The following guest blog is from Bill Carson, Principal of Carlson Small Power Consultants of Redding, CA. Over the last decade, Carlson has consulted in the development of 12 small biomass cogeneration facilities. Over a forty year career in energy, he has operated plants combusting gas, coal, trash, biomass and coal waste. He is the former chairman of the national Biomass Power Association, and served on the boards of 25x’25, California Biomass Energy Alliance, Electric Power Supply Association, and the Independent Energy Producers of California, as well as on the Biomass Task Force of the Western Governors’ Association.
An anti-biomass energy group issued a “report” this week that is, at most, propaganda chock full of scare tactics, misstatements and half-truths so biased in its interpretation of data that it is difficult to figure out just where to start first in pointing out the obvious inadequacies of its findings.
The document, self-published by the Partnership for Policy Integrity (PPI) speciously contends that biomass electricity generation is more polluting and worse for the climate than coal.
It is not the first attack on biomass generated by those who would insist on a “business-as-usual” approach to meeting our nation’s energy needs, and it won’t be the last. But with EPA having under consideration proposals to regulate under the Clean Air Act greenhouse gas emissions resulting from energy generated by biomass in the same way it regulates these emissions from coal-fired energy generation, it’s important to address and correct the impressions left by erroneous, if not baseless, assertions.
Misrepresentation of Hazardous Air Pollutant (HAP) Emissions from Biomass
Perhaps one third of the total PPI document is devoted to Hazardous Air Pollutants (HAP) emissions from biomass and the lack of regulation, control and documentation. In reality, if lead or mercury or chlorine is not present in fuel in the first place, it is not going to be present in emissions. EPA and state regulators appreciate and accept this fact, but the authors clearly do not understand it. Much is made of dioxin and HCL in the report, but virgin wood does not contain more than trace amounts of chlorine, a necessary element in in both pollutants. The vast majority of biomass fuel in the United States remains residue and waste material from the agriculture and forest products industries, and that is not expected to change. These materials do not contain the precursors for the HAPs of greatest concern. Sure, it makes great theater to talk about lowering kids test scores from mercury emissions, but if the fuel contained no mercury to begin with, it is not going to be formed in the combustion process. There are some higher order organic compounds that could be created from inefficient combustion, but EPA and the States have rightly determined that limits on CO and VOC’s will assure these are controlled.
Construction and demolition debris does have some potential to generate HAP emissions, if not sorted and processed properly. However, this feedstock is only a small fraction of the overall biomass supply. Any HAP emissions generated from its combustion would be subject to the emissions thresholds established by EPA, which, if exceeded, would trigger additional regulatory controls.
EPA Is Not Giving Biomass a Pass on the PSD limits
Much is also made in the PPI document of the fact that fossil fueled power plants trigger a Prevention of Significant Deterioration (PSD) review at 100 tons per year (tpy) of emission of any single pollutant, while the same trigger for biomass power occurs at 250 tpy. It’s stated that this is a sweetheart deal that EPA is giving biomass, when, in reality, there is a short list of very major industries that trigger at 100 tpy such as oil refineries, chemical plants, steel mills and fossil fuel power plants. All other industry sectors use the 250 tpy trigger, and that includes biomass. The list was simply a recognition by EPA years ago that there are a few very large sectors in America with known major emissions, and then there is everyone else, including biomass. No pass is given!
Misunderstanding of the EPA/State Relationship
The paper states that biomass power seeks to avoid more stringent EPA emission limits and instead finds a way to rely on more lenient state standards. In fact, the relationship was designed such that the EPA limits are a minimum, and can be exceeded by the states, but never made less stringent. The Clean Air Act was designed so that states could get “delegated authority” from EPA to run the air quality permitting program so long as they ran it in accordance with an EPA approved State Implementation Plan – a system that has been in place for more than 40 years and works just fine. If EPA believes that the state is becoming too lenient, it can pull that authority, and has in the past. The states typically do, however, have the ability to look at biomass permits in totality, recognizing that a new plant may stop open burning of agricultural waste in California, or reduce the open burning of logging slash in Georgia, and, as a result, have a dramatic positive effect on overall air quality in the local region.
The report specifically criticizes the use of “synthetic minor” permits for biomass facilities by states. This criticism is entirely without merit. The minor source permitting systems has been in place for decades, and there is no special treatment for biomass facilities. A synthetic minor permit may be obtained where a facility with a potential to emit above the “major source” threshold does not intend to actually do so. For example, an operator may design a facility to meet future demand which could, were the future demand to occur, result in major emissions. In the meantime, emissions will remain below the major source threshold. In such a case, the operator can request an enforceable permit limit that will require the facility to remain below the major source threshold. In the event the operator wishes to exceed the major source threshold in the future, it would trigger the major source permitting requirements at that time. Far from being a “loophole,” this is a common, lawful, and widespread process designed to promote efficiency and economy in the regulatory process. It is equally available to all source types and is widely approved by EPA in state implementation plans across the country.
