fuel burned at theplant includes mostly wood, but that there are“significant amounts of paper, plastic and otherforeign debris” 145 (Figure 10 146 ). This fuel mixsuggests that the facility is actually anincinerator, although for reasons that areunclear, it was not permitted as one. TheDOE reported that the facility receives 41 –55 tractor trailer loads a day of fuel and burns300,000 – 350,000 tons per year. It generates~70,000 tons of toxic ash a year, which costs$2.45 million a year for disposal.Figure 10. The fuel burned at the Evergreen CommunityPower facility in Reading, Pennsylvania.143Letter to Ms. Kerry Kelly, Waste Management, from US EPA Office of Solid Waste and Emergency Response, August 22,2013. Available at http://www.epa.gov/epawaste/nonhaz/define/144The guidance for the Department of Treasury’s 1603(b) program, which converts the Incentive Tax Credit worth 30% ofconstruction costs to a cash grant, states that the program provides a long-term benefit of expanding the use of clean andrenewable energy and decreasing our dependency on non-renewable energy sources.”http://www.treasury.gov/initiatives/recovery/Documents/GUIDANCE.pdf145 U.S. Department of Energy, Mid-Atlantic Clean Energy Application Center. Evergreen Community Power Plant Case Study:33 MW Facility Using Biomass. November 16, 2011.146U.S. Department of Energy, Mid-Atlantic Clean Energy Application Center. Evergreen Community Power Plant Case Study:33 MW Facility Using Biomass. November 16, 2011.65