PFPI-BiomassIsTheNewCoal-April-2-2014

Hu Honua, Pepe’ekeo, HIWhat: Refire of old coal plant. 407 MMBtu/hr stoker boiler; 23.8 MW gross, 21.5 MW netEstimated CO 2 emissions (tons per year): 349,507Permitted emissions (tons per year): NOx: 210 CO: 246 PM 10 fil : 21.4 SO 2 : 39.2Status for NOx, PM, and CO: Synthetic minor source (avoided PSD)Status for HAPs: Synthetic minor sourceFuel: wood, biodieselConstruction and demolition wood or other waste allowed as fuel? NoUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: This facility took synthetic minor status for criteria pollutants and HAPs. EPA commentedon this permit, observing that it was unlikely that a facility this size could stay below its COcap, and observing that the use of non-EPA sanctioned emission factors for calculatingHAPs emissions needed to be justified. As allowed by the Clean Air Act, a citizen grouppetitioned the EPA to formally object to the permit, and EPA has responded, agreeing thatas written, the pollution limits are not enforceable. This decision is significant because EPAhas made it clear that actual emissions testing for both criteria air pollutants and HAPs mustbe conducted under a variety of operating conditions for a facility to be able to claim andmaintain synthetic minor source status. Many permits for bioenergy facilities being issuedaround the country do not contain these requirements, particularly for HAPs, and aretherefore likely unenforceable under the terms of the Clean Air Act.ecoPower, Hazard, KYWhat: 745 MMBtu/hr fluidized bed boiler; 58 MWEstimated CO 2 emissions (tons per year): 577,073Permitted emissions (tons per year): NOx: 240 CO: 240 PM 10 fil : 240 SO 2 : 240Status for NOx, PM, and CO: Synthetic minor source (avoided PSD)Status for HAPs: Synthetic minor sourceFuel: Hardwood tree stems removed during pre-commercial thinning operations. Storm and firedamaged hardwood trees and tree parts. Low quality hardwood logs and hardwood blocksthat are trimmed in the production of sawlogs. Hardwood wood industry byproducts suchas shavings, saw dust, bark, and similar materials that do not contain preservatives, resins,or other additives. Low quality hardwood logs and hardwood wood chips produced duringright-of-way operations and urban forestry operations. Unrecyclable untreated hardwoodpallets, untreated lumber, and dunnage.Construction and demolition wood or other waste allowed as fuel? YesUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: An early draft of the air permit classified the facility as a major source for HAPs that wouldemit over 35 tons per year. The final version of the permit reduced the amount of HAPs to7.71 tons. The applicant achieved the reduction in estimated HAPs by making up their ownHAPs emissions factors, and only counting certain HAPs toward total emissions. Provisionsrequiring stack testing were removed in the final version of the permit, so the HAPs limitsare unenforceable at this point.75