PFPI-BiomassIsTheNewCoal-April-2-2014

iomass from land clearing operations, each as specified in the definition of Clean CellulosicBiomass in 40 CFR 241.2, excluding any wood which contains chemical treatments or hasaffixed thereto paint and/or finishing materials or paper or plastic laminates. Approvedbiomass is biomass that does not contain contaminants at concentrations not normallyassociated with virgin biomass materials.”Construction and demolition wood or other waste allowed as fuel? NoUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: While initial stack testing is required to determine emissions of SO 2 , NOx, CO, VOCs,sulfuric acid mist, and hydrogen fluoride, there is no stack testing required for HCl or otherHAPs. Requirements for HAPs testing may be included when Title V operating permits forthe plants are issued.Nippon Paper, Port Angeles, WAWhat: Facility expansion; 420 MMBtu/hr stoker; ~20 MW net (cogen, uses some thermal energy)Estimated CO 2 emissions (tons per year): 360,670Permitted emissions (tons per year): NOx: 184 CO: 644 PM 10 fil : 2 SO 2 : 152Status for NOx, PM, and CO: Major sourceStatus for HAPs: Major source (PSD)Fuel: “Approved Cogeneration Plant Fuels: The Permittee shall burn only clean woody biomass,recycled wood-derived fuel, dewatered wastewater treatment sludge, natural gas, and ultralow sulfur diesel fuel in the cogeneration plant. For the purpose of this order: a. Cleanwoody biomass, also known as hog fuel or hogged fuel, is defined is any woody materialthat meets the definition of clean cellulosic biomass in §241.2. b. Recycled wood-derivedfuel is defined as any woody, non-hazardous secondary material that has been declared nonwasteby the standards and procedures outlined in §241.3. c. Dewatered wastewatertreatment sludge is defined as clarifier sludge consisting largely of pulp and paper fibers andproduced on site that has been declared non-waste by the standards and procedures outlinedin §241.3. d. Natural gas means any fuel defined as natural gas in §63.7575, includingpropane and LPG. e. Ultra low sulfur diesel fuel means fuel oils containing less than 0.05weight percent nitrogen and less than 0.0015 weight percent sulfur that comply with thespecifications for fuel oils numbers 1 and 2 as defined by ASTM D396 or diesel fuelnumbers 1 and 2 as defined by ASTM D975. Ultra low sulfur fuel oil may contain anypercentage of biodiesel that complies with the specifications in ASTM 6751, provided thenitrogen and sulfur limits are met by the liquid fuel mixture.”Construction and demolition wood or other waste allowed as fuel? YesUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: Located on the Olympic Peninsula, about 31 miles from the Port Townsend PaperCompany, this facility was required to reduce emissions of air toxics more than most otherfacilities we reviewed, but as it burns a variety of contaminated fuels, including papermakingsludge, its emissions of air toxics are likely to be high. The company is required byits permit to develop a fuel monitoring plan and test fuel analyze for chlorine and mercurycontent. It is supposed to ensure that “recycled wood derived fuel” meets a quality80