PFPI-BiomassIsTheNewCoal-April-2-2014

includes smaller trees, bushes and saplings. Tops, limbs, whole tree material and otherresidues that are damaged due to storms, fires or infectious diseases. Tree parts and/orbranches generated by landscaping contractors and power line/roadway clearancecontractors that have been cut down for land development or right-ofway clearingpurposes. Wood derived from used pallets packing crates; and dunnage disposed bycommercial or industrial users. Herbaceous plant matter; clean agricultural residues (i.e.,rice hulls, straw, etc.; no animal wastes or manure); and whole tree chips and pulpwoodchips.”Construction and demolition wood or other waste allowed as fuel? NoUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: Early in the permit application process, this massive plant applied as a major source forHAPs, but subsequent revisions claimed it would emit less than 25 tons of HAPs, and thefacility was ultimately permitted as an area source. Now, a pending and potential permitrevision filed in February 2014 seeks to regulate the facility under the major source boilerrule, 153 after all, although this re-permitting process is currently suspended. If the plant isre-permitted as a major source for HAPs, its allowable filterable PM emissions will decreaseunder the major source MACT for bubbling fluidized bed boilers, from 0.015 lb/MMBtu to0.0098 lb/MMBtu. This change would reduce permitted emissions of filterable PM from89 tons to 58 tons per year.Green Energy Partners, Lithonia, GAWhat: Two stoker boilers of 93.22 MMBtu/hr; 11.5 MW (net).Estimated CO 2 emissions (tons per year): 160,103Permitted emissions (tons per year): NOx: 25 CO: 249 PM 10 fil : 24 SO 2 :8.1Status for NOx, PM, and CO: Synthetic minor source (avoided PSD)Status for HAPs: Synthetic minor sourceFuel: “Biomass shall consist of wood wastes in chip or in shredded form from timber harvesting,pre-commercial thinning of forest plantation stands, harvesting non-commercial, dead ordeformed species for fuel purposes and land clearing activities (limbs, tops, stumps andnon-commercial trees), and may also include peanut hulls, pecan shells, cotton stalks,lumber and pallet wood wastes (unpainted/untreated only) and similar woody biomass. “Construction and demolition wood or other waste allowed as fuel? YesUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: This plant is being built in the Atlanta metro area, which is out of attainment with EPA’s airquality standard for PM and ozone. It is proposing to use a ceramic filter system for controlof NOx and PM, a technology unique to this facility. Permitted as a synthetic minorsource, the company has avoided measures that could be taken to reduce emissions. Likealmost all the biomass plants that have received air permits in Georgia in recent years, the153Gainesville Renewable Energy Center. Initial Title V air operation permit application filed with Florida Department ofEnvironmental Protection. February 10, 2014.73