Regulatory Authority and Invitation to Comment
Metro Vancouver has been delegated authority for air quality emissions regulation by the Ministry of Environment and Climate Change Strategy. Metro Vancouver Bylaw 1082, 2008 adopts the notification practices and procedures of the Public Notification Regulation promulgated under the Environmental Management Act. Additional details can be found on Metro Vancouver’s Air Quality Regulatory Program website.
In accordance with such regulations, the public is invited to submit comments by December 28, 2020. Comments on this application may be submitted on the Metro Vancouver website, or to Metro Vancouver’s Air Quality District Director by email or mail:
Metro Vancouver website: Online Form
By email: UBC.BRDFcomments@metrovancouver.org
By mail: Air Quality District Director, 4730 Kingsway, Burnaby, B.C. V5H 0C6
Air Quality Permit Notification and Consultation
UBC Energy & Water Services is currently seeking an amendment to its air emissions permit for the Bioenergy Research and Demonstration Facility (BRDF) to reflect recent process changes and optimizations.
The amendment process required UBC to conduct predictive air emission dispersion modeling to anticipate effects from these operational changes on the local air shed. Two modelling scenarios were completed:
- Air dispersion modelling of the existing permit emission sources, including the Steam (biomass) Boiler and the IC Engine; and
- Air dispersion modeling of the above listed (two) permitted emission sources, plus the emissions from a new Hot Water (biomass) Boiler. The Hot Water Boiler will be regulated by Metro Vancouver bylaw and not by permit.
The addition of the Hot Water Boiler is a major part of UBC’s overall strategy to reduce CO2 greenhouse gas emissions annually from 2007 levels, and is a concentrated shift away from the use of the Campus Energy Center’s (CEC) natural gas boilers to renewable energy, which will have a corresponding reduction in total campus emissions.
Although our permit application reflects a 40% reduction in requested facility emission levels from previously permitted levels, the associated predictive air dispersion modelling does indicate individual exceedances of Metro Vancouver’s ambient air quality objectives and the 2020/2025 Canadian Ambient Air Quality Standards (CAAQS) for the parameter of NO2 at localized areas near the facility. No other parameters modeled exceeded these objectives; in fact, they were well under. We do note that this modeling effort is considered the “worst case scenario,” and that the facility will not consistently operate at such maximum conditions. We further note that a large part of the NO2 exceedance value consists of background (existing) concentrations that exist in the air shed even before UBC’s contributions, including from large emitters like the Vancouver International Airport. For example, background concentrations at UBC (before BRDF facility emissions are included) constitute over 50% of the 2020 CAAQS guideline and almost 80% of the 2025 value.
Previous historical air dispersion modeling for the opening of the BRDF also projected exceedances; however, annual emissions data collected from UBC’s real-time, regulatory-grade air emissions monitor at the Marine Drive Residences has repeatedly shown that actual emissions do not rise to the level and frequency that the model predicts. Thus, we believe that significant conservativism is built into the model that would likely nullify much of the predicted exceedances.
The emissions for the new biomass boiler will be authorized separately from this process, as this boiler is considered a low-NOx boiler and will otherwise meet all registration requirements under Metro Vancouver Bylaw 1087, 2008.
What causes the BRDF emissions?
UBC’s BRDF utilizes a combustion process to generate thermal energy. With the retirement of the dryer, the major components of this system include a steam boiler and an engine, fueled by biomass and upgraded biogas (i.e. a mixture of natural gas and renewable natural gas), respectively. Each is considered a point source for air emissions. The new HW boiler will add a third emission source, although this will be separately regulated under Metro Vancouver Bylaw 1087, 2008.
Are the facility air emissions increasing?
As a facility, the total BRDF emissions (tonnes/year) have dropped so significantly that UBC is only seeking a permit amendment for 60% of its previous emissions to align to its operational model. Essentially, process changes and optimizations have made the steam boiler much more efficient and the dryer has been removed from service.
The addition of the new hot water biomass boiler, which is a major part of UBC’s overall strategy to reduce CO2 greenhouse gas emissions annually from 2007 levels, will increase emissions in the air shed from the facility; however, the increased emissions at BRDF will be offset by a corresponding drop in emissions at UBC’s Campus Energy Center and its natural gas-fed boilers
How are emission levels monitored?
As required by its air emissions permit, UBC ensures that annual stack emission testing is completed in early winter every year. A third-party contractor conducts and provides an emissions report that is submitted to Metro Vancouver. In addition, a real-time, regulatory-grade monitoring station installed at the Marine Drive Residences since 2012 records hourly emissions data for analysis. This provides UBC with real-time data and has been used to compare to previous air quality predictive modelling results.
How does the BRDF produce energy from biomass?
Biomass is gasified to produce a clean synthetic gas (syngas), which is combusted to generate steam for heating campus buildings. The facility also houses a cogeneration engine that uses a mix of natural gas and renewable natural gas (upgraded biogas) to generate electricity as well as steam and hot water through recovered heat.
How will the upgrades help UBC meet its climate action goals?
The BRDF currently produces 8.4 MW of thermal energy, accounting for 25% of the total annual heating and hot water needs for the campus in winter and 100% in the summer. When the new boiler becomes operational, the expanded facility will see its heating production capacity increase to 20 MW, effectively providing up to 70% of annual thermal production for UBC’s hot water district system and reducing the utility’s current dependency on natural gas by 50%. This will result in a drop of an average of 14,500 tonnes of CO2 greenhouse gas emissions annually and $1 million in annual reductions to operating costs. It is in addition to the average 8,500 tonnes of CO2 in annual emissions already saved by the current size of the BRDF.
For questions, please contact Jamiann Questa, Director, Environmental Protection, Safety & Risk Services at firstname.lastname@example.org.