December 27, 2012 - Changes to Masco Cabinetry, LLC’s Operating Permit Prompted by CAC’s Comments
On September 21, 2012, the Clean Air Council (Council) submitted comments in response to the Pennsylvania Department of Environmental Protection’s (Department’s) intent to renew an operating permit for Masco Cabinetry, LLC’s Sayre facility, located in Athens Township, Bradford County (Facility). The Facility contains two wood-fired boilers.
The Department took action on two of the Council’s comments. A summary of those comments and the Department’s response to those comments are as follows:
CAC Comment 1: The Clean Air Council commented that the proposed permit failed to indicate a maximum allowable percentage of green wood used for combustion. Green wood contains a higher water content than kiln-dried wood waste and therefore “has the potential to destabilize combustion, leading to greater emissions of products of incomplete combustion (PM/CO/VOCs).” The Review Memo associated with the permit renewal stated that Masco’s two boilers would be “fired primarily on kiln-dried wood waste” but that they “may also fire green wood waste for a combined 336 hours in any 12 consecutive month period.” The Department, however did not provide an analysis of the different impact that these two fuel types have on air emissions, particularly emissions of PM.
PA DEP Response: "The permit file indicates that the Department consequently intended to require mixtures of greenwood fed to the boilers to contain no more than 30% green wood to prevent destabilizing combustion. This condition, however, was at some point erroneously omitted from the permit; therefore, the Department has included the condition in the final version of the renewal operating permit."
CAC Comment 2: The Clean Air Council commented that the proposed permit explicitly required Masco to conduct stack testing using kiln-dried wood waste, which has a lower water content, instead of using a combination of wood types that represents the actual wood types used on a regular basis. The proposed operating permit stated, “All testing shall be performed while Source ID 031 [and Source ID 032 are] operating at [their] maximum rate of production, while being fired on kiln dried woodwaste only . . . .” While this requirement represented the highest load condition, it explicitly required Masco to use kiln-dried wood waste, the fuel source with the lowest potential PM emissions of the three allowable fuel types. This is particularly disconcerting when Masco could, at its discretion, “fire green wood waste for a combined 336 hours in any 12 consecutive month period.”
PA DEP Response: "In response to your concerns, the Department has revised the condition to require stack testing to be performed on a fuel composition representative of routine operation of the boilers, which will included [sic] wood waste, and may include green wood should Masco begin utilizing this fuel type on a regular basis.”