Biomass power plant emissions, if not properly controlled, can cause health problems and stir up opposition groups that can impede a plant's development.
The Russell Biomass Power Plant will be the tightest permitted biomass plant in New England history, said Russell Biomass developer Peter Bos. The plant requires about 36 permits, but construction cannot commence during an active appeal process, which can take up to four years, Bos says. The company currently is on track to get all of its permits in place by March 2010, polish the design over the summer and begin construction by September 2010 with the goal of operating in the spring of 2013. But not if local grassroots opposition group Concerned Citizens of Russell can do something about it, which Bos fully expects.
The group opposes the plant for several reasons outlined on its Web site, www.concernedcitizensofrussell.org, including trucking routes and frequency of travel, river impacts, forest sustainability and, of course, plant emissions. The area already has high levels of air pollution because of its location and geography, according to CCR spokeswoman Jana Chicoine. "This site is ringed by mountains," she says. "You've got a 300-foot smokestack next to a 1,100-foot mountain."
Typical major emissions from biomass power plants include carbon monoxide and carbon dioxide, sulfur dioxide, nitrous oxide and lead, along with particulate matter, among others. All these emissions, in high concentrations, have adverse effects on the environment, but also pose health risks. Carbon monoxide can cause issues such as asthma, headaches, unconsciousness and death; particulates can cause respiratory illnesses; sulfur dioxide can induce breathing difficulty or worsen asthmatic problems in children; and nitrous oxide can affect the central nervous system, along with cardiovascular and reproductive systems, among other side effects.
But the U.S. EPA regulates those harmful emissions and issues penalties, commonly in the form of fines, to facilities not in compliance with National Ambient Air Quality Standards, as per the Clean Air Act, passed in 1970. The law's administrators can require owners or operators of an emissions source, or control or process equipment, to continuously keep emissions records and use monitoring equipment. Administrators will have access to those records and the premises, according to the EPA. The administrator also can require an operator to enhance monitoring and control techniques, or submit compliance certifications, which include compliance status, method of determining that status, and whether it is continuous or intermittent, among other criteria. The EPA may also inspect facilities regularly to determine compliance in accidental release prevention or mitigation programs.
Section 112 of the CAA was amended in 1990 to require the EPA to issue emission standards and requirements for 189 cancer-causing air pollutants. The amendment resulted in more than 100 new rules for industrial and commercial sources of air pollution, according to the EPA. The EPA mostly conducted outreach and compliance assistance in the first few years the new rules were in place, but now has a standard enforcement process of identifying priority violators and taking enforcement actions, including issuing penalties. Since 1997, the EPA has issued enforcement actions for Section 112 violations in more than 600 cases, some involving penalties and environmental projects of more than $1 million each, according to the agency. Penalties for a violation of stationary emissions source requirements of the CAA can be up to $32,500 per violation (per day or per engine), according to the EPA. The federal EPA administrators, along with any state government, also have the power to prevent construction of a major emitting facility that does not conform to the requirements.
After an inspection of a biomass power plant site in Lufkin, Texas, in February 2009, the EPA ordered a stop work order on the 50 MW project because it found construction activities had been completed without required air permits, according to the EPA. The developer, Aspen Power LLC, had been previously granted a Prevention of Significant Deterioration permit, but it was rescinded by the Texas Commission on Environmental Quality because it was challenged by concerned citizens, according to Dave Bary, spokesman for the Region 6 EPA office. "Aspen Power decided to proceed with construction at its own risk in the absence of a permit from the state of Texas," Bary says. The PSD permit is required because Lufkin is near the Houston/Galveston area, which already is not in attainment of federal ozone standards, Bary explains. "In order to proceed with construction, it was necessary to demonstrate that their emissions would not contribute to an existing air quality problem in an area nearby," he says. It is unusual for the EPA to issue a stop work order because of permitting issues, he adds.
Aspen was denied a motion to appeal in April, but construction has since commenced after an Oct. 26 re-issuance of the permit by the state, with the addition of more control technologies, according to the EPA. A message left with Aspen Power was not returned. The $130 million plant will burn clean wood debris generated by timber harvesting and municipal clean-up activities and is expected to begin operations in late 2010. For more information on the CAA, visit www.epa.gov/air/caa/.
In addition, the EPA's Mandatory Reporting of Greenhouse Gases Rule, announced in September, will require suppliers, manufacturers and facilities emitting more than 25,000 metric tons (27,550 tons) of carbon dioxide equivalent annually to report and continuously monitor their emissions. The rule goes into effect Jan. 1.
