PFPI-BiomassIsTheNewCoal-April-2-2014

Construction and demolition wood or other waste allowed as fuel? Yes – “clean municipal wood waste”Use of NCASI or other non-EPA factors to estimate HAPs? UnknownNotes: This is the sister plant to the Gainesville Renewable Energy Center in Florida, which claimsto be a minor source for HAPs although it was permitted as a major source. TheNacogdoches plant was permitted as a major source, with permitted emissions of 126 tonsof HCl per year.EDF Allendale, Allendale, SCWhat: New facility; 275 MMBtu/hr stoker; 21 MW gross, 17.5 MW netEstimated CO 2 emissions (tons per year): 236,153Permitted emissions (tons per year): NOx: 241 CO: 250 PM 10 fil : 36 SO 2 : 30.1Status for NOx, PM, and CO: Synthetic minor source (avoided PSD)Status for HAPs: Synthetic minor sourceFuel: The boiler is permitted to burn only clean, untreated wood waste as fuel. Clean wood isdefined in SC Regulation 61-62.1 as untreated wood or untreated wood products includingclean untreated lumber, tree stumps (whole or chipped), and tree limbs (whole orchipped). Clean wood does not include yard waste, or construction, renovation, anddemolition waste (including but not limited to railroad ties and telephone poles). The useof any other substances, including yard waste and construction, renovation and demolitionwaste, as fuel is prohibited without prior issuance of a construction permit revision fromthe Bureau of Air Quality.Construction and demolition wood or other waste allowed as fuel? NoUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: This permit would be a major source for HAPs if AP-42 emission factors had been used tocalculate emissions instead of a combination of NCASI and other factors. This facility has atwin which has also recently come online, the EDF Dorchester plant in Harleyville, SC.Dominion Energy, Southampton, Altavista, and Hopewell, VAWhat: Three 63-MW coal plants being converted to 51 MW biomass plants: Altavista (Altavista,VA), Hopewell (Hopewell, VA) and Southampton (Franklin, VA)Estimated CO 2 emissions (tons per year): 2,030,060 (three facilities)Permitted emissions (tons per year): NOx: 412 (x 3) = 1,236 CO: 916 (x 3) = 2,748PM 10 fil : 59.6( x 3) = 178.7 SO 2 : 38.2 (x 3) = 114.6Status for NOx, PM, and CO: Major sources (PSD)Status for HAPs: Unknown.Fuel: Three permits; two specify use of 785,480 tons of wood a year and no contaminated wood;one permit (Southampton) allows use of 5,879,518 gal/yr distillate fuel oil. “Biomassmeans those residuals that are akin to traditional cellulosic biomass including forest-derivedbiomass (e.g., green wood, forest thinnings, clean and unadulterated bark, sawdust, trim,and tree harvesting residuals from logging and sawmill materials) wood collected fromforest fire clearance activities, trees and clean wood found in disaster debris, and clean79