Strategic Air Planning: Is the Time for a PAL Here?

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Mark Wenclawiak of All4 Inc. presents "Strategic Air Planning: Is the Time for a PAL Here?". The presentation discusses PAL permitting to support industrial growth, major New Source Review (NSR) issues, the importance of strategic planning, and why getting a PAL is particularly advantageous.

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  • Good morning and thanks again for the introduction. In keeping with the theme of the conference, I wanted to discuss how air quality permitting can be used to support growth for Georgia industries. Today’s presentation will discuss a topic call Plantwide applicability limits (or PALs), which are certainly not new to those of us that are involved with air permitting, but it is a topic that I feel needs to be re-introduced into the thoughts of industry and environmental professionals as a distinct strategy to achieve a facility’s needs and expectations for growth. We’ll review the pressures that are impacting industry and then briefly discuss what a PAL is but more importantly, how a PAL can be a smart strategic decision for a facility.
  • On this slide is just some of the regulations impacting industry today. These regulations are often requiring significant capital expenditures and complicated permitting efforts to obatin authorization for projects. As the recovery from the recession continues, we are seeing industry revamp and overhaul their growth plans. Significant projects are happening again and the regulatory climate for these projects continues to evolve. Therefore, we must strike a balance between these regulatory pressures and growth.
  • We are seeing a common theme with all these pressures and that is that actualemissions are decreasing and will continue to do so, even as we see gains in production.Traditionally this was not case. Historically in attainment areas actual emissions increases were typically predicted for most projects. Even in non-attainment areas a facility could project an emissions increase so long as offsets were obtained. However, it now appears that the days of multiple ton increases are likely behind us and the new goal looks to be protecting/preserving as much baseline as possible. This is a key observation regarding PALs that we will touch on again later.
  • Let’s face it, we all know that facilities need to make changes all the time.There are internal folks charged with figuring out ways to increase productivity and decrease costs and there are external folks charged with developing and implementing new rules, and the majority of the people in this room are right in the middle between them - which can be an extremely difficult position.Take a typical seemingly simple example – a facility completes an energy study and determines that modifications to a process line will result in substantial steam savings and also allow for a modest increase in production. The steam savings will directly reduce boiler emissions and the project is a real win for the facility and the environment. But guess what, those physical changes to the process line require a PSD applicability analysis and that seemingly simple task can give all of you that have to deal with it a lot of heartburn. And remember – this is a relatively simple example of a clean project. This points to another key concept about PALs and how they relate to air permitting for projects (particularly with respect to PSD) that we will explore later.
  • Know that people are looking hard at compliance options for future rules fuels like boiler MACT & CISWI, also questioning fuels – is it a fuel or is it waste. In planning you can’t forget the permitting – there is no out just because you are only adding APCE. Doesn’t matter if it is MACT, RACT, BART, NAAQS driven – there is no out from air permitting.The other point here is that you also need to consider other requirements in planning process – like NAAQS compliance. E.g., MACT scrubber for HCl will reduce SO2, consider new stacks w/projects to address NAAQS…
  • I know that this has improved over time but you can’t be the last to learn about a project.Opportunities in planning exist – most bang for buck e.g. new stack with new scrubberAlways been a disconnect and is now more critical than ever. PSD process not getting easier – getting worse
  • A “Plantwide Applicability Limitation” (PAL) is an available regulatory option that can potentially ease air the PSD permitting cycle. The federal rules provide for pals based on historical actual emissions. PALs are pollutant specific and could be a critical part of a facility strategic plan…Why???? Recall an earlier slide when we discuss how actual emissions at facilities are trending downward. The use of a PAL allows a facility to preserve that higher baseline emissions. So what so is important about that?
  • For facilities with a PAL, by maintaining emissions below the limit, physical changes and changes in the method of operation (i.e., those that could otherwise be subject to PSD permitting) do not require approval under PSD! What a concept. Plus, decisions regarding process and air pollution control technology now remain with the source, not the agency, as is the case with BACT determinations
  • PALs historically worked for relatively simple industries with limited sources and where technology was driving emissions lower per unit of production (automotive, glass manufacturing)New air quality world we are in is forcing facilities to realization that future emissions will be lower per unit of production driven by rules, standards, permitting, technology…Now have more complex facilities like cement plants and pulp and paper mills seeking PALs
  • Our take is that facilities have always had enough trouble with the complications of air permitting that they have avoided investigating the benefits of PALs. Because PALs require detailed tracking and reporting of emissions, facilities were concerned with the effort associated with developing a PAL application. Now, consider the emissions related work that has likely already been completed over the past years through minor permits, enhanced inventories for reporting purposes and the completion of information requests for regulatory support. By now there should not be emission units at most major facilities that are not identified in a spreadsheet with appropriate emission factors. Therefore, tracking and calculating emissions for PAL purposes should just be a matter of linking production data to the appropriate spreadsheet cells. So how do you establish a PAL?
