PFPI-BiomassIsTheNewCoal-April-2-2014

emission limits for HAPs, but does not specify how those emission limits should be met, orwhether testing for all HAPs is required. The HAPs provisions in this permit thereforeappear to be unenforceable, although subsequent issuance of a Title V operating permit mayrectify this.Montville Power, Uncasville, CTWhat: 600 MMBtu/hr stoker boiler when firing biomass; 42 MW (net). Can convert to distillate oilor gas for up to 995 MMBtu/hr and 82 MW (net).Estimated CO 2 emissions (tons per year): 515,244 (when firing biomass)Permitted emissions (tons per year): NOx: 158 CO: 263 PM 10 fil : 31.5 SO 2 : 65.7Status for NOx, PM, and CO: Major source (PSD)Status for HAPs: Presumably majorFuel: Chipped trees, stumps, branches or brush. Recycled wood or clean wood, meaning any woodor wood fuel which is derived from such products or processes as pallets skids, spools,packaging materials, bulky wood waste or scraps from newly built wood products, providedsuch wood is not treated wood. Other Clean Wood, if properly sized, clean,uncontaminated wood materials, such as sawdust, chips, bark, tree trimmings or otherorganic based materials.Construction and demolition wood or other waste allowed as fuel? YesUse of NCASI or other non-EPA factors to estimate HAPs? UnknownNotes: This permit requires the facility to meet emissions standards for a long list of air toxicsoutlined in Connecticut regulations, but only specifies testing for HCl and ammonia, whichwhile toxic, is not considered to be a hazardous air pollutant. The permit therefore appearsto be unenforceable, although subsequent issuance of a Title V operating permit may rectifythis.Gainesville Renewable Energy, Gainesville, FLWhat: 1,359 MMBtu/hr fluidized bed boiler; 116 MW (gross), 100 MW (net)Estimated CO 2 emissions (tons per year): 1,167,000Permitted emissions (tons per year): NOx: 416 CO: 714 PM 10 fil : 58 SO 2 : 172.6Status for NOx, PM, and CO: Major source (PSD)Status for HAPs: Initially permitted as area source; may be re-permitted as major sourceFuel: “Tops, limbs, whole tree material and other residues from soft and hardwoods that result fromtraditional silvicultural harvests; Saw dust, bark, shavings and kerf waste fromcutting/milling whole green trees; fines from planning kiln-dried lumber; wood wastematerial generated by primary wood products industries such as round-offs, end cuts,sticks, pole ends; and reject lumber as well as residue material from the construction ofwood trusses and pallets. Tops, limbs, whole tree material and other residues that resultfrom the cutting or removal of certain, smaller trees from a stand to regulate the number,quality and distribution of the remaining commercial trees; and forest understory which72