Impact of Regulations on Wood Pellets Manufacturing Industry Atlanta, GA ♦ October 24, 2013...
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Transcript of Impact of Regulations on Wood Pellets Manufacturing Industry Atlanta, GA ♦ October 24, 2013...
Impact of Regulations on Wood Pellets Manufacturing
Industry
Atlanta, GA ♦ October 24, 2013
Anupama Krishnan
Outline
˃ Why Wood Pellets?˃ How are Wood Pellets Made?˃ Impact of International Regulations on
Growth of Industry in the U.S.˃ Regulatory Applicability˃ Results of Testing and Impact on PSD
Applicability ˃ Case Studies˃ Impact of Biomass Deferral Rule Vacatur for
Industry
What is a Wood Pellet?
> Raw wood compacted into a homogeneous product Processed residues (i.e., chips,
bark, sawdust by-products) Unprocessed residues (i.e.,
tree tops, branches, non- saleable wood, forest thinning)
> Uniform-size cylindrical shapes
> Variety of fuel applications Residential heating appliances Large scale boilers in
commercial operations
Raw Wood vs. Wood Pellets
Parameter Raw Wood Wood Pellets
Energy Density Low High (similar to coal)
Moisture Content 50% <10%
Bulk Density Low High
Why Wood Pellets?
˃ Every ton of pellets used vs. oil reduces CO2 emissions by about 1.5 tons
˃ Wood pellets have a fossil energy ratio (net energy output/fossil energy used) of 12:1
˃ Good for the environment Improves air quality Better waste management Sustainable sources
How are Pellets Manufactured?
Material Processing
Drying
Pelletizing
Cooling
Storage
Wood Pellet Carbon Cycle
Source: Enviva (2/12)
International Interest in Wood Pellets˃ Europe has incentives for using
renewable fuels Rising fossil fuel prices Tax on fossil fuels Green electricity certification
system Big push to reduce CO2 emissions Large-scale boiler applications and
residential furnaces with secure supply of wood pellets
International Interest in Wood Pellets
˃ Islands are looking into sustainable sources
˃ Low conversion costs for utilities Coal to wood pellets
˃ Predictable and reliable˃ Sustainable raw materials
Why Manufacture in the USA?>Largest privately owned and
sustainably managed forest resource in the world
>Can easily export wood pellets both east to Europe and west to Asia
>The primary product grown by Southeast U.S. timberland owners is softwood saw timber Southern yellow pine
Southern Yellow Pine
> Commonly found in Southeast U.S. Grows well in acidic soils More than 32 million
acres of pine are grown in the southeastern U.S. (Forest Nutrition Cooperative)
> Has a lower density Easier to chip and mill
into pellets than hardwood
> Grows relatively fast ~20 years
Wood Pellet Mills – North America
Source: Klean Industries
Wood Pellet Trade Flow
Source: USIPA Conference (10/12)
Future Wood Pellet Production
Source: Global Wood Pellet Industry Market and Trade Study (12/11)
Sound solutions delivered uncommonly well
Federal Regulations Applicable to the Wood Pellets Industry
˃ CAM – potentially applicable for control devices˃ NSPS Subpart Db (Steam Generating Units) or
NSPS Subpart Dc (Small Steam Generating Units) potentially applicable if heat source uses steam to heat dryer or if it creates steam for other process operations
˃ NESHAP Subpart DDDD (PCWP MACT) – not applicable since
adhesives not used for pellet formation Boiler MACT or Boiler GACT – potentially applicable to
heat source used to generate steam˃ Engine NSPS/NESHAP for generators or
emergency fire pumps
Sound solutions delivered uncommonly well
Impact of Post-Dryer VOCs on PSD Applicability
˃ Initial facility designs did not account for any post-dryer VOC emissions
˃ Later testing conducted at several facilities indicated very high amounts of VOC emissions from the post-drying process – hammermills, pelletizing and storage
˃ Facilities may require PSD permitting with BACT, or consider expensive VOC controls for PSD avoidance
Sound solutions delivered uncommonly well
Possible Compliance Testing Requirements˃ Heat Energy Source/Dryer Stack
VOC CO NOX
PM/Opacity Formaldehyde Methanol Acetaldehyde
˃ Post-Dryer Sources Stacks VOC
˃ Initial testing requirements likely; annual or biannual testing requirements dependent on testing results
Sound solutions delivered uncommonly well
Use of Testing Data˃ GA EPD recommended wood pellets industry
VOC emission factors based on engineering testing results for Georgia Biomass facility
˃ Testing results can vary greatly depending on process, type of wood, control methods, etc.
˃ If test data is unavailable for a site, EPD will accept test data from another site with a similar process; however, testing will be required to confirm emissions values If actual test results are much higher than PTE in
application (e.g., above PSD major source thresholds), the site faces potential compliance actions
Sound solutions delivered uncommonly well
Impact of Biomass Deferral Rule Vacatur˃ Vacatur of rule may have significant impacts
on the future of this industry in the U.S.˃ GHG emissions from wood pellets and other
biogenic sources can no longer be excluded in PSD applicability determinations
˃ Facilities may easily trigger PSD for GHGs, thereby be subject to cumbersome PSD permitting or avoidance, BACT evaluations and modeling assessments
˃ If U.S. becomes a less profitable market for wood pellets, Europe may well turn to emerging markets like Brazil to fulfill demand
Sound solutions delivered uncommonly well
Pellet Facility #1 – Regulations Impact˃ Greenfield site˃ Originally permitted as Title V major, PSD
minor source˃ Internal testing revealed significant VOC
emissions from post-dryer sources not previously accounted for
˃ Received Consent Order from EPD and installed RCOs on post-dryer sources to remain PSD minor source
˃ Incurred significant financial penalties
Sound solutions delivered uncommonly well
Pellet Facility #2 – Regulations Impact
˃ Conversion of existing wood product facility into wood pellet production
˃ Originally permitted as Title V synthetic minor
˃ EPD permitted as Title V major source, to be confirmed with testing
˃ Operation limitations accepted to avoid PSD permitting No VOC emissions controls for dryer or post-
dryer operations
Sound solutions delivered uncommonly well
Pellet Facility #3 – Regulations Impact˃ Future conversion of an existing wood
pellet facility˃ Previously permitted as synthetic minor
with respect to Title V˃ Revise permitting based on new testing
data from sister facility site for post-dryer VOC emissions for PSD avoidance
˃ Revise permitting for vacatur of biomass deferral Natural gas usage instead of biomass for
combustion for PSD avoidance
Sound solutions delivered uncommonly well
Thank You!Questions?
Anupama [email protected] No.: (678)-441-9977