Emission Standards

EPA Proposed Area Source Boiler Regulations

UPDATE: On March 21, 2011, the U.S. Environmental Protection Agency (EPA) published its revised final rules for Area and Major Source Boilers, making them effective on May 20, 2011 (60 days after publication). Read more >>

BTEC has welcomed the revised rules and their increased use of biennial tune-ups in place of impractical emissions limits for many biomass boiler units. The association is also maintaining an open dialogue with the EPA during the publication of the rules and the reconsideration process. Read the press release >>.

Join BTEC today to learn more about the impact of the proposed rules or to get connected to BTEC's efforts in this area. Members also gain access to comprehensive factsheets on this and other regulatory and legislative issues.

Background

On June 4, 2010, the U.S. Environmental Protection Agency (EPA) released a Proposed Rule for Area Source Boilers that threatens to severely curtail the future growth of the biomass thermal industry and place prohibitively expensive emissions requirements on existing equipment. EPA is inviting public comments on the proposed rule until August 23, 2010.

A working group of BTEC members has spent a considerable amount of effort in developing BTEC's public comments to the EPA. Those comments are now finalized and can be downloaded here:

BTEC Comments to the EPA on the Proposed Rule for Area Source Boilers

Under the previous proposals, new and existing biomass boilers at area source facilities would be required to meet new emission limits for carbon monoxide (CO) and particulate matter (PM):

Unachievable and Unrealistic Standards

EPA’s proposed emissions limits rely on a data set that is not representative of real-world technologies.  Biomass boilers that achieve EPA’s particulate matter (PM) standard are not the same boilers that achieve its carbon monoxide (CO) standard.  Using EPA’s own data set, it is obvious that there is no biomass boiler tested that can achieve both the proposed levels for PM and CO.  Requiring new biomass boilers to meet standards that no single biomass boiler has ever achieved in testing is unreasonable. 

High Compliance Costs and Economic Consequences

Under EPA’s new annual emissions testing requirement, testing expenses would add an estimated $8,000- $15,000 per boiler system. That added cost likely surpasses the biomass fuel bill for smaller systems and is a major budget consideration for larger biomass boiler systems.  Also, proposed compliance technology requirements could cost more than the biomass systems themselves.  Such costs negate the monetary and environmental advantages of using renewable, local biomass fuel, thus encouraging continued fossil fuel use and discouraging investment.

EPA’s unachievable emissions limits will reduce biomass boiler use and fuel demand, which will incur widespread economic losses in industries that rely upon this low cost fuel, such as the wood products manufacturing, forestry, and agriculture sectors.

BTEC Recommendations

BTEC recommends initial and interim data-driven limits and practices that are representative of real-world technologies:

• Initial minimum performance standards of (CO) – 1,164ppm (@ 7% O2) and (PM) - 0.23 lbs/mmBtu for all boilers, with reductions thereafter based on data collected during the first two years of the Rule’s implementation;
• Initial third party boiler certification test with required annual tune-ups without ongoing costly stack testing. Once a boiler (or range of boilers) is tested, that boiler would be approved for installation until a change was made in the boiler design.

More Info

BTEC Comments to the EPA on the Proposed Rule for Area Source Boilers

www.epa.gov/airquality/combustion/actions.html

How You Can Get Involved

Join BTEC today to learn more about the impact of the proposed rules or to get connected to BTEC's efforts in this area.