Burning Biomass Is Not the Same as Burning Trash
The paper would also have you believe that biomass plants are just closet trash burners, when the two fall into distinctly different classes. I have operated both, and believe me, the approach and regulatory requirements are miles apart. Trash is a totally mixed product that is burned unsegregated and may contain most anything. As a consequence, a dedicated trash burning plant will have to hang virtually every sophisticated type of pollution control equipment known to man in order to be permitted. The reward for that is they will be able to charge the “tipping fee” that figures so prominently in the document. By contrast, a biomass plant can have a reasonable set of pollution controls that assures clear stack operation and NOx and CO limits that will not threaten the well being of the community. Both plants must conduct extensive air quality modeling to make sure that they meet the ambient standards established by EPA (and perhaps lowered by state regulators) and thus the plant is protective of public health. The biomass plant is much cheaper to build, but will be far more restricted on what it can burn. The wood must all be clean, and can only be from sources designated in the air quality permit. There may be testing requirements of the fuel in the pile, or even upstream at the fuel supplier, if that is what the State deems necessary. Because of these restrictions, the plant will NOT be able to charge a tipping fee and, at best, will have to pay just the transportation of the fuel. Typically, entrepreneurs will have established clean wood businesses just outside the gate of the landfill, where they will accept clean wood for free, allowing deliverers to avoid paying the landfill tipping fee on that portion of their waste stream. The system works very well and the fuel that arrives at the plant will have been sorted, cleaned, processed and run under a bank of magnets to assure it meets the plant’s permit requirements. Any failure on the part of the fuel supplier means being cut off and the end of the supplier’s business.
Getting the Data Wrong
In one of many examples of the report getting the data wrong, one of the plants cited in the paper, Nippon Paper in Port Angeles, WA, is one that I know well and have worked on for years. In its characterization, the author says generally good things about the permit, but concludes that it is very likely that the plant will be a large emitter of HAPs due to the nature of its fuel supply. The paper says it has a very low PM emission limit (0.001 lb/MMBTU) ‑ so low that it will only emit 2 tpy of particulates from a 20 megawatt plant. However, all of the above is wrong. The plant’s PM emission limit is actually 0.02 lb/MMBTU, which still keeps it comfortably within other limits discussed. The plant will burn primarily sawmill byproducts, logging slash, clean urban wood and the wood fines from their wastewater cleanup operation (referred to by the author as sludge), not exactly a recipe for large HAP emissions as claimed by the author. The logging slash will be from private lands on the Olympic Peninsula and have all been previously legally open burned in the airshed of Olympic National Park. At the plant itself, the new boiler will replace a collection of older boilers dating back to the 1950s that currently burn wood and No.6 oil. The new boiler will actually lower emissions versus the current boilers by 68 percent for PM, 98 percent for acid gases, 12 percent for CO and 52 percent for sulfur dioxide, while increasing NOx by 20 percent. There will be no “lag” in the plant paying back its CO2 debt, as it will burn material that is currently waste and would be emitting CO2, or worse in the case of CH4 (methane), by open burning or decomposing in landfills. All of the information in this paragraph is readily available and could have been used to give credit to the project and balance the tone of the diatribe.
In assessing the report overall, I have to say that looking at only the plant stack and concluding that it is bad is akin to looking at the needle on a smallpox shot and concluding that sharp thing will hurt the patient. Biomass needs to be looked at in totality, what it does for forestry, agriculture and waste management, not just what comes out the stack.
There is a reason biomass has not been singled out for scrutiny by the EPA, and that is because the nature of the fuel is such that it is relatively benign. Virtually every scientific organization in the world has concluded that biomass emissions are carbon neutral so long as the fuel source is sustainable. It is foolish to state that biomass emissions “can literally kill you”, when there is not one instance of that being true, especially given the fact that there is a current fleet of nearly 200 biomass plants, many of which have been in existence for 50 years or so.
The biggest supporters of biomass power are the communities and regulatory agencies that have the most experience with it. There is a good reason that the DTE coal to biomass conversion in Stockton, CA, could be successfully permitted in one of the worst air quality situations in America. That is because the San Joaquin Air Quality Management District knows that another biomass plant in the district, despite its stack emissions, will be a net benefit in air quality as it eliminates more of the open burning from agriculture that is a source of much of their problem. If a regulatory agency were to cut biomass any slack in the regulatory process it would be because he wants it to be completed as a part of his overall air quality strategy to keep the ambient contaminant levels as low as possible in his jurisdiction.