¦EMISSIONS frame for when it will be issued, because very little construction is typically permitted before an air permit is issued. In my experience, air permit applications can generally take from three weeks to three months to prepare, depending on the size and complexity of the proposed project. Following application submittal to a state agency, it can typically take between two and 18 months for the agency to issue the permit, again depending on the project. Given these timeframes, it may be necessary to start work on an application up to two years before commencing construction for a complex project. Emissions are typically vented to ambient air with a vertical stack that extends some height above the building it is associated with. Some state regulatory agencies have rule-of-thumb formulas for establishing stack heights. PHOTO: ALL4 LLC
If I Knew Then What I Know Now: Air Emissions Permitting Considerations for Biomass Boilers Addressing major questions early on the biomass boiler development process can help save valuable time and money. BY JOHN HINKLEY
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If I knew then what I know now, then I would have done things much differently.” One of the most standout observations in my past two decades of assisting clients is that project developers who ask the right questions early in the project planning process enjoy the process the most, and are the ones who are happiest with the outcomes. In this article, I will address questions that commonly occur when an air emissions permit is required for a new biomass-fired boiler.
When do I need an air emissions permit? An air permit is intended to protect human health and the environment and is a
legally binding document that includes enforceable limits on air pollutant emissions (e.g., particulate matter (PM) nitrogen oxides, sulfur dioxide and carbon monoxide) that a facility can release to ambient air. Air permits specify how facilities must design and operate pollution control equipment, how emissions must be vented (i.e., how exhaust stacks should be designed), air pollutant limits that must be met, as well as how to monitor, record keep and report aspects of their operations related to their emissions. Assuming an air emissions permit is required, it is important to anticipate the time-
Am I subject to federal requirements? Permits are issued by state agencies, and in some cases, not all federal requirements are included in the air permit. For example, not all state agencies enforce the federal rule that many refer to as the “Area Source Rule” (40 CFR Part 63, Subpart JJJJJJ—National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers) and therefore do not include that rule’s requirements in the air permits they issue. Further, there are some cases in which a boiler may not trigger air permitting in a particular state, but the rule still applies, so its requirements still have to be met.
Are there new state or federal regulations on the horizon? Regulations im-
pact the design, operation and therefore cost of facilities. Consequently, it is imperative to perform due diligence to determine if there are new regulations that could be promulgated at a time that could impact your project. For example, the New York State Department of Environmental Conservation recently changed Title 6, Part 227-1 of the New York Codes, Rules and Regulations (6 NYCRR 227-1) for stationary combustion installations, which significantly reduced the allowable PM emissions limit for biomass boilers. This change means that many small biomass boilers, or boilers with a heat input less than 10 million British thermal units per hour (MMBtu/hr), will likely have to be permitted with an advanced form of emissions control such as a high-efficiency multicyclone, electrostatic precipitator (ESP) or fabric filter baghouse in lieu of a cyclone or conventional multicyclone. This significantly increases capital and operating costs of a constructing and operating a biomass boiler.
CONTRIBUTION: The claims and statements made in this article belong exclusively to the author(s) and do not necessarily reflect the views of Biomass Magazine or its advertisers. All questions pertaining to this article should be directed to the author(s).
28 BIOMASS MAGAZINE | ISSUE 3, 2021
