Successfully reported this slideshow.
We use your LinkedIn profile and activity data to personalize ads and to show you more relevant ads. You can change your ad preferences anytime.

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

1,333 views

Published on

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.

Published in: Technology
  • Be the first to comment

  • Be the first to like this

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

×