Case Study - NSR 2010
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  • 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? cmccall@all4inc.com All4 Inc. 2393 Kimberton Road P.O. Box 299 Kimberton, PA 19442 610.933.5246 x20 www.all4inc.com17