  • PALs can be established for one or more pollutant. Each PAL is based on a 12-month rolling total expressed in tons per year and compliance must be demonstrated monthly during the permit term.Each limit is generally established based on the average annual (baseline) emission rate for a 24-month consecutive period during the prior 10 years of facility operation. Different baselines can be established for different pollutants. The PSD or nonattainment new source review threshold is then added to the baseline actual emission rate to set the PAL level.
  • Some big picture concerns are highlighted on this slide.The PAL is in place for 10 years and at renewal can be adjusted (and likely it will be adjusted downward). The PAL can be reopened during its term and the limit can be adjusted accordingly – for example for new applicable requirements or to address issues like NAAQS compliance. NAAQS is becoming a driver because as more stringent standards get established, the PSD permitting process unravels at the modeling step – now that means your project may not be able to go at all!PAL termination requirements are included in the regulation. However, if you get out of a PAL, existing federally applicable requirements such as BACT continue to apply.
  • As we touched on earlier, some of the initial drawbacks regarding PALs were related to the efforts associated with developing the application. Again, with the efforts required lately to prepare detailed emissions inventories due to various regulations, the hard work should be done already. Likewise for the methods to demonstrate compliance. As we move forward with policy, it is clear that NAAQS compliance is one of the top priorities for facilities and that is not alleviated with NAAQS. However, to reiterate a point earlier, the benefit of a PAL is that the changes are not considered modifications that required PSD modeling – therefore, if you have done your diligence regarding your naaqs compliance prior to entering into the PAL, you can feel confident that your bases are covered. Also, the PSD reform rules are working, particularly with the could have accommodated provisions that have help reduce the projected emissions increase in the accounting process. More projects are able to not trigger PSD; however, even the work to demonstrate nonapplicability of PSD for a given project is rarely simple. Finally, the PAL permit process does not relieve a facility of complying with requirements such as construction permitting, NSPS, NESHAPs, etc.
  • To summarize the planning steps, It begins with the baseline emissions inventory and identifying the potential PAL levels. Then it becomes an all hands on deck planning session with management, engineering, corporate, and other decision makers to evaluate what the next 10 years for the facility will be from a production basis as well as the types of project that will be implementsNow is the time to address potential NAAQS issues – whether you go for the PAL or not, knowing where you stand with respect to NAAQS will reap many benefits.If you are considering more than 1 pollutant, consider the findings of your planning session and evaluate if a pal for a given pollutant will be too limiting. Will the types of projects under consideration impact one pollutant more heavily (e.g., coating operations may impact VOC emissions more than PM).
  • The PAL allows a facility to implement projects more quickly and efficiently by avoiding the PSD process. This streamlined process may result in a competitive advantage over your competitors.The pal process establishes a bright line that facilities can manage toward rather than managing toward mystical PSD emission thresholds, significant impact levels, increments, BACT and all those PSD related elements that make people cringe.Lastly, it eliminates the liability associated with a mistake in a PSD applicability evaluation that could have dire consequences for a facility.
  • Strategic Air Planning: Is the Time for a PAL Here?

    1. 1. Strategic Air Planning: Is the Time for a PAL Here? Presented to Georgia AWMA by All4 Inc. Mark Wenclawiak, CCM| mwenclawiak@all4inc.com | (678) 460-0324 October 24, 2013 www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324
    2. 2. Agenda  Air permitting to support growth • Plantwide Applicability Limit (PAL) permitting • Not new concept but time for a kick start?      2 Mounting air pressures Facility needs and expectations Major New Source Review (NSR) struggles Importance of strategic planning What is a PAL, how it can be smart strategic decision Your environmental compliance is clearly our business.
    3. 3. Air Pressure     National Ambient Air Quality Standard (NAAQS) NSR Greenhouse Gas (GHG) Regulation National Emission Standards for Hazardous Air Pollutants (NESHAPs) • Boiler MACT  Project happening again • Significant capital expenditures and complicated permitting efforts • Balancing these pressures with economic recovery and growth 3 Your environmental compliance is clearly our business.
