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Progress Energy is proposing to add equipment to allow burning of biomass in the (normally) coal-fired boilers. The biomass is defined as: evaluated engineered laminated veneer lumber (LVL) and structural I-Joist manufactured at the Louisiana Pacific plant and/or unadulterated wood wastes from forest derived lumber mill wastes and pallets. The biomass I-beams contain a resin and hardener slurry which are mixed together to obtain a polymer to manufacture the I-beams. Progress originally wanted to burn up to 10% by heat input as biomass, with coal being the remainder of the heat input. The amount of heat input due to biomass was later changed to be no more than 5%. In the original application, from the MSDSs, Progress calculated emissions for the two toxics that are in the resin: phenol and formaldehyde. Their analysis, based on a destruction efficiency of 99.99% in the boilers, indicated that emissions of these toxics would be below the TEPRs of 0.04 lb/hr for formaldehyde and 0.24 lb/hr for phenol; and therefore modeling would not be required. However, they only included the net (incremental) increase due to burning biomass at 10% heat input and 90% coal, compared to burning 100% coal in all three boilers. DAQ informed Progress that total toxic emissions from each affected source (where biomass is to burned) must be included in the toxics demonstration and questioned the validity of using a 99.99% destruction efficiency. DAQ requested a modeling demonstration using a 98% destruction efficiency for the toxics. Progress submitted this demonstration for burning biomass at 10% heat input for the boilers, a destruction efficiency of 98% for the three boilers, and including all facility-wide emissions for each of the two toxics. This demonstration showed the maximum ambient impact to be approximately 7.7% of the formaldehyde AAL and 0.02% of the AAL for phenol.
Information submitted with the application indicated there would not be an increase in any criteria pollutant except for a negligible increase in VOCs. DAQ questioned the emissions of CO, PM, PM-10 and NOx since there are no definitive AP-42 emission factors for burning biomass and the information submitted by Progress for other facilities burning biomass varied widely depending on boiler configuration, type of biomass and other parameters specific to those facilities. Therefore, DAQ is requiring testing for biomass (see Section VII.A below) to determine emissions of CO, PM, PM-10 and NOx to demonstrate that the PSD significant levels are not exceeded. After submittal of the test results, DAQ will determine whether additional testing is required, whether emissions are greater when burning biomass compared to burning coal, and whether the permit can be revised to allow burning of biomass.
Originally Progress wanted to burn biomass in all three boilers, but later decided to burn biomass only in the Unit 1 and 3 boilers. A permit (No. 01318T21) will first be issued for the biomass equipment along with a requirement to stack test to determine emission rates for CO, PM and PM-10 when burning biomass; then after submittal of the test results, and if approved by DAQ, the permit will be revised to allow burning of biomass not to exceed 5% on a pounds per million Btu heat input basis per unit for the Units 1 and 3 boilers.
The facility has been operating under Permit No. 01318T18. Permit No. 01318T19 and Permit No. 01318T20 were petitioned and were therefore not in effect. An application to renew Permit No. 01318T18 has been timely filed, so that an application shield pursuant to 15A NCAC 2Q .0512(b)(1) remains in effect. This Permit No. 01318T21 shall not expire until the renewal permit has been issued or the request has been denied, and all terms and conditions of the existing permit shall remain in effect until the renewal permit has been issued or the request has been denied pursuant to 15A NCAC 2Q .0513(c).