A substitute for 2012-09 has been offered by Assembly members Nadine Winters and John Davies. It only adds to Coal-Gate.
The proposed substitute leaves what emission standard up to subjective interpretation. What defines a “in a similar category“?
Section 2 (proposed change underlined, substitute in bold): “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 in a similar category.”
Is “category” based on both device design and fuel type? An auger-fed coal boiler has an auger like a wood-pellet stove but are they “in a similar category”? Emission products from burning coal are fundamentally different from wood. Burning coal releases a rich collection of toxic metals. Burning coal also releases high levels of sulfur and nitrogen oxides gases which convert to PM 2.5 in the atmosphere. Wood doesn’t.
Emissions from a coal boiler are not similar to those from a wood burning appliance. Call us extreme, but a coal boiler is nothing like our wood stove. Do you think a coal boiler is similar to your wood-pellet stove or boiler?
Bottom line, who decides? If the substitute amendment is approved, the Assembly has handed this vital distinction over to the “discretionary authority” of staff. These are the same staff who, under existing code on Jan 24, 2012, used their “discretionary authority” to approve the Titan 2 coal boiler–based on emission tests conducted only at low burn. Titan 2 was not run at maximum emission rates as required by EPA for testing wood-pellet hydronic heaters.
The Borough used EPA’s emission limits for wood or pellet hydronic heaters, also called outdoor wood boilers, to approve Titan 2. If borough staff already have the authority to approve Titan 2, why push Section 2 of 2012-09? The change is needed to allow the borough to approve coal-burning appliances according to sponsor Nadine Winters:
“It came up recently that a coal burner didn’t have an EPA standard. What this [original proposed ordinance] does, is if there is no standard as long as it meets an equivalent standard it can be approved.” [APCC hearing 1/31/2012, discussion of 2012-09 Audio CLICK HERE]
Why would the sponsors give staff such free rein to approve more coal appliances? If approving Titan 2 was a one-shot deal, why give staff broad authority to approve even more coal-burning appliances?
Are Borough staff capable of properly overseeing tests of heating appliance emissions? At Borough staff request, OMNI lab in Portland, Oregon, conducted 2 test runs on Titan 2:
- Only at low burn by Borough order, not maximum burn rate. EPA emissions limit standard for a wood or pellet hydronic heater requires at least two test runs at “maximum burn rate“. Decker, the manufacturer of Titan 2, expected it to be tested a “full run capacity,” email from OIT/Northland Fuels to OMNI, 5/25/2011, p 6.
- In a warm warehouse at 75ºF and 78ºF, highly unusual temps for a Fairbanks winter. This concern was raised by Jim Conner in an email on 6/6/2011, the day before Titan 2 was tested.
- May have used “a regular garden hose to run cold water through one side of the heat exchanger….” Suggested by OIT/Northland Fuels in 5/25/2011 email to OMNI, p 6. EPA requires for “all test runs, the return water temperature to the hydronic heater must be equal to or greater than 120°F.” See p 27 of EPA Phase 2 partner agreement.
- Results found Titan 2 emitted many times the lead and selenium compared to devices burning other fuels (OMNI Appendix A #29).
- Did not test for beryllium or mercury known in Healy Coal, USGS report, Healy Coal Quality. Lead, selenium, beryllium, and mercury are designated as hazardous air pollutants (HAPs) by the 1990 Clean Air Act Amendment.
- Results found Titan 2 emitted the most grams per hour of sulfur and nitrogen oxides of the 9 devices tested (OMNI Report, p 17). These noxious gases convert to secondary PM 2.5, but no consideration was given to secondary PM 2.5 impacts to our nonattainment air.
Pretend Titan 2 was burning wood pellets. OMNI lab testing of Titan 2 did not follow EPA’s testing procedures for pellet hydronic heaters. The tests did not reflect real winter conditions. However, Titan 2 burns coal, not wood or pellets. EPA has never approved a coal-burning appliance. EPA is proposing tighter wood-burning emission limits this summer which may include tighter limits on wood-fired hydronic heaters. EPA is not considering an emission limit standard for coal boilers or coal stoves because of “significant emission concerns” and a lack of data.
Other Coal-Gate posts:
- FNSB Coal-Gate: Borough Illegally Approves Coal Boiler
- 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