Proposed EPA Emissions Rules Threaten to Send Biomass Heating Industry Up in Smoke
The proposed rule differentiates between small boilers under 10 million Btu (MMBtu) and large boilers over 10 MMBtu. Existing large biomass boilers will not be tested for particulate matter (PM) emissions, but will be required to demonstrate carbon monoxide (CO) emissions of fewer than 160 parts per million (PPM) at 7 percent oxygen (O2). These facilities must also undergo a certified energy conservation assessment. Rightly, EPA believes that by reducing the heating load with conservation measures emissions will also be reduced. Existing small biomass boilers will not require testing due to technological limitations and relatively high costs for testing. However, a record of certified tune up must be submitted to the EPA every two years. This is a tough regimen, but it is doubtful that owners of these older, dirtier boilers will consider upgrading to more modern technology given the proposed requirements for new boilers.
Under the proposed rule, new biomass boilers must meet strict emissions limits for CO and PM, which are 100 PPM CO at 7 percent O2 and PM limits of 0.03 pounds per MMBtu. Initial compliance must be demonstrated by a stack test and retested annually. After demonstrating initial compliance, a monthly fuel record must also be maintained. If the fuel type is changed a new compliance test must be performed. For biomass boilers, initial compliance cannot be obtained without the performance of a facility energy assessment. These emissions levels are, at a minimum, two times more stringent than what is required to meet strict German and Austrian Eco-Label requirements. New oil boilers will also be challenged to meet similar strict criteria at 1 PPM CO at 7 percent O2 and PM limits of 0.03 pounds per MMBtu.
Advanced boiler designs control fuel combustion time, temperature and turbulence to achieve complete burn-out of the fuel which results in low HAP, such as tars and creosotes. The remaining ash PM from highly efficient wood combustion is mostly inorganic salts (calcium, magnesium) not heavy metals (mercury, cadmium) as are found in coal or heavy oil. As a result, wood particulate emissions are less toxic than other fossil fuel sources; however in the proposed rule, only PM weight is considered, not composition. Consequently, the surrogate tests-CO for HAP and PM for heavy metals-may not accurately reflect the differences between biomass boiler and fossil fuel boiler emissions.
Installing exhaust testing ports and instrumentation along with advanced emissions control technology such as filter bag houses or electrostatic precipitators (ESPs) and other equipment can add immensely to installations costs-approximately $100,000 for even the smallest sized boilers. Testing and control technology can easily cost more than the boiler itself. Annual testing alone is reported to cost $5,000 to $20,000 per boiler. For boilers under 3 MMBtu the required additional emissions controls and testing make new biomass boilers unaffordable.
Schools, churches and small businesses will be disproportionately affected by these regulations, which could turn a cost-effective, locally available, job-producing heat source into an economic nonstarter. Many of these applications may utilize more than one boiler, which could easily lead to a doubling, tripling or quadrupling of costs. There is a human component too. In small-scale installations finding trained personnel to manage the filter bag houses, ESPs and test reporting will be difficult. EPA's favored fuel, natural gas, is not available in many rural communities, where biomass has played a cost-effective heating role. In the Northeast, a region heavily dependent on fuel oil for heating, biomass has materially reduced that dependence, but now biomass heating could be bound and shackled by the proposed rule.
As one reads this article the initial 45-day comment period is complete. The EPA administrator is under court order to complete the final rule by Dec. 16. It will then be three years before compliance is mandatory. Seemingly, this is reasonable time to achieve compliance until one considers that the rule is retroactive to the day it is published in the federal register, scheduled for June 4. Potential biomass boiler customers are now putting purchasing decisions on hold while the EPA reaches a final decision. This is a major blow to an industry that is already challenged by a struggling economy. Coordinating our industry's response, BTEC aims to ensure that the final air quality regulation integrates clean air goals with encouragement for cost-effective, renewable biomass heat for customers throughout the U.S.
Scott Nichols is BTEC director and president of BioHeatUSA. To learn more about the BTEC, go to www.biomassthermal.org.