Impact of Regulations on Wood
Pellets Manufacturing Industry
Atlanta, GA ♦ October 24, 2013
Anupama Krishnan
Outline
˃ Why Wood Pellets?
˃ How are Wood Pellets Made?
˃ Impact of International Regulations on
˃
˃
˃
˃
Growth of Industry in the U.S.
Regulatory Applicability
Results of Testing and Impact on PSD
Applicability
Case Studies
Impact of Biomass Deferral Rule Vacatur for
Industry
What is a Wood Pellet?
>
Raw wood compacted into a
homogeneous product


Processed residues (i.e., chips,
bark, sawdust by-products)
Unprocessed residues (i.e., tree
tops, branches, non- saleable
wood, forest thinning)
Uniform-size cylindrical
shapes
> Variety of fuel applications
>


Residential heating appliances
Large scale boilers in
commercial operations
Raw Wood vs. Wood Pellets
Parameter
Raw Wood
Wood Pellets
Energy Density
Low
High (similar to
coal)
Moisture Content
50%
<10%
Bulk Density
Low
High
Why Wood Pellets?
˃ Every ton of pellets used vs. oil reduces
CO2 emissions by about 1.5 tons
˃ Wood pellets have a fossil energy ratio
(net energy output/fossil energy used) of
12:1
˃ Good for the environment



Improves air quality
Better waste management
Sustainable sources
How are Pellets Manufactured?
Pelletizing
Drying
Material Processing
Cooling
Storage
Wood Pellet Carbon Cycle
Source: Enviva (2/12)
International Interest in Wood
Pellets
˃ Europe has incentives for using
renewable fuels





Rising fossil fuel prices
Tax on fossil fuels
Green electricity certification
system
Big push to reduce CO2 emissions
Large-scale boiler applications and
residential furnaces with secure
supply of wood pellets
International Interest in Wood
Pellets
˃ Islands are looking into sustainable
sources
˃ Low conversion costs for utilities

Coal to wood pellets
˃ Predictable and reliable
˃ Sustainable raw materials
Why Manufacture in the USA?
> Largest privately owned and sustainably
managed forest resource in the world
> Can easily export wood pellets both east
to Europe and west to Asia
> The primary product grown by Southeast
U.S. timberland owners is softwood saw
timber

Southern yellow pine
Southern Yellow Pine
> Commonly found in
Southeast U.S.


Grows well in acidic soils
More than 32 million
acres of pine are grown in
the southeastern U.S.
(Forest Nutrition
Cooperative)
> Has a lower density

Easier to chip and mill
into pellets than
hardwood
> Grows relatively fast

~20 years
Wood Pellet Mills – North America
Source: Klean Industries
Wood Pellet Trade Flow
Source: USIPA Conference (10/12)
Future Wood Pellet Production
Source: Global Wood Pellet Industry Market and Trade Study (12/11)
Federal Regulations Applicable to
the Wood Pellets Industry
˃ CAM – potentially applicable for control devices
˃ NSPS Subpart Db (Steam Generating Units) or
NSPS Subpart Dc (Small Steam Generating Units)
potentially applicable if heat source uses steam
to heat dryer or if it creates steam for other
process operations
˃ NESHAP


Subpart DDDD (PCWP MACT) – not applicable since
adhesives not used for pellet formation
Boiler MACT or Boiler GACT – potentially applicable
to heat source used to generate steam
˃ Engine NSPS/NESHAP for generators or
emergency fire pumps
Sound solutions delivered uncommonly well
Impact of Post-Dryer VOCs on PSD
Applicability
˃ Initial facility designs did not account for any
post-dryer VOC emissions
˃ Later testing conducted at several facilities
indicated very high amounts of VOC emissions
from the post-drying process – hammermills,
pelletizing and storage
˃ Facilities may require PSD permitting with
BACT, or consider expensive VOC controls for
PSD avoidance
Sound solutions delivered uncommonly well
Possible Compliance Testing
Requirements
˃ Heat Energy Source/Dryer Stack
 VOC
 CO
 NOX
 PM/Opacity
 Formaldehyde
 Methanol
 Acetaldehyde
˃ Post-Dryer Sources Stacks
 VOC
˃ Initial testing requirements likely; annual or
biannual testing requirements dependent on
testing results
Sound solutions delivered uncommonly well
Use of Testing Data
˃ GA EPD recommended wood pellets industry VOC
emission factors based on engineering testing
results for Georgia Biomass facility
˃ Testing results can vary greatly depending on
process, type of wood, control methods, etc.
˃ If test data is unavailable for a site, EPD will
accept test data from another site with a similar
process; however, testing will be required to
confirm emissions values

If actual test results are much higher than PTE in
application (e.g., above PSD major source
thresholds), the site faces potential compliance
actions
Sound solutions delivered uncommonly well
Impact of Biomass Deferral Rule
Vacatur
˃ Vacatur of rule may have significant impacts on
the future of this industry in the U.S.
˃ GHG emissions from wood pellets and other
biogenic sources can no longer be excluded in
PSD applicability determinations
˃ Facilities may easily trigger PSD for GHGs,
thereby be subject to cumbersome PSD
permitting or avoidance, BACT evaluations and
modeling assessments
˃ If U.S. becomes a less profitable market for wood
pellets, Europe may well turn to emerging
markets like Brazil to fulfill demand
Sound solutions delivered uncommonly well
Pellet Facility #1 – Regulations
Impact
˃ Greenfield site
˃ Originally permitted as Title V major, PSD
minor source
˃ Internal testing revealed significant VOC
emissions from post-dryer sources not
previously accounted for
˃ Received Consent Order from EPD and
installed RCOs on post-dryer sources to
remain PSD minor source
˃ Incurred significant financial penalties
Sound solutions delivered uncommonly well
Pellet Facility #2 – Regulations
Impact
˃ Conversion of existing wood product facility
into wood pellet production
˃ Originally permitted as Title V synthetic
minor
˃ EPD permitted as Title V major source, to be
confirmed with testing
˃ Operation limitations accepted to avoid PSD
permitting

No VOC emissions controls for dryer or postdryer operations
Sound solutions delivered uncommonly well
Pellet Facility #3 – Regulations
Impact
˃ Future conversion of an existing wood pellet
facility
˃ Previously permitted as synthetic minor with
respect to Title V
˃ Revise permitting based on new testing data
from sister facility site for post-dryer VOC
emissions for PSD avoidance
˃ Revise permitting for vacatur of biomass
deferral

Natural gas usage instead of biomass for
combustion for PSD avoidance
Sound solutions delivered uncommonly well
Thank You!
Questions?
Anupama Krishnan
akrishnan@trinityconsultants.com
Ph No.: (678)-441-9977
Sound solutions delivered uncommonly well