In a mockery of law and public process, on Jan 24, 2012 Borough air quality staff approved the Titan 2 coal boiler for installation in the Fairbanks PM 2.5 nonattainment area.
EPA has no emissions limit standard for coal appliances, so approval of a new coal appliance in the PM 2.5 nonattainment area is prohibited by current ordinance. A new ordinance, 2012-09, would clear the way for more coal devices. It appears air quality staff jumped the gun in approving the Titan 2 coal boiler before receiving Assembly approval.
If approving coal appliances is within the “discretionary authority” of staff, why this change proposed in Ordinance 2012-09, Section 2?
Section 2 (proposed change underlined): “The appliance is tested by an accredited independent laboratory, or other qualified person or entity approved by the borough, establishing that it meets the EPA emissions limit standard appropriate for that appliance or an emissions limit standard equivalent to that of a listed appliance.”
Jan 17: Assembly members write Ordinance 1012-09
Jan 24: Jim Conner, FNSB AQ staff, approves Titan 2, effective immediately
Jan 24: Sierra Research sends critique of the Borough’s $300,000 OMNI lab study to Jim Conner
Jan 26: Ordinance 2012-09 introduced to Assembly, forwarded to APCC
Jan 31: APCC hearing, residents testified against allowing new coal appliances, Sect 2 of 2012-09. Air Quality staff, Transportation Director, and Mayor did not mention Titan 2’s prior approval. APCC voted 5-0 to forward 2012-09 unchanged.
Phone calls to Dr Jim Conner, Mayor Luke Hopkins, and Chief of Staff Jeff Jacobson over the past week were not returned prior to this writing.
Ordinance 2012-09 allows new coal-burning appliances to be approved for installation in the FNSB PM 2.5 nonattainment area if they meet EPA emission limits for outdoor wood boilers. The proposed ordinance would modify current code that has prohibited new coal-burning appliances since July 12, 2010, FNSB Code Chapter 8.21.020 A.1.b.
In 2011, the Borough commissioned a $300,000 study by the OMNI lab in Portland to test nine heating appliances. One was the Decker Titan 2 industrial-scale (440,000 BTU) auger-fed coal boiler, sold by North Pole Coal/OIT, Inc. Comparing against Titan 2 against a coal stove and a coal boiler, the OMNI report concluded: Titan 2 “shows that coal can be burned in a clean manner.” (OMNI Report, p 28)
Cleaner perhaps, but is Titan 2 truly clean? The OMNI report and other evidence show Titan 2 does not burn coal cleanly. A town ranked #4 on Time Magazine’s list of the top ten most air-polluted cities in the nation needs much cleaner heating systems. The last thing we need is to roll what meager air quality protection we have backwards.
Why the Assembly Should Not Allow the Titan 2 Coal Boiler — 16 Reasons
- TESTED ONLY AT “LOW” – At the direction of Jim Conner, Titan 2 was tested only at low burn: “Two tests were performed with this unit at the same heat output rate, which was approximately 35% of the maximum achievable heat output.” (OMNI Report, p 20) Hardly a “worst-case” emission test or even a real world test.
- HIGH IN TOXIC METALS – Even at low, Titan 2 emitted over 265 times more lead than an EPA-certified wood stove (Drolet Escape 1800) and 34 times more lead than an EPA-Phase 2 outdoor wood boiler (Central Boiler 1400). Selenium was also emitted by Titan 2, at levels vastly higher than wood devices. The oil furnace had no detectable emissions of these metals. OMNI Report, Appendix A. Healy coal is high in lead and selenium, USGS report, Healy Coal Quality. OMNI’s tests of coal ash showed no detectable levels of lead and selenium. The metals travel in the smoke.
- SMOKIER THAN OIL – Even at low, Titan 2 emitted over 60 times more PM 2.5 than an oil furnace (Lennox, Elite Series O23 Q34-104/120 #2 fuel oil). Trading out oil furnaces with Titan 2 will make our PM 2.5 problems worse, not better.
- SMOKIER THAN PELLETS – Even at low, Titan 2 emitted twice as much PM 2.5 as a wood-pellet stove (Harman P68). No wood-pellet hydronic boiler was tested, so comparison with that (likely cleaner) unit cannot be made.
