Strategic Air Planning:Is the time for a PAL here?                        John Egan                          All4 Inc.    ...
Agenda       Mounting air pressures       Mill needs and expectations       Major new source review struggles       Im...
Air Pressure       NAAQS       Boiler MACT/CISWI/NHSM       Pulp & Paper MACT/Residual Risk       GHG Regulation     ...
Air Pressure       Common theme:         For most facilities future emissions         will decrease from historic actual ...
Mill Needs       Ability to change operations/equipment        quickly and as needed       Long range targets for planni...
New Source Review       NSR reminder:        • Attainment Area = Prevention of          Significant Deterioration (PSD), ...
PSD Implementation       Quick PSD implementation history for mill        changes:         • Old/old way (pre-reform)    ...
Old/Old PSD       Pre-NSR reform:        • Actual-to-potential test        • New limits to reduce PTE and avoid PSD      ...
Old/New PSD       Post-NSR reform:        • Actual-to-projected actual test        • Better baseline/no new limits       ...
New/New PSD        Current & post 1-hr NAAQS:         • Still actual-to-projected actual test         • Concern w/exclude...
Future Planning        Strategic planning for facility future must         consider implications of both new air rule    ...
Future Planning        Air issues must be integrated into facility         operations planning        Result will be sam...
PAL Option        “Plantwide Applicability Limitation” (PAL) is         an available regulatory option that can         p...
PAL Advantages        For a facility with a PAL permit that         maintains emissions below PAL, physical         chang...
Why a PAL Now?        PALs historically worked for relatively         simple industries with limited sources and         ...
Why a PAL Now?        Must be able to track and report emissions         against PAL        Historically mills saw too m...
Establishing a PAL        Same baseline actual emissions used in         PSD applicability assessment:         • Adjust f...
PAL Concerns        PAL established for 10 year period        PAL can be adjusted down to account for         new applic...
PAL Planning Approach        Develop historic mill-wide baseline         emission rates and potential PAL levels        ...
Final Thoughts        For typical mill projects PSD is no longer a         consideration under a PAL        For planning...
Questions?       jegan@all4inc.com             All4 Inc.       2393 Kimberton Road           P.O. Box 299       Kimberton,...
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Strategic Air Planning: Is the time for a PAL here?

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

  1. 1. Strategic Air Planning:Is the time for a PAL here? John Egan All4 Inc. NCASI 2011 Northern Regional Wausau, WI May 19, 2011
  2. 2. Agenda  Mounting air pressures  Mill needs and expectations  Major new source review struggles  Importance of strategic planning  Considerations for an advantage2
  3. 3. 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
  4. 4. 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
  5. 5. 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
  6. 6. 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
  7. 7. 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
  8. 8. 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
  9. 9. 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
  10. 10. 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
  11. 11. 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
  12. 12. 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
  13. 13. 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
  14. 14. 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
  15. 15. 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
  16. 16. 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
  17. 17. 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
  18. 18. 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
  19. 19. 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
  20. 20. 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
  21. 21. 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

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