Case Study - NSR 2010
Upcoming SlideShare
Loading in...5

Like this? Share it with your network

  • Full Name Full Name Comment goes here.
    Are you sure you want to
    Your message goes here
    Be the first to comment
    Be the first to like this
No Downloads


Total Views
On Slideshare
From Embeds
Number of Embeds



Embeds 5 3 2

Report content

Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

    No notes for slide


  • 1. Case Study - NSR 2010 Colin McCall All4 Inc.NCASI 2010 Southern Regional Meeting Charleston, SC June 29, 2010
  • 2. Agenda  Overview of Project  PSD Applicability Approach  Review Process and U.S. EPA Involvement  Mill Response and Project Impact  Conclusions2
  • 3. The Project  Modify recovery furnace: • DCE to NDCE  Modify combination fuel boiler: • Upgrades for additional biomass/alternative fuels • Overfire air improvements • Steamside efficiency increases  Install new steam turbine generator set and new cooling tower3
  • 4. Positive Environmental Aspects  Recovery furnace modifications: • Low odor conversion • Eliminates BLOX • Predicted reductions in SO2, VOC, CO, PM, PM10, PM2.5, and TRS  Combination fuel boiler modifications: • Projected decrease in fossil fuel • Improved combustion efficiency • Predicted reductions in NOX, CO4
  • 5. PSD Applicability Actual-to-projected actual applicability analysis • Projected actual emissions (PAE) for modified recovery furnace for all but NOX and PM, potential to emit (PTE) for NOX and PM • PAE developed for combination fuel boiler based on Mill business projections • PAE for combination fuel boiler excluded emissions that it could have accommodated during baseline • PTE for new cooling tower5
  • 6. PSD Applicability  PSD Assessment: • Step 1 – Are project emissions increases greater than significance levels? • Step 2 – Are net emissions increases greater than significance levels?6
  • 7. PSD Applicability  Step 1 results: • Project increases alone were significant for NOX, PM, TRS  Step 2 results: • Net decreases from project eliminated TRS • Project was a PSD major modification for NOX, PM7
  • 8. PSD Application  Key PSD application components: • BACT for NOX on recovery furnace • BACT for PM on recovery furnace, combination fuel boiler, cooling tower • Air quality modeling demonstration for NOX resulted in predicted annual impacts below significant impact level (SIL)8
  • 9. Application Review  Application submitted late 2009  State agency reviewed and forwarded to U.S. EPA  Permit was anticipated by early May 2010  U.S. EPA commented in early April9
  • 10. Application Review  U.S. EPA comments: • If permit not issued by 4/12/10 application had to address new 1-hr NO2 standard • Concern w/excluded emissions that boiler could have accommodated10
  • 11. Mill Issues/Approach  Project timing critical date - June 2010  Develop immediate response to U.S. EPA concerns to expedite permit: • Determine implications of short-term NOX impacts • Revisit use of excludable emissions that the combination boiler could have accommodated11
  • 12. Mill Issues/Approach  Short term 1-hour NO2 analysis; • No SIL, no U.S. EPA guidance • Short-term project NOX emissions increases modeled • Results <10% but >5% of new NAAQS • Time for full NAAQS study not acceptable12
  • 13. Mill Issues/Approach  Additional NOX reductions evaluated to: • Determine impact on short-term model results • Reduce project NOX increases to below PSD significance level (<40 TPY)  Resulted in management commitment of significant $$$ to reduce NOX from combination fuel boiler13
  • 14. Mill Issues/Approach  Eliminate use of excludable emissions for combination fuel boiler analysis: • Down-sized new turbine generator set • Incorporated new test data for PM10, PM2.5 and condensables from ICR testing • Incorporate NOX reduction technology14
  • 15. Project Status  Revised approach presented to state agency and support obtained at all levels  Formal update to application submitted and awaiting U.S. EPA review15
  • 16. Project Conclusions  No grandfathering – be prepared for new NAAQS and other requirements (SO2, GHG)  Lack of guidance and tools for new standards will slow process  Concern for ability to demonstrate compliance with new NAAQS will force additional reductions  PSD process under NSR Reform continues to evolve…16
  • 17. Questions? All4 Inc. 2393 Kimberton Road P.O. Box 299 Kimberton, PA 19442 610.933.5246 x20 www.all4inc.com17