Gronstal Anderson, Ingrid, PAL Case Study Plant-Wide Applicability Limit for Campus Air Compliance, MECC, 2016, Overland Park

1. PAL Case Study:
Plant-Wide Applicability Limit for Campus Air Compliance
Ingrid M. Gronstal Anderson, J.D.
University of Iowa

2. Agenda
• University of Iowa campus overview
• PAL permit basics
• University of Iowa PAL
• Innovation example: Biomass fuel project

3. University of Iowa

4. University of Iowa
• Located in Iowa City, IA
• Southeast Iowa
• Population 70,000
• Enrollment of 31,000 undergraduate and graduate students
• 1700 acre main campus, 298 major buildings
• Oakdale campus research park
• Located 10 minutes away from the main campus in Coralville
• Research facilities

5. Campus Community
• Many departments and activities on campus contribute to complexity
in environmental compliance
• University of Iowa Hospitals and Clinics
• Life-safety requirements for generators
• Research facilities
• Classrooms and dormitories
• Teaching equipment (e.g. art kiln)
• Museums
• Building maintenance
• Servers/backup power

6. University of Iowa Utilities
Campus Utilities include: Main Power Plant, Oakdale Renewable Energy Plant, 4
Chilled Water Plants, and Water Treatment Plant

7. Existing air quality programs
• 456 emission sources on campus
• Title V Operating permit for entire campus
• Major source
• Main Campus and Oakdale campus treated as one facility
• Construction permits required for all sources unless specifically
exempted
• MACT, NSPS, NESHAPS
• GHG reporting

8. PSD Challenges
• Major facility for PSD
• Difficult to predict permitting costs, timeline
• Equipment modification/replacement uncertainty
• Project aggregation uncertainty
• Synthetic minor status creates operational constraints
• Justification of BACT for state-funded institution is difficult
• Expanding biomass/renewable fuels is a priority

9. PAL Advantages
• Increase operational flexibility/certainty
• Streamlined project management
• Construct or modify sources without going through PSD applicability analysis
• Transition to biomass fuels with fewer permitting hurdles
• Optimal operation of sources based on campus needs while still protecting
campus air quality
• Streamlined permitting process
• Option to amend limits previously taken for synthetic minor purposes

10. PAL Basics
• Alternate NSR compliance method
• Part of 2002 NSR Reform rules
• 40 CFR 52.21(aa)
• Permit for each criteria pollutant
• Sets cap for criteria pollutant actual emissions. Facility must stay
below cap for 10 years
• 10-year permit
• renew at permit expiration
• If no renewal, must proportion set cap across existing units

11. PAL Basics
• Baseline is calculated from a representative 2-year period within the
last 10 years from the permit application date
• Baseline calculation and emissions cap calculation specified in the rules
• Must stay below facility-wide emission cap
• Cap is 12-month rolling average tons/year of each pollutant
• Monthly emissions tracking
• Must track monthly emissions from all sources to compare facility-wide
emissions to cap.

12. University of Iowa PAL permits
• Effective March 24, 2016
• Seven permits total: PM, PM2.5, PM10, CO, NOx, SO2, VOC
Pollutant Abbreviation
Capped Emission Level
(tpy)
Particulate Matter (≤ 2.5 µm) PM2.5 85.9
Particulate Matter (≤ 10 µm) PM10 97.72
Particulate Matter PM 111.51
Sulfur Dioxide SO2 1602.97
Nitrogen Oxides NOx 751.84
Volatile Organic Compounds VOC 172.75
Carbon Monoxide CO 444.73

13. Monthly Monitoring
• 99% of emissions come from small
subset of sources.
• Prioritize these sources in monthly
monitoring methods.
• CEMS, flowmeters, real time data from PI
data historian
• Stack testing aligned with existing
requirements
• Small sources
• Many sources but small percentage of
emissions
• Worked with IDNR to develop emission
factors
• Stack test or AP-42/worst case
• Work with IT, Energy Control Center
to develop monthly tracking database
and emission calculation reports

14. Additional PAL Considerations
• Unit-specific requirements remain
• Construction permit terms
• NSPS, NESHAPS, MACT
• Construction Permitting
• Construction permits still required for new sources
• Interaction with Title V Program
• Campus air sources that were previously insignificant become significant due
to “applicable requirement”

15. PAL Collaboration
• Collaboration with IDNR key to success of permit process
• Complexity of campus sources and permit novelty required significant
time and effort from UI and IDNR to develop permits

16. 2020 Vision - The University of Iowa's
Sustainability Targets
1. Achieve Net-negative Energy Growth
2. Green Our Energy Portfolio
Consume less energy on campus in 2020 than consumed
in 2010 despite projected growth
Achieve the goal of 40% renewable energy consumption
on the campus by 2020

17. 4,000,000 MMBtu per year

18. 4,000,000 MMBtu per year

19. Biomass Fuel Portfolio
• Industrial byproducts:
• Current: oat hulls
• Future: energy pellets, cardboard recycling sludge, scrap from
furniture making
• Wood chips:
• Current/past: timber stand improvement, pallet remanufacture
• Future: opportunity wood, short rotation woody crops
• Energy grasses:
• Current development: Miscanthus
• Future: prairie and switchgrass

20. Densified biomass
Fuel pellets make use of non-recyclable
industrial byproducts
Partnering with UI Chemistry Department to
quantify emissions changes

21. PROFITABILTY
• ~15% of land within Iowa fields not
profitable in corn
ENVIRONMENT
• Planting ~15% of land within Iowa fields to
diverse perennials provides
disproportionate environmental benefit
ENERGY
• Planting ~15% of land within Iowa fields to
perennial high-yielding energy crops
provides enough biomass
Slide courtesy of Dr. Emily Heaton, Iowa State University

22. Science-based Trials of Rowcrops Integrated
with Prairie Strips www.prairiestrips.org
Slide courtesy of Matt
Helmers, Iowa State
University.
(Helmers, M.J., et al., Sediment removal by perennial filter strips in row-cropped ephemeral
watersheds. Journal of Environmental Quality, 2012. 41(5): p. 1531-1539.)
Photocredit:JoseGutierrez

24. Summary
• Innovative permit unique in the state of Iowa
• Collaboration with IDNR essential to project success
• Increases project planning certainty
• Allows U of Iowa to develop innovative strategies to provide reliable
utilities service to campus, ensure campus air compliance, and pursue
cutting edge renewable energy solutions

25. Thank you
Ingrid M. Gronstal Anderson, J.D.
University of Iowa
(319) 384-0993
ingrid-gronstal@uiowa.edu