    4. 4. Air Pressure (continued)   In years past, actual emission increases predicted and realized from projects Common theme of this new day and age has emerged: 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 Preserve those historically high emissions! Your environmental compliance is clearly our business.
    5. 5. Facility Needs   Ability to change operations quickly & as needed Long range targets for planning: • Internal - production/energy/economics (more production at lower costs) • External – new rules driving up costs to comply • You – caught in the middle  Energy study – modify process line to generate steam savings and increase in production • Emissions from boiler decrease – good thing • But…still need that PSD applicability analysis 5 Your environmental compliance is clearly our business.
    6. 6. Future Planning  Strategic planning for the future must consider implications of both new air rule applicability and air permitting implications: • • • •  6 Lots of rules/lots of issues/lots of confusion New rules likely require facility changes No exemption for pollution control projects Permitting issues can impact project design Do you install scrubber to control HCl for MACT? • Co-benefit: SO2 will decrease as well – how does that impact your NAAQS compliance • Scrubber project many now be desirable Your environmental compliance is clearly our business.
    7. 7. Future Planning (continued)   Air issues must be integrated into facility operations planning Result will be same old push/pull for projects whether needed or required: • PSD applicability analysis • Potential impacts to project design, cost, schedule • Confusion and frustration   7 System for evaluating projects must be established and adhered to Compliance with NAAQS is critical Your environmental compliance is clearly our business.
    8. 8. PAL Option    “Plantwide Applicability Limitation” (PAL) is an available regulatory option that can potentially ease the PSD permitting cycle Federal PSD rule provides for PALs based on historic actual emissions PALs are pollutant specific and could be a critical part of a facility strategic plan…Why???? • Preserve that baseline! 8 Your environmental compliance is clearly our business.
    9. 9. PAL Advantages   9 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 PSD Decisions regarding process and air pollution control technology now remain with the source, not the agency (e.g., BACT) Your environmental compliance is clearly our business.
    10. 10. Why a PAL Now?    10 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 facilities to realization that future emissions will be lower per unit of production driven by rules, standards, permitting, technology, etc. Emerging in complex plants like cement, pulp and paper Your environmental compliance is clearly our business.
    11. 11. Why a PAL Now? (continued)   Air permitting complicated enough Largely avoided up until now • Must be able to track and report emissions against PAL • Historically facilities saw too many sources and not enough data to justify a PAL   11 However, data and tools now available for demonstrating compliance due to other rule activities So how do you establish a PAL? Your environmental compliance is clearly our business.
    12. 12. Establishing A PAL    One or more pollutants (including GHGs) Based on 12-month rolling total (tons/yr) Same baseline actual emissions used in PSD applicability assessment: • 24-month consecutive period during the prior 10 years of operation • Add PSD/NNSR significance threshold 12 Your environmental compliance is clearly our business.
    13. 13. PAL Concerns – Big Picture     13 PAL established for 10 year period PAL can be adjusted down to account for new applicable requirements, NAAQS compliance concerns Getting out of a PAL can have serious ramifications (e.g., BACT) State/local air construction permits may still be required Your environmental compliance is clearly our business.
    14. 14. PAL Concerns – Specifics  Effort associated with developing PAL application • Ahead of the game more than you think  Developing methods to demonstrate compliance • Also likely in place  NAAQS are a driver – know where you stand • Modifications under a PAL will not trigger modeling  But NSR reform rules appear to be working • Could have accommodated • Even non-applicability evaluations not simple  14 SIP permits, NSPS, NESHAPs, RACT, etc. still apply Your environmental compliance is clearly our business.
    15. 15. PAL Planning Approach   Develop historic facility-wide baseline emission rates and potential PAL levels Major planning sessions • Consider new rules, facility operations plans, potential energy efficiency improvements, new technologies, low hanging fruit for emissions reductions   Address potential NAAQS issues Weigh value of PAL for each pollutant • PM and VOC from coating operations 15 Your environmental compliance is clearly our business.
    16. 16. Parting Thoughts      16 Allows you to implement projects quickly For typical facility projects, PSD is no longer a consideration under a PAL Economic and competitive advantage over competitors For planning facility now has a clear bright line it can manage operations to (12-month emissions) Future second guessing by agency of PSD applicability decisions and potential enforcement issues off the table Your environmental compliance is clearly our business.
    17. 17. Questions? Mark Wenclawiak, CCM| mwenclawiak@all4inc.com | (678) 460-0324 www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324

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