1. Presentation to Board of Forestry November 29, 2011 Alice Edwards Division of Air Quality Alaska Department of Environmental Conservation Email: alice.edwards@alaska.gov

2. Overview Air Quality Health Standards Alaska Regulations Federal Regulations Future ADEC Actions

3. National Ambient Air Quality Standards Ambient health standard of greatest concern from wood/biomass burning is particulate matter (PM) Fine particulate matter standard 35 ug/m 3 for 24-hour period 15 ug/m 3 annually

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

5. 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

7. 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

8. Definitions – 18 AAC 50.990 Wood-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 Equipment Excludes wood-fired heating devices, but includes wood-fired industrial processes Regulated under 18 AAC 50.055 Incinerator Device used for thermal oxidation of garbage or other wastes

9. 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.

10. Emission Standards Other 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

12. DEC Minor Permitting - 18 AAC 50.502(c) PollutantLimitTypical size PM 10 15 tons/yr8.6 MMBtu/hr NO X 40 tons/yr18.6 MMBtu/hr SO 2 40 tons/yr365 MMBtu/hr Lead (Pb)0.6 tons/yr2870 MMBtu/hr CO100 tons/yr38 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

13. 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 Supervisor Zeena Siddeek (907) 465 - 5303

14. Major Permit Requirements Facility emitting 250 TPY or more of an air pollutant 100,000 TPY or more CO 2 equivalent for greenhouse gases On July 1, 2011 EPA deferred, for a period of three years, the application of major source permitting requirements to CO 2 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 http://www.gpo.gov/fdsys/pkg/FR-2011-07-20/pdf/2011-17256.pdf

16. 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

17. NSPS -40 CFR Part 60 Subpart Dc Boiler Standards SO 2 : No limit for wood-fired devices PM 10 : 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

18. NESHAP Industrial/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

19. NESHAP Industrial/Commercial/Institutional Boilers and Process Heaters Area Source rule Existing small biomass boilers must conduct tune-ups every 2 years New 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

20. NESHAP Industrial/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.

21. 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