PFPI-BiomassIsTheNewCoal-April-2-2014

assurance plan. The plant was permitted as a major source of HAPs before the significantlyweakened version of the boiler rule that exists today, and was required to meet a filterablePM emission limit of 0.0011 lb/MMBtu (the current MACT standard for major sourceboilers is 0.03 lb/MMBtu, which is 27 times higher). The filterable PM limit explains therelatively low estimated emissions of 2 tons per year from the plant. The permit also setslimits for emissions of acrolein, ammonia, benzene, formaldehyde, hydrogen chloride(HCl) mercury, and dioxins/furans. Initial and “intermittent” stack tests are required toensure compliance (once per permit term, or every five years). The plant is also requiredto install a continuous emissions monitoring system for PM, which is unusual for thepermits we reviewed.Port Townsend Paper Company, Port Townsend, WAWhat: Facility expansion; 414 MMBtu/hr stoker; ~24 MW net (cogen, uses some thermal energy)Estimated CO 2 emissions (tons per year): 355,518Permitted emissions (tons per year): NOx: 262 CO: 635 PM 10 fil : 36.4 SO 2 : 96Status for NOx, PM, and CO: Major source (PSD)Status for HAPs: Synthetic minor sourceFuel: “Wood fuels including hog fuel, forest biomass, and urban wood. Ecology does not currentlyclassify these wood fuels as solid waste. Wood fuels do not include wood treated withcreosote, pentachlorophenol, or copper-chrome-arsenic; or municipal waste. Forestbiomass means the by-products of current forest management activities, current forestprotection treatments authorized by the agency, or the by-products of forest healthtreatment prescribed or permitted under Washington's forest health law. Forest biomassdoes not include municipal solid waste. Urban wood is purchased wood fuel meeting anacceptance program which prohibits wood treated with creosote, pentachlorophenol, orcopper-chrome-arsenic; municipal waste, hazardous material contaminants (asbestos, lead,mercury), lead painted items, and plastic coatings.” (Urban wood is demolition waste. PortTownsend Paper's fuel also includes reprocessed fuel oil (about 15% of total fuel) andcorrugated cardboard recycling rejects ("OCC rejects"), meaning corrugated boxes that aretoo contaminated with labels, fasteners, etc., to recycle. PTPC uses approximately onethirdof Washington’s recycled cardboard.Construction and demolition wood or other waste allowed as fuel? YesUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: Unlike the Nippon Paper plant at Port Angeles, which was issued by the Olympic RegionClean Air Agency in Washington, the permit for this facility was issued by the WashingtonDepartment of Ecology and contains relatively few protective measures, even though it is alarger facility than the Nippon plant. Emissions calculations that were used to justify theexpansion of biomass burning at the facility include reductions from installing futureemissions control equipment that will be required by law regardless of whether the biomassproject is built or not. The proposed expansion will increase fuel throughput to 2.9 timesthe present amounts.81