1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: February 18, 2015

SUBJECT: Technical Support Document

– Maryland’s Biomass Fuel

- Burning Equipment

Standards /s/ FROM: Irene Shandruk, Physical Scientist

O ffice of Air Program Planning

TO: File /s/ THRU: Marilyn Powers

, Acting Associate Director

Office of Air Program Planning

A. BACKGROUND

Biomass materials, which include wood residue and wood products

, animal manure (including litter and other be dding materials)

, vegetative agricultural materials as well as silvi cul tural materials , can be used as fuel burned to provide heat and power . New technologies and environmental initiatives have recently increased the use of biomass material for combustion

. Therefore, the Maryland Department of the Environment (MDE) has established requirements for the combustion of biomass fuel by developing a new Code of Maryland (COMAR) regulation, COMAR 26.11.09.12

– “Standards for Biomass Fuel

- Burning Equipment Greate r Than 350,000 British Thermal Units (Btu)/Hour (hr) Heat Input.”

COMAR 26.11.09.12 allows for the use of small biomass boilers (i.e. 35 mmBtu (million metric Btu)) in urban areas and 13 mmBtu in rural areas ( which are based on historic attainment areas defined in COMAR 26.11.01.03) by replacing the prohibition and exception process in COMAR 26.11.09.04 with specified emission limits requiring the use of particulate matter (PM) emission control technology

. S tate legislation enacted in early 2013 mandate d that MDE revise the existing exception process for solid fuel

- burning equipment in COMAR 26.11.09.04 to allow for potential sources burning biomass to take advantage of new technologies ( See Maryland Laws, Chapter 322, Senate Bill 797). According to MDE , t his amendment removes a time

- consuming analysis and exemption process for solid fuels, except coal, that exists in COMAR 26.11.09.04 and establishes specific emission limitations for biomass fuel combustion in new regulation COMAR 26.11.09.12.

The typ ical type of equipment that is regulated under this new regulation is a boiler, however, it also applies to process heater s or other application s

. The new regulation and additional amendments to several existing regulations under COMAR 26.11.09 are consis tent with federal2

maximum achievable control technology (MACT) standards for boilers with greater than 10 mmBtu /hr heat input in the federal regulation for biomass ( see 40 CFR 63 S ubpart DDDDD)

, and the generally available control technology (GACT) standar ds for boilers with less than 10 mmBtu/hr heat input ( see 40 CFR Subpart JJJJJJ). New biomass fuel

- burning equipment would be subject to stan dards based on MACT, GACT and best available control technology (BACT) analysis

. The regulations also provide add itional standards for PM and nitrogen oxides (NOx) and

, according to MDE, are more restrictive than federal regulations for smaller units

. Additionally, MDE asserts that s mall biomass boilers will need to install PM emission controls , whereas t he NOx emis sion rates for biomass fuel

- burning equipment can be achieved through efficient system design and do not require add

- on pollution controls.

B. STATE SUBMITTAL

On January 12, 2015

, Maryland Department of the Environment (MDE) submitted to EP A a State Im plementation Plan ( SIP ) revision concerning the new biomass fuel

- burning provisions in COMAR 26.11.09.12 and revised provisions in COMAR 26.11.09.10 for inclusion in the Maryland SIP. The SIP submittal also includes revisions to COMAR 26.11.09.01 (2/22/11 , 76 FR 9650), .04 (11/3/92, 57 FR 49651), .06 (7/6/05, 70 FR 38774), .07 (11/3/92, 57 FR 49651), and .09 (5/1/03, 68 FR 23206), which were previously included in the Maryland SIP. The revisions became effective i n the state on April 28, 2014. The follow ing changes are being made to COMAR 26.11.0 9:

Regulation 26.11.09.01

– Definitions

– incorporates the definition of “ biomass. ”

Regulation 26.11.09.04

– Prohibition of Certain New Fuel

- Burning Equipment

– provisions from this regulation do not apply to fu el

- burning equipment installed after March 1, 2014 that burn only biomass fuels.

Regulation 26.11.09.06

– Control of Particulate Matter

– provisions from this regulation do not apply to fuel

- burning equipment installed after March 1, 2014 that burn only b iomass fuels, however, the PM requirements of Regulation 26.11.09.12 will apply to new biomass fuel

burning units.

Regulation 26.11.09.07

– Control of Sulfur Oxides From Fuel

- Burning Equipment

– provisions from this regulation do not apply to fuel

- burning equipment installed after March 1, 2014 that burn only biomass fuels.

Regulation 26.11.09.09

– Tables and Diagrams

– incorrect reference is amended.

Regulation 26.11.09.10

– Requirements to Burn Used Oil and Waste Combustible Fluid as Fuel

– incorrect r eference is amended in this provision, which is a new submission for inclusion in the SIP.3

Regulation 26.11.09.12

– Standards for Biomass Fuel

- Burning Equipment Equal to or Greater Than 350,000 Btu/hr

– This new regulation, establishes PM and NOx standar ds and requirements for biomass fuel

- burning equipment (Table 1) . It furthermore establishes requirements for biomass fuel

- burning equipment where there are no federal standards , and are thereby more stringent than federal requirements

. Additionally, it includes provisions for: startup and shutdown; compliance; and record keeping and reporting.

Table 1: Standards for Biomass Fuel

- Burning Equipment Heat Input Capacity (mmBtu/hr) PM (pounds/mmBtu) NOx (pounds/mmBtu)

≥10 0.03

- 0.07 0.25

- 0.30 >1.5 and <10 0.1

- 0.23 0.30 >0.35 and ≤1.5 0.1

- 0.35 0.30

C. EPA EVALUATION

MDE has adopted the standards and requirements for biomass fuel

- burning equipment and is amending the Maryland SIP to reflect these amen dments. Reduct ions in NOx and PM emissions from biomass fuel

- burning equipment will help Maryland attain and maintain the National Ambient Air Quality Standards ( NAAQS ) for ozone and PM , as well as contribute to Maryland’s greenhouse gas reduction goal

.

D. CONCLUSI ONS AND RECOMMENDED AGENCY ACTION

Maryland’s biomass fuel

- burning equipment regulations will result in the reduction of PM and NOx emissions from biomass

- fueled boilers . EPA ’s approval of the SIP revision is recommended.