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To: Brian Shrager, EPA/SPPD 

From: Amanda Singleton, ERG 

Date: July 2, 2010 

Re: Minutes of Bagasse Industry Meeting – June 30th, 2010 

Meeting Attendees 

Sean O’Keefe, Hawaii Commercial and Sugar Company 

Jose Alvares, Sugar Cane Growers Cooperative of Florida 

David Dee, Industry Counsel 

David Buff and Jeremy Paul, Golder Associates 

John Fanjul, Okeelanta Corporation 

Kathy Lockhart, Sugar Growers Cooperative 

Peter Briggs, US Sugar 

Ben Shelden, HDF 

Brian Shrager and Jim Eddinger, USEPA 

Amanda Singleton, ERG 

Meeting Agenda 

 Brief Sugar Industry Overview 

 Need for Bagasse Subcategory 

 Significant Impacts to Industry if Rule is Finalized as Proposed 

 Other Comments on the Proposal 

Brief Sugar Industry Overview 

There are 22 bagasse boilers located at major sources of HAP. Currently these units are classified in 

the dutch oven/suspension burner biomass category. The boilers fueling these plants manufacture 

two million tons of sugar annually. 

Need for Bagasse Subcategory 

Industry representatives discussed that bagasse boilers are designed uniquely for bagasse fuel and the 

attributes of bagasse fuel are fundamentally different than other woody biomass. Unlike other boilers 

in the proposed suspension burner/dutch oven subcategory, bagasse boilers are a hybrid of grate and 

suspension design. Smaller fuel particles are fired in suspension while larger fuel particles are fired 

on the grate. The design differences are necessary to burn bagasse, and suspension burners designed 

to combust wood cannot use bagasse as a fuel without significant modification. 

Industry representatives added that bagasse fuel characteristics differ significantly from woody 

biomass with respect to fuel moisture and shape of the feedstock. Bagasse ranges between 48 and 52 

percent moisture. As part of the mill operations the cane is crushed, washed, and injected with water 

in order to extract the sugars from the cane fiber. The resulting fuel is a non-homogenous fibrous 
 

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material. Variability of fiber sizes in the bagasse fuel feed affects furnace temperature in different 

regions of the combustion chamber, which in turns affects formation of carbon monoxide (CO). 

Further, representatives from the industry indicated that boilers designed to burn bagasse are an 

integral combined heat and power process to each sugar plant, providing 100 percent of each plant’s 

steam and electricity needs. The boilers are designed to handle wide fluctuations in fuel feed rates, 

fuel size, and fuel moisture contents that are dependent on field conditions when the bagasse is 

harvested. As a result of these variable milling operations the boilers are designed to operate with 

fluctuating steam loads that vary much more widely than processes operating under steady-state 

conditions. 

Significant and Unique Impacts on the Sugar Industry 

In Hawaii, the one remaining plant fires bagasse from approximately 35,000 acres and in Florida the 

plants fire bagasse from 400,000 acres and employ between 10,000 – 20,000. 

Industry representatives indicated that the each bagasse plant’s capital equipment value was 

approximately $120 to $150 million and that the proposed CO limit would require between 54 and 97 

percent reductions at all units which could require units to replace existing boilers with new boilers, 

at a cost of $30 to $50 million per boiler. CO limits could not be achieved at many units with any 

type of overfire air or other advanced combustion controls. PM emission reduction requirements 

would also be significant for many boilers, between 86 and 92 percent reductions, despite the de 

minimus levels of metallic HAP in the particulate. Further, fabric filter control technology does not 

exist on any bagasse boiler and this control is a fire hazard on the units due to potential sparks in the 

fly ash. 

Other Industry Comments on the Proposal 

MACT Floor Methodology 

 Industry requested EPA to use a minimum of five data points for setting any standard. It 

was noted that standards based on one or two data points do not address variability 

among tests that are necessary to demonstrate achievability.

 Industry noted that bagasse boilers do not have any dioxins/furans test data available. 

Given the absence of chlorinated compounds in the fuel there has never been a concern 

over emissions in the past and the industry requested EPA to consider a work practice 

standard for dioxins/furans a bagasse units. EPA suggested that the industry might want 

to consider completing testing at some of the units although it was recognized that the 

seasonal operation of the units would be difficult to test with respect to the current 

schedule for promulgating the rule.

 Industry suggested that EPA consider ranking units to identify the top 12 percent by the 

average of all test runs as opposed to ranking according to the minimum test run.

 Industry also noted that the pollutant-by-pollutant approach for setting the floor makes 

it difficult to demonstrate that the top performing boilers can meet the limits for all 

regulated pollutants.

Emission Averaging 

 Industry requested that the emissions averaging provision be expanded to cover CO 

emissions. 
 

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 Industry questioned the rationale for including of a 90 percent discount factor for 

qualifying for emissions averaging. Industry preferred emission averaging to use the 

actual heat input instead of the permitted design capacity of each unit in Equation 1 of 

Section 63.722 of the proposed rule. 

Start-up, Shutdown, and Malfunction (SSM) Provisions 

 Industry requested exemptions of start-up, shutdown and malfunction data from 30-day 

rolling averages. As an alternative method for handling periods of SSM, it was 

suggested to insert provisions into the rule to limit start-up time, such as the language 

included in the RICE NESHAP. 

 Industry noted that malfunctions are more frequent in the sugar industry given the crop 

and weather dependent fuel. 

Alternative non-Hg Metallic HAP Standard 

 Industry requested EPA to consider an alternative non-Hg metallic HAP standard that 

facilities could comply with in lieu of a PM standard. The industry noted that metallic 

HAP emissions from bagasse are very low considering the inherent properties of the 

fuel and the additional washing process that the fuel undergoes to extract the sugar from 

the cane prior to fueling the boiler. 

PM CEMS 

 Industry suggested that for units greater than 250 MMBtu/hr with control devices such 

as ESPs or fabric filters, the parametric monitoring data for these devices are sufficient 

for demonstrating continuous compliance with a standard. 

Relationship with PSD/NSPS Programs 

 Industry requested that boiler modifications made primarily to meet NESHAP standards 

should not trigger PSD/NSPS review. There is concern that by modifying the boiler to 

meet low CO standards NOx emissions may increase as a tradeoff of combustion 

modfications. 

Co-Fired Boilers 

 Industry representatives were concerned about the 10 percent annual heat input 

threshold for defining a fuel category as coal versus biomass. The bagasse boilers in 

Hawaii burn coal when sufficient quantities of bagasse aren’t available. Representatives 

from the Hawaii mill indicated that bagasse comprises at least 50 percent of the heat 

input according to a permit requirement. When firing bagasse, these boilers will be 

unable to meet the proposed 50 ppm CO limit for coal-fired boilers. The industry 

suggested that boilers burning a majority of biomass/bagasse should be classified in the 

biomass or bagasse category as opposed to the coal category. 

Additional Data 

 EPA requested that the industry support its submitted comments with all available data. 

The industry indicated that it has submitted 10 years worth of data, where it is available 

and representative of current operating conditions. Industry also indicated that it is 

reviewing its submitted data and submitting corrections in the next month.