Concentration, Not Weight
Concerned Citizens of Russell lists expected emissions amounts of harmful compounds from the Russell plant on its Web site, but Bos says it's not the number of tons or pounds emitted, but the concentrations that indicate the health measure. "The numbers mean nothing when you're thinking about health impacts," he says. "You must know what the resulting concentrations in the air are of that pollutant or any pollutant." For example, the plant will emit 39 tons of particulate matter 2.5 microns (PM2.5) or smaller per year, but that goes up the 300-foot smokestack and into the air, where it disperses, resulting in a concentration of 0.2 micrograms per cubic meter, he says. The standard set by the EPA for PM2.5 concentration is 35 micrograms per cubic meter, he adds. In the 1,600-person village of Russell, particulates emitted from wood stoves in homes during the winter will result in an overall concentration of 5 to 10 micrograms per cubic meter, he explains, adding that emissions from each stove results in 40 micrograms per cubic meter right around the home emitting them. "The reason our concentrations are so small is we have a huge filter that captures over 99 percent of all particulates generated," he says. "Whereas a wood stove in a house only has maybe a 20-foot stack that goes up to the roof." The company has offered to replace 20 wood stoves in the community with clean-burning pellet stoves, effectively reducing the concentration of wintertime particulates and carbon monoxide. "I think this is the first time in history that a developer has created a program that will reduce pollutants of concern if the plant is built," he says.
Chicoine disagrees with Bos's concentration measurements for the plant and has consulted a meteorologist who says conditions around the village, including surrounding mountains, make it harder to disperse air pollutants. But besides the smokestack emissions, Chicoine worries about the diesel exhaust from the trucks transporting wood on the route right next to her family's home. "You've got what I like to call an ozone factory," she insists. "This is a health threat."
Russell Biomass has acquired a number of the required permits and has a draft permit to discharge into the river under the National Pollutant Discharge Elimination System from the EPA. CCR has appealed three permits to date and two or three more appeals are expected, Bos says, adding that all appeal rulings thus far have gone against the opponents and sustained the project.
A broad, statewide opposition to biomass has developed in Massachusetts, initiating a petition for a carbon dioxide emissions law that would prohibit biomass plants emitting more than 250 pounds per megawatt hour from operating. That's far lower than any biomass plant emits, along with any fossil fuel power plant, Bos says.
Biomass power should not be included as a renewable energy resource because it is not carbon neutral, Chicoine says, adding that a number of other organizations in the state have formed around opposition of biomass power plants. "Opposition to biomass power plants in Massachusetts is uniquely strong, organized, gifted, qualified, focused and accomplished, I think, in all the world," she says, adding that the idea of biomass being carbon neutral is a "fairy tale." The state has one operational biomass plant in Westminster that generates 17 MW and four more have been proposed, including Russell's. A number of coal plants are also considering switching to biomass. Additionally, Massachusetts has a renewable portfolio standard (RPS) of 15 percent by 2020, with smaller goals each year.
At the beginning of December, the Massachusetts Department of Energy Resources suspended all consideration of new biomass projects for participation in the state RPS, as it awaits the results of a third-party study to determine the sustainability and carbon neutrality of biomass power generation. The study is fueled in large part by opposition to new biomass facilities proposed in the state and will focus on forest management as it relates to biomass collection, along with the life-cycle analysis of the carbon inputs to biomass growth, harvesting, transportation and combustion. The study, led by the Manomet Center for Conservation Sciences, should be completed by June, with any new rulings released in about one year.
The study and suspension can delay development, but Bos says it will not affect his plant, as he already expects a delay because of appeals. It will not cause any further delays, he says, adding that construction should start in 2011. The study's chief function will be to help the DOER determine how many projects it can approve for renewable energy credits, based on the supply of feedstock, Bos says. He does not expect a ruling that allows no biomass power generation in the state at all. "The question is how much biomass will be allowed," he explains, "not if no biomass will be allowed. The answer to how much wood is available is not zero." Qualification for state RPS generates renewable energy credits, a key portion of a biomass power plant's revenue. "Without them, you won't likely have biomass power," Bos says. The study also will help identify specific sources of the wood supply that will be allowed for biomass power generation, limiting total megawatts to what's available. Different ways of supplying biomass and different sources have an effect on the GHG emissions, he adds.
"In all states, you find that environmental standards are tightening, but Massachusetts is clearly the tightest permitting state in New England," Bos says. That might not be the only reason fewer plants exist in the state than elsewhere, he adds, such as in New Hampshire, which has supported 200 MW of biomass power from woody biomass for years without clear cutting. More forest management activities take place in northern New England than southern, he says, providing more feedstock. If he had it to do over again, Bos says he would propose a site in New Hampshire over the former paper company site he chose in Massachusetts, one of two paper mills shut down in the village of Russell about 15 years ago. "It was a good paper company site and it's a very good power plant site," he says.
A support group for the Russell plant, RussellFirst, also has emerged in the past six months and has about 100 members, who are concerned about losing the tax revenues the plant would bring in ($120 million over 50 years) and the 22 permanent jobs, Bos says. Even so, Chicoine calls RussellFirst an "astro turf group" and says it is indistinguishable from Russell Biomass. "Grassroots is genuine and astro turf is not," she says, adding that RussellFirst is more concerned with tax dollars than the other issues, such as health and sustainability. "RussellFirst just doesn't show an interest in the information," she says.
But permitting standards are rigid, Bos argues, and no health or environmental risks are ignored. "It defies rational thinking that there are that many environmental impacts that have been overlooked by and allowed by the various permitting agencies," he emphasizes. "Unfortunately, the appeal stage is a typical final stage of project development in the northeast." BIO
Lisa Gibson is a Biomass Magazine associate editor. Reach her at firstname.lastname@example.org or (701) 738-4952.