- SMOKIER THAN A WOOD STOVE – Titan 2, at low, emitted more PM 2.5 than an EPA-certified wood stove (Drolet Escape 1800, a non-catalytic, relatively high PM 2.5 emitting unit).
- TOTAL PM 2.5 NOT MEASURED – Titan 2 emitted vastly more SO2 and NOx than any other wood or oil appliance tested. For sulfur dioxide, Titan 2 emitted twice as much as a waste oil burner, 11 times more than an oil furnace, and over 240 times more than a wood stove or EPA-Phase 2 wood boiler. (OMNI Report, p 17) SO2 and NOx gases convert into PM 2.5 through a process called “secondary conversion.” OMNI only tested for primary PM 2.5 emissions and did not consider secondary conversion of PM 2.5.
- MORE SULFUR AND NITROGEN OXIDES THAN EVEN WASTE OIL – Titan 2, at low, emitted twice as much SO2 and NOx than a waste oil burner (NuEra 340CS).
- NOT TESTED IN COLD – Titan 2 was not tested at ordinary winter temperatures from zero to -40ºF, but rather at over 70ºF. The moisture content of the coal was 33.5%. The effects on emission from burning cold coal (and ice) in Titan 2 are unknown but can’t be good. Again, not a worst-case emission test or even a real world test.
- INVALID TEST METHOD – to test Titan 2, OMNI used EPA Method 28 for biomas-pellet boilers. This method has never been validated for any coal appliance. Titan 2 is an auger-fed coal boiler not a wood-pellet boiler. Further, “replicate testing was not conducted” and there was “no quality assurance plan” for the study, Sierra Research Critique, p 6.
- USES EPA’S DIRTIEST LIMITS – 2012-09 allows new coal-burning appliances that “meet an emission limit standard” equal to an EPA listed device. EPA’s dirtiest emission limit is for outdoor wood boilers, called Phase 2. EPA-Phase 2 devices are not clean burning. Dense smoke at Woodriver Elementary, largely from two EPA-Phase 2 outdoor wood boilers, prompted residents to report over 140 smoke complaints and describe how they have been injured by the smoke. Smoke forced the School District to install a $44,000 filtration system at Woodriver Elementary but complaints about smoke inside and outside the school continue. Homes near the two OWBs have not sold.
- STRONGER RULES ON THE WAY – EPA is revising the New Source Performance Standards for wood-fired hydronic heaters and considering a cap of 7.5 g/hr. Even at low burn rate, Titan 2 exceeds this emission level. Rushing to allow new coal appliances using EPA’s weak wood boiler emission limits ignores mounting evidence that technology has improved and that current limits fail to protect health. Because of “significant emission concerns” and a lack of data, EPA is not considering approving coal appliances.
- CONFUSING, EVEN DECEPTIVE WORDING – While the proposed ordinance neglects to mention “coal” or “Titan 2,” the language applies only to coal appliances and the only device immediately in line to benefit from this change is Titan 2.
- SPECIAL INTEREST LEGISLATION – Intense pressure to approve Titan 2 has come from the Titan dealer, North Pole Coal, and their associated business OIT. Their “business plan” involves a “large number” of Titan 2 coal burners.
- NO APPEAL – If the Assembly passes this ordinance, the public cannot prevent Borough Air Quality staff from approving Titan 2 or other highly polluting devices and making them eligible for the changeout program. The proposed ordinance gives up all Assembly control of authorization of new coal-burning appliances.
- CUTS OPTIONS – Continued high levels of PM 2.5 and more highly polluting devices leave few options other than burn bans to meet PM 2.5 attainment. Approving Titan 2 sets the stage for forcing attainment through burn bans on responsible wood stove users.
- SETS US BACK ON GETTING INTO ATTAINMENT – EPA and DEC should block Titan 2 on the grounds that it contributes to violations of the PM 2.5 standard, increases frequency and severity of violations, and unnecessarily delays meeting attainment.
Our town needs help reducing smoke that harms residents and to get into PM 2.5 attainment. The poorly tested Titan 2 will set us back on meeting our needs for healthy air.
For more on 2012-09, see:
- APCC Approves More Coal Burning Despite Citizen Pleas
- The Business Plan for More Coal Burning Units
- Testify Tuesday Against Weaker Smoke Ordinance to Air Pollution Commission