Presentation to Board of ForestryNovember 29, 2011

Alice EdwardsDivision of Air Quality

Alaska Department of Environmental ConservationEmail: alice.edwards@alaska.gov

OverviewAir Quality Health StandardsAlaska RegulationsFederal RegulationsFuture ADEC Actions

National Ambient Air Quality Standards

Ambient health standard of greatest concern from wood/biomass burning is particulate matter (PM)

Fine particulate matter standard35 ug/m3 for 24-hour period15 ug/m3 annually

Particulate Matter – What Is It?A complex mixture of extremely small particles and liquid droplets

Particulate Matter Health Impacts

Particulate matter can penetrate to lower regions of the lung

Deposited particles may accumulate, react, be cleared, or absorbed

• Scientific studies link breathing particle pollution to significant health problems:• Aggravated asthma• Increases in respiratory symptoms like coughing

and difficult or painful breathing• Chronic bronchitis• Decreased lung function• Premature death in people with heart and lung

disease

Control Strategy

• Purpose is to protect public health

• Emission standards– Apply to operation of units regardless of

whether a permit is required

• Permit requirements– Regulate construction, installation, and

operation of larger units

Definitions – 18 AAC 50.990Wood-Fired Heating Devices

Designed for wood combustion such that useable heat is derived for the interior of a building

Includes wood stoves, fireplaces, cooking stoves, or combination fuel furnaces or boilers that burn wood

Does not include parts of industrial processes that incidentally provide useable heat

Fuel burning EquipmentExcludes wood-fired heating devices, but includes wood-

fired industrial processesRegulated under 18 AAC 50.055

IncineratorDevice used for thermal oxidation of garbage or other

wastes

Emission Standards• Wood fired heating device visible emission

standards– 18 AAC 50.075

– No black smoke– Opacity <50% if air quality advisory issued– Operation prohibited if air quality episode declared under 18

AAC 50.245

Air Pollution Prohibited– 18 AAC 50.110

– No person may permit any emission which is injurious to human health or welfare, animal or plant life, or property, or which would unreasonably interfere with the enjoyment of life or property.

Emission StandardsOther considerations:

Use as an incinerator is regulated under incinerator rules

Burning treated or painted waste wood may be considered incineration under state and federal regulations

Burning clean wood, brush, or untreated lumber is generally not considered incineration

DEC Minor Permitting - 18 AAC 50.502(c)

Pollutant Limit Typical sizePM10 15 tons/yr 8.6 MMBtu/hrNOX 40 tons/yr 18.6 MMBtu/hrSO2 40 tons/yr 365 MMBtu/hrLead (Pb) 0.6 tons/yr 2870 MMBtu/hrCO 100 tons/yr 38 MMBtu/hr

Major permitting thresholds are much higher and generally not an issue unless the device is part of a larger source of air pollution

Minor permit requirements

Must have permit issued before beginning construction

Application includes computer modeling demonstration showing source will comply with Air Quality Standards

Must pay fees – set up billing account

Contact Construction Permit SupervisorZeena Siddeek (907) 465 - 5303

Major Permit Requirements

Facility emitting 250 TPY or more of an air pollutant

100,000 TPY or more CO2 equivalent for greenhouse gasesOn July 1, 2011 EPA deferred, for a period of

three years, the application of major source permitting requirements to CO2 from bio-energy sources Published July 20, 2011 in Federal Register:

http://www.gpo.gov/fdsys/pkg/FR-2011-07-20/pdf/2011-17256.pdf

New Source Performance Standards

• 40 CFR 60• Subpart Dc Small Industrial-Commercial-

Institutional Steam Generating Units– 10 MMBtu/hr < Unit < 100 MMBtu/hr

• Subpart AAA – New Residential Wood Heaters– Applies to residential woodstoves– does not include boilers and furnaces– EPA is working on an update to this NSPS that

will include outdoor wood hydronic heaters

NSPS -40 CFR Part 60 Subpart Dc Boiler Standards

SO2: No limit for wood-fired devices

PM10: If unit heat input > 30 MMBtu/hr, 0.10 lb/MMBtu heat input if wood capacity is >30%0.30 lb/MMBtu heat input if wood capacity is <30% and

is subject to an enforceable limit on capacity factors to <30%

No opacity incidents >20% for more than 6 minutes in any hour

NESHAPIndustrial/Commercial/Institutional Boilers and Process Heaters

• Final rule – published March 21, 2011, – effective May 20, 2011– Must comply by February 2014

• Rules for Major sources and Area Sources– Major – mostly at industrial facilities– Area source – mostly commercial/institutional• e.g.: Medical centers, municipal buildings

NESHAPIndustrial/Commercial/Institutional Boilers and Process Heaters

Area Source ruleExisting small biomass boilers must conduct

tune-ups every 2 yearsNew biomass boilers > 10 MMBtu/hr heat

input must comply with particulate matter emission limits

All facilities with large boilers must conduct energy assessment

http://www.epa.gov/airquality/combustion.html

NESHAPIndustrial/Commercial/Institutional Boilers and Process Heaters

EPA announced that it will be reconsidering several aspects of this rule and stayed the effective date for the major source boiler and solid waste incinerator standards until reconsideration process is complete or legal challenges are resolved

Proposed revised rule is expected to be released on November 30, 2011. Final rule planned for release in April 2012.

Future ADEC Actions• Evaluating whether minor air permit thresholds are

still protective given new federal air quality standards

• Considering regulation of residential outdoor wood heaters– Concern about locating in dense residential areas– Typical design can lead to poor combustion and poor

dispersion of smoke– Smoke can, and has, significantly impacted neighbors

in a number of instances: nuisance and health concerns– Newer designs meeting EPA voluntary certification are

somewhat cleaner

• Considering whether necessary to regulate larger biomass combustion devices as well