Biorefinery Upgrading of Herbaceous Biomass to Renewable Hydrocarbon Fuels, Part 2: Air Pollutant Emissions and Permitting Implications

The development of advanced biofuel production facilities is still at a nascent stage, and the biorefineries could face challenges in obtaining air permits required for their construction and operation because they are novel emission sources. To fill gaps in knowledge regarding potential emissions, we perform a detailed federal regulatory analysis and estimate air pollutant emissions for an advanced biorefinery that produces renewable diesel blendstock (RDB) from lignocellulosic biomass via aerobic respiration documented in Part 1 of the paper. We evaluate 12 design permutations that include two feedstocks, a uniform format blend (UFB) and corn stover; three biorefinery scales, 2,000, 5,200, and 9,100 dry metric tons per day (dmtd) of lignocellulosic biomass feed; and two lignin uses, as either a boiler fuel or for pellet production. We also evaluate 6 additional design permutations by incorporating non-emitting renewable power, which could reduce up to 63% carbon monoxide (CO) and nitrogen oxides (NO_x) each, 21% volatile organic compounds (VOC), and 43% hazardous air pollutants (HAP) as opposed to on-site power production, for biorefineries that produce pellets, using either UFB or corn stover. Our results indicate that all 18 design permutations would be classified as a major source under the Clean Air Act's New Source Review program without additional emission controls. Compared to using lignin as a boiler fuel, diverting lignin for pellet production reduces the emissions of CO up to 88%, NO_x up to 73%, sulfur dioxide (SO₂) up to 99%, VOCs up to 72%, and HAPs up to 66%. Additionally, we explore control options that could further reduce emissions and assess whether reductions are enough to achieve minor source classification. Insights from our analysis can help biorefinery developers and regulators develop permitting strategies to mitigate investment risks.