By Kenneth Norris, Contributing Editor, Pulp & Paper International
NEW YORK,
April 8, 2011
(RISI) -
Since the February 23, 2011 release of the U.S. Environmental Protection Agency's final rules governing emissions from biomass boilers, reactions have been muted so far. In contrast to the heated responses from all sides to the previous proposal released in April 2010, the latest ruling on Boiler Maximum Achievable Control Technology (MACT) has generated far less conversation.
The final Boiler MACT rules from the EPA reduce the emissions and monitoring requirements for biomass boilers used in energy production. The concern, say industry analysts, is the new rules still impose a economical strain on the industry and, as acknowledged by the EPA, could be reconsidered again, leaving the industry in a state of flux.
Biomass boiler regulations
Biomass boilers used in the pulp and paper industry typically serve as a source of renewable energy for production facilities. Considered as an energy sources by the EPA when using cellulosic fuel sources, the Boiler MACT rules split the regulations of biomass boilers between new and existing boilers at major source facilities and area source facilities. Under the final rules, published by the EPA on March 23, 2011:
- Existing biomass boilers at area source facilities, such universities and hospitals, will not be required to meet emissions limits. However, existing boilers will be required to meet a work practice standard or undergo a boiler tune-up every two years.
- New boilers with a heat input of 10 million Btu/hour or less also will not be required to meet emissions limits, but must undergo a boiler tune-up every two years.
- New boilers with a heat input more than 10 million Btu/hour will be required to meet emissions limits for particulate matter.
- New and existing biomass boilers with a heat input of more than 10 million Btu/hour at major source facilities, such as industrial facilities, also will be required to monitor oxygen consumption for combustion quality and conduct a one-time energy assessment to identify cost-effective energy conservation measures.
As part of the EPA's filing of emissions standards for hazardous air pollutants from major sources, pulp and paper mills are given as an example of a major source facility and their biomass boilers could fall under that category.
According to the EPA, the final Boiler MACT rules will reduce the cost of compliance by 50% as compared to the earlier proposal. And the new rules include some flexibility for biomass boilers, according to Gina McCarthy, assistant administrator for the EPA's Office of Air and Radiation. The rules have combined biomass and coal boilers into a single solid-fuel category and eliminated the requirement for biomass boilers to install scrubbers for pollutants, such as mercury and hydrogen chloride, which are not heavily emitted from biomass boilers.
The primary incentive of the new rules, say analysts, is to move industries away from coal-burning boilers and toward boilers using biomass and natural gas. This can be seen in the removal of earlier requirements for biomass boilers to monitor pollutants that are commonly emitted from coal-burning boilers.
However, the cost of retrofitting existing boilers, where necessary, is a direct impact on the industry. In addition, all facilities installing new boilers must comply with these new requirements within 60 days. Another concern is the EPA's statement that they may reconsider these Boiler MACT rules at a future date, based on additional comments and data from affected parties.
Room for improvement
The EPA stated after the February ruling that it had received over 4,800 public comments on the proposed rules issued in April 2010. Industry groups from the American Wood Council and the American Forest & Paper Association (AF&PA) to the U.S. Chamber of Commerce and the Wisconsin Congressional delegation all sent publicly addressed comments to the EPA. Since the final Boiler MACT rules were released in February, some of these associations have said the new rules are far better than the original proposal, but there is room for improvement.
In a statement released on the day of the EPA's ruling, AF&PA President and CEO Donna Harman said the new rules were an improvement but "fall short of what is ultimately needed to support jobs and the economy." A major concern is the nearly immediate financial impact the new rules would have on the industry.
"Forcing billions more in investments to retrofit already environmentally good-performing boilers fails to allow targeting of scarce capital toward creating jobs and growing the economy in local communities supported by those facilities," said Harman.
In an independent study commissioned by AF&PA, it was found that the proposed rules from April 2010, taken incrementally to other EPA air regulations, would likely cause 30 mill closures and result in the loss of nearly 17,000 jobs in the industry. This loss would amount to a 14% reduction in the primary pulp and paper sector in the US industry.
With the new final ruling, it unclear now whether mills and jobs are still at stake. The EPA estimates the cost to American industry to implement the new rules will be approximately $1.8 billion. This is exactly half of the estimated $3.6 billion cost to comply with the original proposal, states the EPA.
The next step for the Boiler MACT rules could be new modifications on certain portions of the ruling. The EPA has announced that it intends to begin the formal process of reconsideration, with additional details to be released in the near future.
AF&PA is one group that has already called for the EPA to open the reconsideration process as soon as possible. "An affordable regulation that protects health and the environment is still possible," said Harman.
Ken Norris is a US based contributing editor to PPI magazine and the RISI community website and can be contacted at: knorris@quintstrategies.com
