PFPI-BiomassIsTheNewCoal-April-2-2014

Summary case studies: the emerging bioenergy industryThe following are some representative examples of biomass power plants being proposed and builtaround the country. Information on facilities and the loopholes from which they benefit is takenfrom permits and permit application documents. Unlike the set of permits for new, “greenfield”facilities that we used for graphically demonstrating the differences between PSD facilities andsynthetic minor facilities (Figures 4 through 7), this list includes some biomass facilities thatpreviously burned fossil fuels.Sierra Pacific, Anderson, CAWhat: An existing facility that is increasing biomass-burning capacity. 468 MMBtu/hr stoker boiler;31 MW (gross)Estimated CO 2 emissions (tons per year): 401,890Permitted emissions (tons per year): NOx: 267 CO: 472 PM 10 total : 41 SO 2 : no limit setStatus for NOx, PM, and CO: Major source (PSD)Status for HAPs: Major sourceFuel: 25 bone dry tons/hour of: “a. Untreated wood pallets, crates, dunnage, untreatedmanufacturing and construction wood debris from urban areas; b. All agricultural crops orresidues; c. Wood and wood wastes identified to follow all of the following practices; i.Harvested pursuant-to an approved timber management plan prepared in accordance withthe Z'berg-Nejedly Forest practice Act of 1973 or other locally or nationally approved plan;ii. Harvested for the purpose of forest fire fuel reduction or forest stand improvement.”Construction and demolition wood or other waste allowed as fuel? YesUse of NCASI or other non-EPA factors to estimate HAPs? UnknownNotes: This air permit does not set a limit for SO 2 at all, and does not specify any means ofcontrolling emissions of HCl, as apparently, the major source limit of 0.022 lb/MMBtu forHCl under the boiler rule is so easily met, no controls are needed. The plant can emit up to45 tons of HCl under the major source limit. This permit is also notable in that it actuallyspecifies an emission rate for CO 2 , unusual for a bioenergy plant permit.DTE Stockton, Stockton, CAWhat: Refire of old coal plant to biomass. 699 MMBtu/hr stoker boiler; 54 MW (gross).Estimated CO 2 emissions (tons per year): 600,259Permitted emissions (tons per year): NOx: 108 CO: 248 PM 10 total : 58 SO 2 : 70Status for NOx, PM, and CO: Synthetic minor source (avoided PSD)Status for HAPs: Synthetic minor sourceFuel: “Biomass is defined as any organic material originating from plants, not chemically treated andnot derived from fossil fuels, including but not limited to products, by-products, andresidues from agriculture, forestry, aquatic and related industries, such as agricultural,energy or feed crops and residues, orchard and vineyard prunings and removal, stone fruitpits, nut shells, cotton gin trash, corn stalks and stover, straw, seedhulls, sugarcane leavingsand bagasse, aquatic plants and algae, cull logs, eucalyptus logs, poplars, willows,70