The following guest
blog is from Bill Carlson, 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.
Anti-Biomass Group Paints Misleading Portrait of Beneficial Energy Source
An anti-biomass energy group issued a screed this week that is,
at most, a compilation 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 from the Partnership for Policy Integrity (PPI),
an outgrowth of the Environmental Working Group, 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 biomass-derived electricity under the Clean Air Act, it’s
important to address and correct the impressions left by erroneous, if not
baseless, assertions.
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.
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.
Misrepresentation of
Hazardous Air Pollutants (HAPs) from Biomass
Perhaps one third of the total PPI document is devoted to
Hazardous Air Pollutants (HAP) 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
either. The vast majority of biomass fuel in the U.S. remains wood waste 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
this does not happen.
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 of emission of any single pollutant, while
the same trigger for biomass power occurs at 250 tons per year (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 100tpy such as
oil refineries, chemical plants, steel mills and fossil fuel power plants. All
of the rest of the world use the 250 tpy trigger, and that includes biomass.
The list was simply a recognition by EPA 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,
they can pull that authority, and have. 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 ag 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, something EPA would be
unable to do.
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 a "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 status of the community. Both plants will
have done 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 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 permits at the plant. Any failure on the part of the fuel supplier
means being cut off and the end of their 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 ‑ so low
that it will only emit 2tpy of particulates from a 20MW plant. In actuality,
all of the above is wrong. The plant’s PM emission limit is actually 0.02
lb/MMBTU, placing it comfortably among other limits discussed, and is projected
to emit 37tpy of particulates. 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). 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
was readily available to the author and could have been used to balance the
tone of the diatribe.
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 close to
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.
Despite having no scientific credentials, it is amazing that
the authors of the PPI document think they know more than every policymaker,
regulator and scientist that has ever looked critically at biomass.
Bill Carlson 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.
Bill Carlson 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.
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