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Strategic Air Planning: Is the time for a PAL here?

Strategic Air Planning: Is the time for a PAL here?






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    Strategic Air Planning: Is the time for a PAL here? Strategic Air Planning: Is the time for a PAL here? Presentation Transcript

    • Strategic Air Planning:Is the time for a PAL here? John Egan All4 Inc. NCASI 2011 Northern Regional Wausau, WI May 19, 2011
    • Agenda  Mounting air pressures  Mill needs and expectations  Major new source review struggles  Importance of strategic planning  Considerations for an advantage2
    • Air Pressure  NAAQS  Boiler MACT/CISWI/NHSM  Pulp & Paper MACT/Residual Risk  GHG Regulation  BART/Regional Haze  Utility MACT/NSPS  Multi-pollutant Rules  Black Carbon  More…3
    • Air Pressure  Common theme: For most facilities future emissions will decrease from historic actual levels as a result of new and developing air regulations and standards, regardless of growth in productivity.4
    • Mill Needs  Ability to change operations/equipment quickly and as needed  Long range targets for planning: • Internal - production/energy/economics • External - rule driven costs to comply  Clarity in regulatory requirements particularly for permitting5
    • New Source Review  NSR reminder: • Attainment Area = Prevention of Significant Deterioration (PSD), allowed to increase actual emissions but always a challenge • Non-attainment Area = Non-attainment New Source Review (NNSR), project has to improve area air quality6
    • PSD Implementation  Quick PSD implementation history for mill changes: • Old/old way (pre-reform) • Old/new way (post-reform) • New/new way (current & post 1-hr NAAQS)7
    • Old/Old PSD  Pre-NSR reform: • Actual-to-potential test • New limits to reduce PTE and avoid PSD • BACT main driver if PSD triggered • Air modeling a challenge for some pollutants but manageable • Implementation evolved over 25 years8
    • Old/New PSD  Post-NSR reform: • Actual-to-projected actual test • Better baseline/no new limits (supposedly) • Required to track relative to projections • Formal guidance evolved but limited • If PSD - BACT still a driver and air modeling still a challenge for some9
    • New/New PSD  Current & post 1-hr NAAQS: • Still actual-to-projected actual test • Concern w/excluded emissions • How to handle project on project • Watch out for netting • If PSD - air modeling more critical than BACT and can alter project design10
    • Future Planning  Strategic planning for facility future must consider implications of both new air rule applicability and air permitting implications: • New rules likely require facility changes • No exemption for pollution control projects • Permitting issues can impact project design11
    • Future Planning  Air issues must be integrated into facility operations planning  Result will be same old push/pull for mill projects whether needed or required: • PSD applicability analysis • Potential impacts to project design, cost, schedule • Confusion and frustration12
    • PAL Option  “Plantwide Applicability Limitation” (PAL) is an available regulatory option that can potentially ease air permitting PSD cycle  Federal PSD rule provides for PALs based on historic actual emissions  PALs are pollutant specific and could be a critical part of a Mill strategic plan13
    • PAL Advantages  For a facility with a PAL permit that maintains emissions below PAL, physical changes and changes in method of operation are not major modifications and do not require approval under PSD14
    • Why a PAL Now?  PALs historically worked for relatively simple industries with limited sources and where technology was driving emissions lower per unit of production  New air quality world we are in is forcing mills to realization that future emissions will be lower per unit of production driven by rules, standards, permitting, technology…15
    • Why a PAL Now?  Must be able to track and report emissions against PAL  Historically mills saw too many sources and not enough data to justify a PAL  Data and tools now available for demonstrating compliance due to other rule activities (e.g., ICR work)16
    • Establishing a PAL  Same baseline actual emissions used in PSD applicability assessment: • Adjust for current applicable requirements • Add PSD significance threshold • Justify PAL and provide method of compliance17
    • PAL Concerns  PAL established for 10 year period  PAL can be adjusted down to account for new applicable requirements  Getting out of a PAL can have serious ramifications  State/local air construction permits may still be required18
    • PAL Planning Approach  Develop historic mill-wide baseline emission rates and potential PAL levels  Address potential NAAQS issues  Consider new rules, mill operations plans, potential energy efficiency improvements, new technologies, low hanging fruit for emissions reductions  Weigh value of PAL for each pollutant19
    • Final Thoughts  For typical mill projects PSD is no longer a consideration under a PAL  For planning mill now has a clear bright line it can manage operations to  Project timing may result in competitive advantage  Future second guessing by agency of PSD applicability decisions and potential enforcement issues off the table20
    • Questions? jegan@all4inc.com All4 Inc. 2393 Kimberton Road P.O. Box 299 Kimberton, PA 19442 610.933.5246 x14 and x20 www.all4inc.com21